Ammonia Standards Program (Code of Practice for Ammonia)

1. Ammonia Standards Program(Code of Practice for Ammonia) Fertilizer Safety & Security Open House April 2008

2. Today’s Agenda • Background • Consultation process • Implementation • Current activity • Discussion

3. Background • The code of practice is an auditable collection of standards covering the manufacture, transportation, and use of Agricultural Anhydrous Ammonia • Code is a book or CD • Supported by an implementation guide • Supported by an appendix of examples and other useful information

4. Drivers • Increasing public concern about ammonia incidents, the meth problem, and terrorism • Increased focus on ammonia from regulators • Desire to harmonise standards across the country • Desire to demonstrate due diligence and manage liabilities

5. Principles • Safety of workers and the public of primary importance • Based on regulations and proven risk management practices • Supported by science and practical experience • Balance risk against economic realities • Integrate the principle of equivalent level of safety • Incorporate best practices • Phase-in approach for implementation

6. Structure of the Program • CFI partnership with the Agrichemical Warehousing Standards Association (AWSA) • Same auditors • Same audit process

7. Structure of the Program Code items are either mandatory or score points Audit fails if any mandatory item is not passed, or less than 80% of points scored in any section Stakeholders must contract with an auditor to have an audit performed on a two year cycle

8. Code Contents • Siting • Storage facility equipment • Transport equipment • Bulk transport • Nurse tanks and applicators • Training • Documentation • Employee knowledge • Emergency Preparedness • Railcar equipment • Insurance

9. Consultation Process • Communication and public consultations held since 2004 • Code posted for comment on FSSC website in March 2006 • Trial audits conducted in AB, SK, MB, ON, PQ • Public awareness and consultation sessions Jan-March 2007 • Competition Bureau opinion received on no-ship policy May 2007 • Code revised as a result of feedback received from stakeholders • Questions hotline: 866-311-0444

10. Trial Audit Results • Trial audit on a full service Ag site in Saskatchewan • Failed audit on several mandatory items • Estimate $1,452 to achieve a pass • Deficiences: • No security on mobile units • Lack of egress in storage tank fencing • Hoses were not pressure tested annually • “Inhalation hazard” signage missing • WHMIS training was required

11. Code Revisions • Details of audit process added • Siting protocol completely revised • Two sets of requirements for existing operations vs three • Risk assessment requirement added (G3) • Insurance protocol completely revised • Sections moved to make more sense

12. Code Revisions • Some regulatory items made mandatory • Additional compliance mechanisms added • Changes to clarify requirements, provide more compliance flexibiliy, and improve auditability • TDG amendment 6 incorporated

13. Current Activities • Auditors trained August 2007 • Technical committee formed to respond to questions about standards • Auditor re-training session on revised code scheduled for June 2008 • Branding the Code as the Ammonia Standards Program ongoing • Completing Appendices • Future goal to extend ASP to other segments of the life cycle of ammonia • Manufacturing, transportation

14. Implementation Schedule • 2007 – 2008 • Two years for awareness and pro-active compliance, voluntary audits • 2009 – 2010 • An audit will be required during this two years. Compliance is still voluntary • Jan 1, 2011 • Compliance enforced • Manufacturers will not ship ammonia to firms not in compliance after Jan 1, 2011

15. Discussion • Questions, concerns, feedback or discussion

16. Thank you!