IIAR

In this issue, we’re presenting news on many exciting activities in our industry and our organization. IIAR is working harder than ever to deliver on its promise to membership: to promote the ongoing growth and health of industrial refrigeration. And this is a theme that touches on so many important goals, including an emphasis on environmental sustainability, future growth through scholarship and research programs and an ever-widening commitment to the foundation work done by our volunteer members through IIAR committees.

In my column this month, I’d like to address a subject that underlies much of the work that IIAR does on behalf of membership, and that is our relationship with the regulatory community.

Regulatory issues are front and center in everything we do now. Our industry is continuing to see increased enforcement activity from OSHA and the EPA, and I’m pleased to report that IIAR has come to the table on many important activities.

We’ve worked very closely with OSHA over the last year, involving decision makers at that agency in the public review process for IIAR-2, one of our most important efforts, and a standard that has the potential to have a real and lasting impact for years to come.

That effort – to work closely with OSHA throughout our standards development process – has paid off in a big way. In June, OSHA released its 2015 guidance to inspectors related to Recognized and Generally Accepted Good Engineering Practices, or RAGAGEP. In that guidance, OSHA referenced IIAR-2 for the first time as the RAGAGEP standard for the industry.

As you know, RAGAGEP plays an important role in how inspectors evaluate a facility’s compliance with PSM. Under the PSM regulation, employers must document that all equipment in PSM-covered processes complies with RAGAGEP.

RAGAGEP, along with inspection and test frequency, must follow manufacturer’s recommendations and good engineering practice, and inspections and tests performed on process equipment are subject to the PSM regulation’s mechanical integrity requirements.

Importantly, the recent OSHA guidance recognizes that PSM does not strictly define RAGAGEP.

Under the new guidance, facilities have the ability to select their own RAGAGEP.

The guidance points to the importance of consensus standards and cites IIAR as a primary source of RAGAGEP.

According to the new guidance, if a facility is properly following consensus standard, then they are likely in compliance. That means that engineering documents and technical papers, like IIAR-2, can also form the basis of RAGAGEP.

The formal reference to the IIAR-2 standard in this important guidance from OSHA is a major step for IIAR and the industrial refrigeration industry as a whole because it represents the first time that the relationship between IIAR standards and best regulatory practices has been acknowledged in writing.

As a result of that guidance, we, as an industry, may now indicate that IIAR-2 should be used as a basis for RAGAGEP in ammonia plant inspections – rather than other standards and guidelines belonging to different, unrelated industries, such as the petroleum and refining industry.

This is a very significant step, given that standards from the American Petroleum Institute have often been referenced in regulation of our own industry, where fundamental differences in RAGAGEP have necessitated costly and drawn-out appeals.

OSHA’s RAGAGEP guidance is just the first in what I hope will be a series of beneficial outcomes as we work ever closer with regulatory agencies.

Next up is an effort to work together as an industry with the Environmental Protection Agency at a local level. Together with RETA, GCCA and other organizations, IIAR is leading an effort to open communication with regional EPA inspection offices.

We’re holding meetings with the heads of those regions, most recently EPA region 1, to discuss and identify common issues they are facing in the field, for example, facility owners not being aware of their regulatory requirements or responsibilities during an inspection. And we’re also collecting data on the number of non-compliant facilities they are finding in a region.

To back up these efforts, IIAR has created a new regulatory member portal, to make standards and other information available to all regulatory agencies, particularly OSHA and EPA.

Alongside that effort, IIAR continues to work with the New Jersey Department of Labor to identify opportunities to initiate change in regulations to make markets like New Jersey more economical for the safe use of ammonia and other natural refrigerants.

All of these activities point to the importance of taking direct involvement in the work of IIAR and our industry. Anyone who operates an ammonia or natural refrigerant facility should find some way to participate in the work of IIAR. Investing in this association can make a real impact when it comes to creating a strong, safe industrial refrigeration industry for the future.