IIAR Standards Shaping RAGAGEP
“There are a number of advantages in having an organization like IIAR come out with standards that are applicable to their own industry,” said Jim Lay, safety engineer, process safety management at the Occupational Health and Safety Administration. “To have clear, easily understood practical guidance on safe system designs and maintenance practices is extremely valuable.”
Peter Thomas, president of Resource Compliance Inc., said regulators want good information. “They aren’t trying to be tricky or apply things inappropriately or make people spend money. They want to learn and want a good resource just like everyone else,” he said.
As the first comprehensive standard for the safe design of closed-circuit ammonia refrigeration systems, IIAR-2 was designed to serve as the single authoritative source document on such systems. “Having regulatory agencies turn to IIAR standards is good for both private industry and the regulators,” Thomas said.
“OSHA, the Environmental Protection Agency and other regulatory agencies are going to have to rely on private industry literature when they make industry standard decisions. Having something written specifically for our interest is best for us and the safest,” he said.
Lay said Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) are a key component of the Process Safety Management standard. “It is a management systembased standard and the RAGAGEP aspect of it gives the employer flexibility to select the codes and standards they are going to comply with,” he said. “Once they do that, OSHA wants them to actually comply.”
Bob Czarnecki, chairman of the IIAR standards committee, said the point of IIAR-2 was to serve as the primary source for the safe design of refrigeration systems. “The goal for IIAR is to have their standards become RAGAGEP,” he said. “The whole idea is to get a RAGAGEP out there that we have input on that applies to our industry and have the inspectors agree with it. Hopefully the end users are adhering to best engineering practices.”
Thomas recently received a memo from an inspector who referenced IIAR-2 standards. “One jurisdiction in California in Monterey County was making it clear they are using the IIAR standard for their standard,” he said.
In the memo, the county inspector wrote, “One of the primary sources of RAGAGEP is IIAR. Others include, but are not limited to, ANSI, ASHRAE, California Mechanical Code, California Fire Code, NFPA, etc.”
“Historically, IIAR published bulletins to document baseline safe maintenance and operation guidelines, like IIAR B109, or IIAR B110,” the inspector wrote, adding that in the past year or so, these bulletins are being replaced with ANSI/IIAR Standards 1 through 8.
Thomas said he delivered a presentation to California regulatory personnel in February on the importance of IIAR standards in understanding RAGAGEP, which he said helped inform inspectors on the latest standards.
“My goal was to explain that for ammonia refrigeration systems, RAGAGEP of choice are the IIAR standards 1-8 with 6 still being developed,” Thomas said. “It’s great to see the hard work of the IIAR and Standards Committee reaping its intended result.”
Thomas said it is important that regulatory agencies have the information they need. “The goal now is to get the word out and to make sure people know the standards exist and how they should be applied,” Thomas said.
Czarnecki said many inspectors have a petroleum or chemical background. “They aren’t necessarily refrigeration people, so they tend to fall on their sources, such as the American Petroleum Industry,” he said. “Have we gotten totally away from that? Probably not. Are we moving in the right direction? Absolutely.”
OSHA has access to the IIAR website, all of their documents and all of their standards at no charge. “They can reference the information all they want,” Czarnecki said, adding that IIAR has worked to train OSHA inspectors to get them to use IIAR information as RAGAGEP. “In the past, inspectors have cited all kinds of best practices that don’t necessarily apply to the ammonia refrigeration industry.”
Lay said IIAR has documents that are clear and straightforward, which is an advantage both for the employers, their facilities and the inspectors. However, he noted that OSHA does not select the RAGAGEP employers must use. “The employer selects the RAGAGEP. If they fail to do so and our inspectors discover hazards, we will refer to applicable standards,” he said.
Lay said many of OSHA’s programs are administered at the state level. “There are 26 state plans,” he said, adding that OSHA has 10 regions. “One of the concerns industry always has is variability in how standards are being enforced region to region. IIAR has been very proactive reaching out to OSHA to offer resources to help mitigate that concern.”
OSHA has modified and made more intensive training for compliance officers to help them have a better understanding of the systems they will be enforcing.
Getting IIAR standards recognized by jurisdictional code is an important part of using the standards for RAGAGEP, Czarnecki explained. “IIAR-2 is recognized in the codes. We made a good stride recently here and got ourselves on an even footing with [the American Society of Heating, Refrigerating, and Air-Conditioning Engineers],” he said.
“We have gotten feedback on IIAR2. Regulatory agencies like it and they are recognizing it as good RAGAGEP for ammonia refrigeration systems,” Czarnecki said.
Lay said he has had a positive experience working with IIAR. “They listened to us and we listened to them,” he said.
Thomas said he has not witnessed anything but positive reactions from regulating agencies, EPA and OSHA, regarding IIAR’s standards. “I think IIAR has a strong reputation in the regulatory community,” Thomas said.
