Work Continues on Existing Facilities Standard

IAR is moving forward on its recognized and generally accepted good engineering practice (RAGAGEP) standard for existing facilities, which is intended to provide guidance for end users and compare their older designs to the new and updated safety standards.

“New and updated standards are applicable for new construction, so the idea is to give them a guideline to compare what is in the new standards and give them a method or procedure to evaluate their existing systems, and implement the practices that need to be updated in their worker-safety programs,” said IIAR President Dave Rule.

The whole idea is to give people something they can lean on to determine what they have to bring up to code.”

Bob Czarnecki, chairman of the IIAR standards committee

Bob Czarnecki, chairman of the IIAR standards committee and recently retired refrigeration program manager at Campbell Soup Co., said, “Basically they are going to spell out, based on the latest standards that are out there, things you must comply with whether you have an old system or not. The whole idea is to give people something they can lean on to determine what they need to bring up to code.”

Eric Smith, vice president and technical director at IIAR said, “Older facilities were built under different codes and standards. As such, they aren’t really expected to have to comply with new standards as they get published or updated. However, there are clearly some technologies and issues that arise which should be addressed by everyone regardless of system age.”

There is often a grey area on what is grandfathered in. “This effort will try to identify those grandfathered questions and add clarity on how to go about updating and documenting your new RAGAGEP for your plant without totally redesigning and rebuilding your facility,” Rule said.

Eric Johnston, chairman of IIAR’s RAGAGEP Standard sub-committee and director of process safety management at American Foods Group, said the proposed IIAR standard for evaluating RAGAGEP scope will provide minimum general safety and systemdesign requirements for all systems no matter when they were built.

It will also provide a method to document adherence to RAGAGEP for new installations of ammonia refrigeration systems, and provide a method for operators of existing ammonia refrigeration systems to evaluate new and revised codes, standards and practices to determine which practices to adopt.

Tony Lundell, director of standards and safety at IIAR, said, “The RAGAGEP standard will also provide a method for existing ammonia refrigeration systems to determine and document that existing equipment that was designed and constructed in accordance with codes, standards or practices that are no longer in general use is designed, maintained, inspected, tested, and operated in a safe manner. It is up to each facility to confirm this for each system.”

Smith said the RAGAGEP standard isn’t necessarily confined to existing facilities. “It could be a new facility which operates under a code that is somewhat outdated. Sometimes states and jurisdictions by legislation are not caught up to the latest codes. It is incumbent on the owner and designer to establish with the code official and within their documents how their facility is being built,” Smith said.

Lundell said the Federal Occupational Safety and Health Administration and Environmental Protection Administration regulations require that each ammonia refrigeration system have its own RAGAGEP, which should be found in the facilities process safety information element of the site’s refrigeration management program, or PSM program if over 10,000 lbs. threshold quantity.

“Depending on the year a system was designed and installed, a site with more than one ammonia refrigeration system more than likely will have different RAGAGEP for each system,” Lundell said. He added that the employer, who may be the owner or an assigned designee, is required to document that the refrigeration equipment complies with RAGAGEP. Determining and documenting the RAGAGEP for each refrigeration system is required for regulatory compliance. Lundell said if the system is audited, it should only be audited to its RAGAGEP. It should not be audited to codes, standards, and guidelines that were not used in its design, installation, or for its operations and maintenance.

Johnston said OSHA published its interpretive memo, ‘RAGAGEP in Process Safety Management Enforcement’ in June 2015, which means it is imperative that IIAR provide guidance for end users on identifying the RAGAGEP that is applicable to the ammonia refrigeration industry.

“If the ammonia refrigeration industry does not identify the applicable RAGAGEP for our industry, then we are potentially leaving our industry open to having other industries, regulatory agencies, etc. define the applicable RAGAGEP for us,” Johnston said.

The initial idea for IIAR’s current RAGAGEP project was conceived well over a year ago when OSHA invited the association to discuss RAGAGEP with them. “As far as industries go, our industry has done a lot to write our own RAGAGEP and not depend on other industries,” Smith said. “OSHA has recognized our efforts and we perceive that citations of other industry standards against ammonia refrigeration systems have waned.”

At the initial meeting, OSHA and IIAR discussed the concept of how older facilities could examine newer standards against their existing facilities and determine which standard practices should be mandatory, which ones should be considered, and which ones could be ignored, Smith said.

“I think OSHA viewed the meeting positively and I think our members will as well, since our members will provide specific guidance on the procedures they need to follow,” Rule said.

Within IIAR, the standard is being developed as a cooperative effort between the Standards Committee and the Compliance Guidelines Committee as well as sub-committees within each. Johnston said the committee is continuing to work on the draft and will create several versions before one is released for public review, which is expected in June 2017.

“Essentially the next step is that the standards committee provides input, modifies the document, and then generally we submit the draft to other members for additional feedback,” Czarnecki said. “We consider and incorporate their comments before we put it out for public review.”

Czarnecki expects to receive a good amount of feedback on the drafts. “Everybody is probably going to have a whole lot to say about it, particularly the end users. The whole idea is to put something out there that is clear and that everyone can follow,” he said.