Tag Archives: RAGAGEP

IIAR 2 and IIAR 4 up for public review

IIAR Standard 2 (Safety Standard for Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) and IIAR Standard 4 (Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) are available for public review on the IIAR website. While being an IIAR member … Continue reading

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Do your Emergency Shut-down and Ventilation switches comply with IIAR2-2008b/IIAR5-2013, Appendix B?

IIAR5 was released just recently and a surprising number of people think that it introduces new requirements for emergency switches. The requirements themselves don’t differ from IIAR2-2008b – they are just laid out a little clearer in IIAR5, Appendix B: … Continue reading

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OSHA is going to have a field day in 2016

The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading

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OSHA to revise Palmer guidance on Hydrostatic Trapping

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading

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OSHA to focus on difficult inspections (like PSM) in 2014

Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading

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Five Year Independent Full Inspection

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading

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Maximum Intended Inventory (1910.119(d)(2)(i)(C))

Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you … Continue reading

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Unclear on the concept…

This one starts simply enough: 1910.119(d)(3)(ii) The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices. In this case the citation is in regards to an MSA gas monitor that wasn’t … Continue reading

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Pressure Relief Valves – The Five Year Replacement Interval

There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading

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Two recent NH3 Refrigeration Fines

US Labor Department’s OSHA cites Rochester, NY, milk products manufacturer, proposes more than $200,000 in fines, for repeat and serious hazards. . $153k of the citations are Repeat citations. . Failing to address the hazards of oil draining in the PHA. … Continue reading

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