Inspection, Testing, and Maintenance (IIAR 6, Part 6)
ANSI/IIAR 6-2019 §5.1 lays out the foundational requirements of an ITM Program. Most obligations in this section build upon an existing MI requirement in the PSM regulations (Title 8 CCR §5189(j) and Title 29 CFR §1910.119(j)).
For example, ANSI/IIAR 6-2019 §5.1 requires that “The owner or owner’s designated representative shall ensure an inspection, testing, and maintenance program is developed to reduce the probability of an ammonia release.” This language carries much of the same intent as Title 8 §5189(j)(1)(A) which states that “The employer shall establish and implement written procedures to maintain the ongoing integrity of process equipment and appurtenances.”
Similarly, §188.8.131.52 requires the frequency of inspections and tests to be “consistent with applicable manufacturers’ recommendations and operating history” which parallels the PSM requirement in Title 8 §5189(j)(2)(C). §184.108.40.206 prescribes that inspection and testing procedures follow RAGAGEP which is also required in Title 8 §5189(j)(2)(B).
As it relates to documenting inspections and tests, IIAR 6 requirements extend far beyond PSM as demonstrated in the table below:
|IIAR 6 Documentation Requirements
ANSI/IIAR 6-2019 §220.127.116.11
|PSM MI Documentation Requirements
Title 8 CCR §5189(j)(2)(D)
|Date of the inspection or test||Date of Inspection|
|Name of the individual or individuals who performed the inspection or test||Name of person who performed inspection or test|
|Serial number or other identifier of the equipment on which the inspection or test was performed||Serial number or other identifier|
|Description of the inspection or test performed|
|Recommended corrective action(s) for each deficiency identified|
|Description of corrective action(s) for each deficiency identified|
|Identification of each designated responsible person assigned and authorized to remedy each deficiency identified|
|Results based on the conditions at commencement of the inspection or test, including instrumentation readings|
|Expected activation set points (+/-) including a functional description of the control logic|
|Results based on the conditions after completion of the inspection or test, including instrumentation readings|
|Expected completion date(s)|
|Actual completion date(s)|
Therefore, to comply with IIAR 6, it is probable that the forms you are currently using to document MI tasks may require modification to align with the requirements of IIAR 6.
This is Part 6 of a series on IIAR 6. You can access previous blogs in this series below: