• SRM's Commitment to You
    • SRM's Covid-19 Commitment
    • About SRM
    • Meet the Principals
  • Services
    • Safety
    • Environmental Services
    • PSM & RMP
    • SmBA Program
  • SRM News Blog
  • Contact Us
Schneider Risk Management - Providing Safety & Environmental Consulting that allows you to do your work without worry.
  • SRM's Commitment to You
    • SRM's Covid-19 Commitment
    • About SRM
    • Meet the Principals
  • Services
    • Safety
    • Environmental Services
    • PSM & RMP
    • SmBA Program
  • SRM News Blog
  • Contact Us

SRM News Blog

IIAR Bulletin Updates and PSM

5/18/2017

 
The PSM Standard requires that employers operate and document that their PSM covered process (e.g., ammonia refrigeration system) operates in accordance with recognized and generally accepted good engineering practices, also known as REGAGEPs (29 CFR 1910.119(d)(3)(ii). 
Picture
​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.

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 requirements for maintaining your ammonia systems.   But, 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.
To view the IIAR Proposed Bulletin 6-201X click here.
To view other IIAR Bulletin Updates click here.
To view the OSHA Policy referencing IIAR Bulletins as REGAGEPs click here.

Comments are closed.

    ARCHIVES​

    April 2021
    March 2021
    January 2021
    July 2020
    May 2020
    April 2020
    March 2020
    February 2020
    May 2019
    April 2019
    February 2019
    January 2019
    September 2018
    June 2018
    May 2018
    March 2018
    January 2018
    December 2017
    November 2017
    October 2017
    August 2017
    June 2017
    May 2017
    January 2017
    December 2016
    November 2016
    October 2016
    September 2016
    August 2016
    July 2016
    June 2016
    April 2016
    October 2015
    September 2015
    July 2015
    April 2015
    March 2015
    September 2012

    CATEGORIES

    All
    2017 Holiday Safety Tip
    Air Permit
    Ammonia
    Beach Cleanup
    Beryllium
    Business
    Cannabis
    CDC
    Community
    Compliance
    Coronavirus
    COVID 19
    COVID-19
    Culture
    EGLE
    EManifest
    Enforcement Alert
    Environmental
    EPA
    Events
    Falls
    Fire
    Forklift
    Generator
    Generator Improvement Rule
    GHS
    Global Harmonized System
    Grilling
    Hazard Communication
    Hazardous Waste
    HazCom
    Heat Stress
    Illness & Injury Logs
    Industrial Storm Water
    Inventory
    Local
    Manifest
    Marijuana
    MDEQ
    MDHHS
    MECC
    Michigan Safety Conference
    MIOSHA
    National Safety Council
    NEP
    NIOSH
    OSHA
    OSHA's Electronic Reporting
    Penalties
    Permit
    PHIT
    Procedures
    Process Safety Management
    PSM
    Recording
    RecordKeeping
    Reporting
    Risk
    RMP
    Safety
    Safety Culture
    Silica
    Smoke Alarm
    SRM
    Storm Water
    SWPPP
    Tier 2
    Toxic Release Inventory
    TRI
    TSCA
    Universal Waste
    USEPA
    Wellness
    Winter

    RSS Feed

Address:
​

2155 W. Sherman Boulevard
Muskegon,  MI  49441
Picture


​© COPYRIGHT 2022. ALL RIGHTS RESERVED.

  • SRM's Commitment to You
    • SRM's Covid-19 Commitment
    • About SRM
    • Meet the Principals
  • Services
    • Safety
    • Environmental Services
    • PSM & RMP
    • SmBA Program
  • SRM News Blog
  • Contact Us