IIAR Initiatives Target Guidance on RAGAGEP for Existing Facilities
By: Tim Facius, IIAR Marketing Committee – August 26, 2016
ANSI/IIAR 9-20XX on Application of RAGAGEP for Existing Systems and IIAR Educational Program on Application of RAGAGEP
Since IIAR’s inception it has been providing advocacy, education and publications which focus on safe, reliable and efficient closed circuit refrigeration systems that use ammonia and other natural refrigerants. At present there are seven ANSI-accepted IIAR standards which deal with safe system design; refrigeration valve considerations; system installation, start-up, commissioning, operating procedures, decommissioning, as well as definitions and terminology. A listing of these standards can be viewed here.
Several of these ANSI/IIAR Standards have become incorporated or adopted into state and municipal codes. As ANSI-accepted standards, all of these ANSI/IIAR Standards are considered published consensus documents. As such, all of these standards are widely used to establish “recognized and generally accepted good engineering practice” (RAGAGEP), and are accepted as RAGAGEP by regulatory bodies such as OSHA and EPA.
However, since the ANSI/IIAR Standards have generally been developed for new systems; system owners and operators with older existing systems have sometimes struggled to develop the required documentation for the Process Safety Information (PSI) and Mechanical Integrity (MI) elements of PSM/RMP requirements within OSHA and EPA regulations regarding determination and documentation of safe practices for these older systems.
Two IIAR initiatives currently under development are specifically aimed at providing clarification as well as a basis for RAGAGEP for existing systems.
ANSI/IIAR 9-20XX, RAGAGEP for Existing Closed Circuit Ammonia Refrigeration Systems
Over the course of the past twelve months, a sub-committee within IIAR’s Standards Committee has been busy at work developing IIAR 9, specifically to provide a sound basis for establishing minimum RAGAGEP in existing refrigeration systems. This sub-committee is chaired by Eric Johnston, Director of PSM at American Foods Group. According to Johnston, there are ten active members on the standards development sub-committee, and another 10-12 individuals lined up to participate in the standards consensus review process. The target is to have the 50 page draft of the standard finalized for presentation to the IIAR board of directors by the February 2017 board meeting at the IIAR annual conference, and out for public review shortly thereafter. States Johnston, “We have a broad base of knowledge participating on this sub-committee, representing end-users from small, medium and large facilities; as well as system designers, system installers and risk-management consultants. This broad spectrum of contributors allows for the establishment of appropriate safety measures and risk management procedures for all sizes of facilities of all ages. IIAR 9, a consensus document, is especially important for older systems because a lot has changed from a safety perspective over the years. Current practices and procedures which will be addressed in this standard better ensure system and operational safety and provide a sound basis for RAGAGEP.”
The IIAR 9 standard will outline system, equipment and component documentation requirements; inspection, testing and maintenance requirements; system and equipment operation requirements; and minimum system safety requirements applicable to all systems. Further, it provides a RAGAGEP evaluation methodology and frequency. Finally, the IIAR 9 standard will provide five informative appendices which provide additional explanatory information and guidance as well as useful examples.
As IIAR 9 sub-committee Chair Eric Johnston states, “Without this new ANSI/IIAR standard, many existing refrigeration system owners are struggling to define appropriate RAGAGEP. Some are still using non-consensus documents such as bulletins that were current at the time of system installation, or gas industry documents. With IIAR 9, existing system owners will be able to use a recognized consensus document as a basis of RAGAGEP for their system, which helps ensure acceptance by regulatory bodies as appropriate RAGAGEP.”
IIAR Conference Education Session, Application of RAGAGEP for New and Existing Systems
At the upcoming IIAR annual conference in San Antonio, TX February 26 – March 1, 2017, the Sunday Educational Session will be focused on the application of RAGAGEP for new and existing refrigeration systems. This will be a four hour session, on Sunday afternoon of the conference, from 1 pm to 5 pm.
Mike Lynch, IIAR Vice-Chair and 2017 Conference Chair strongly encouraged the selection of RAGAGEP as the topic of the 2017 Education Session. “As a result of Presidential Executive Order 13650 issued in April 2013 there has been increased rigor by regulatory bodies in ensuring safe operation of facilities; particularly in the area of well-defined, documented and updated RAGAGEP. Especially in older systems, but even in new systems, we have seen some confusion in the industry over the specifics of RAGAGEP application. This upcoming IIAR Education Session will focus on PSM/RMP requirements as they relate to Process Safety Information and RAGAGEP in order to help our member companies and others to not only ensure safe operation of their systems, but remain in full compliance with OSHA and EPA regulations”, says Lynch.
At the February 26, 2017 IIAR Education Session, a full roster of speakers will cover a variety of specific topics relative to the application of RAGAGEP in both new and older systems. They will include: overview of PSM/RMP, PSI documentation including RAGAGEP, establishing and updating RAGAGEP, discussion of “grandfathering”, review of applicable ANSI/IIAR standards and bulletins, building codes, addressing of conflicts in RAGAGEP requirements and much more. There will also be in depth coverage of technical issues that have changed over time and/or which have been the sources of some confusion, and examples of things not to do or issues that have caused citations. An interactive Q&A session will round out the agenda.
Mike Lynch states, “We are very excited about this Education Session. It will address topics which are very important and relevant not only to end-users of refrigeration systems, but also to contractors and consulting engineers who are called upon to design, install and provide advice for these systems.”
These two IIAR initiatives, the IIAR 9 Standard and the RAGAGEP Education Session, dovetail to provide IIAR members and all who operate closed circuit refrigeration systems the tools to ensure safe operation of their systems and full compliance with safety regulations.