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The PSM Standard requires that employers operate and document that their PSM covered process (e.g., ammonia refrigeration system) in accordance with recognized and generally accepted good engineering practices, also known as REGAGEPs (29 CFR 1910.119(d)(3)(ii).
IIAR, a leading advocate for the safe use of ammonia in refrigeration systems, has established a number of “Bulletins” that identify how to operate, calculate relief valve sizes, and inspect and manage ammonia refrigeration systems. They have been commonly used for many years and establish the minimum requirements for industry compliance. |
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On May 11, 2016, OSHA issued an Enforcement Policy entitled “RAGAGEP in Process Safety Management Enforcement.” In this policy, OSHA notes that Consensus documents are often used as REGAGEPs and specifically calls out IIAR Bulletins stating that, “Such consensus documents are widely used as sources of RAGAGEP by those knowledgeable in the industry.”
Recently, IIAR announced that it will be issuing a new Bulletin - IIAR Standard 6: Standard for Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration Systems. This Bulletin was issued on March 30, 2017 for public review and will be open for comment until May 15th, 2017. “This proposed standard specifies minimum criteria for inspection, testing, and maintenance of closed-circuit ammonia mechanical refrigeration systems, including the ammonia side of a cascade refrigeration system.”
According to some in the industry, this new bulletin is going to increase the requirements and documentation for maintaining your ammonia systems. Your Mechanical Integrity Program should already take into consideration the equipment manufacturers’ recommendations. But, be ready to review and potentially update your Mechanical Integrity Program with the standards outlined in Bulletin 106. The document is 129 pages after all. We’ll have an update on some specific changes soon.
Recently, IIAR announced that it will be issuing a new Bulletin - IIAR Standard 6: Standard for Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration Systems. This Bulletin was issued on March 30, 2017 for public review and will be open for comment until May 15th, 2017. “This proposed standard specifies minimum criteria for inspection, testing, and maintenance of closed-circuit ammonia mechanical refrigeration systems, including the ammonia side of a cascade refrigeration system.”
According to some in the industry, this new bulletin is going to increase the requirements and documentation for maintaining your ammonia systems. Your Mechanical Integrity Program should already take into consideration the equipment manufacturers’ recommendations. But, be ready to review and potentially update your Mechanical Integrity Program with the standards outlined in Bulletin 106. The document is 129 pages after all. We’ll have an update on some specific changes soon.
Here is some helpful information:
- To view the IIAR Proposed Bulletin 6-201X click here.
- To view other IIAR Bulletin Updates click here.
- To view the OSHA Enforement Policy referencing IIAR Bulletins as REGAGEPs click here.
