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 Systems

I believe these standards are going to result in significant OSHA general duty and PSM citations for Ammonia refrigeration systems starting in 2016. Why 2016? It’s just how this has worked in the past – when a new standard comes out, OSHA starts enforcing RAGAGEP compliance to it hard and heavy about three years after it has been published.

The IIAR5 standard is ready-made with requirements and checklists that will result in non-compliance issues for nearly every facility whether they meet the PSM threshold quantity or not.  Much of IIAR5 seems sensible on first review though, so those of you who are planning on starting a new process or modifying an existing process need to read this standard and take appropriate steps to come into compliance.

The real problem I think we’re all going to have is IIAR7 concerning operating procedures. First, in my opinion, the IIAR has no business whatsoever developing standards on PSM practices. There’s already an organization for that and it’s called the CCPS. The Center for Chemical Process Safety already has guidance on writing effective operating and maintenance procedures. The guidance is excellent and it’s been referenced by nearly every PSM citation concerning SOPs I’ve seen over the last five years. It’s even directly quoted in the published Refinery PSM NEP.  I’ve discussed this guidance before and my SOPs for the past few years have been written with it in mind.

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You’re going to want to acquire a copy of IIAR7, if for no other reason, to explain in your SOP guidelines why you choose not to follow it. I have already re-written my example SOP guidelines to address some of the issues caused by this standard (and explain that my RAGAGEP of choice for SOPs is the CCPS, not the IIAR) and I imagine they’ll be more revisions to come.

What the IIAR has done in IIAR7 is muddy the water. They’ve sewn confusion on the operating phases and what they mean. They appear to have completely ignored CCPS guidelines and published OSHA NEP guidance and this confusion will result in hundreds of citations if people don’t rewrite their SOP guidelines or their SOPs to take this standard into account.

*I’ll be putting together checklists for these two standards to go with the existing RAGAGEP checklists that are provided in the PSM classes I teach. Look for updates on this subject at www.chemnep.com in the coming weeks.

About Brian Chapin

PSM / RMP Compliance Consultant
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