Project safety management and risk management plans are the subject of a recent IIAR publication update. IIAR has updated its PSM/ RMP manual, a compilation of all relevant Occupational Health and Safety Administration and Environmental Protection Agency requirements that would concern end users of ammonia refrigeration systems over 10,000 pounds.

Drafted in 2011, the manual has served as a guide for developing programs to be in compliance with the regulations set by both federal regulatory bodies, said Jeanna Emmons, chair of the Compliance Guideline Committee. “If you didn’t have any paperwork, you could buy this document and tailor it to your facility’s needs so you could comply with both OSHA and EPA,” she said. While the manual has been used as a tool in developing compliant programs, its organization and accessibility were lacking. “What we did was take that 2011 version and updated it and refreshed it,” Emmons said. “We believe it’s now more user-friendly.”

Making the document easier to digest was an important goal, Emmons said, but it was also important to update the document to reflect modern practices. “It was outdated,” she said. “Regulations and their implementation evolve over time, and we wanted to make sure we captured that. There have been substantial changes [since 2011] in the way the industry implements the document, so the idea was to take the document, have fresh eyes look at it, and have them take it apart, revise, and put it back together.”

Lesley Shafer, IIAR PSM & RMP Program Guidelines Sub-Committee chair, agrees. “Some of the things in the old guidelines, you kind of had to dig through the background and explanations to figure out why you have to do things [in a certain way.] Shafer said. “This [new manual] is a little more useful because it helps people understand why they need to do things and how.”

Shafer explained that the concept was to break up the manual into four discrete parts. The introduction explains at a very high level what the regulations say, and what must be done to satisfy them. This provides baseline information and explanation to users with little institutional understanding.

The second and third elements are the templates and attachments. Available for purchase separately or as part of the complete manual, these new, more userfriendly templates help users create site-specific, compliant programs according to their needs, Shafer said. “With a little tweaking, users can create a program that is in line with the regulations and requirements and is in line with both OSHA and EPA.” The attachments provide insight into why operations are performed in certain ways.

The fourth element is unique to the new manual. The how-to section states the actual language from the regulation and then explains in standard language how to go about satisfying it. “The template will get you to the point that you have the program in place,” Schafer said. “But a lot of people have a hard time following through and actually implementing the things written down in the programs. We’re really excited about this section.”

The revision process began in early 2015, Schafer said, and initially, progress was slow. Over the past year or so, development of the manual has increased dramatically, and the goal is to have a completed draft to the IIAR board for approval in October. Once it’s approved, the manual should be available to the public sometime in early 2019.