Program Administration (IIAR 6, Part 5)
Who is responsible for implementing an IIAR 6 ITM Program at your facility?
§4.1.1 speaks to that very question:
“The owner or owner’s designated representative shall be responsible for overseeing and ensuring that inspection, testing and maintenance is performed in accordance with the requirements of this standard.”
While the owner or the designated representative is responsible to ensuring that ITM tasks are performed in accordance with IIAR 6, compliance with the standard is voluntary until either of the following occurs:
- Authority having jurisdiction (AHJ) adopts the standard; or
- Owner adopts the standard
Common AHJs include building/fire code officials, OSHA, USEPA, and local enforcement agencies (e.g. a CUPA in California). There typically isn’t an “official” announcement when an AHJ begins applying a new standard for issuing citations, so our industry will likely learn how each agency plans to enforce IIAR 6 in the coming months. We advise all facilities to be prepared to defend the basis (RAGAGEP) for each mechanical integrity (MI) task and task frequency in your PSM program. As stated in Part 1, a facility need not change RAGAGEPs simply because a new standard has been published. Due to the importance of this particular standard, it would be prudent to perform a gap analysis of existing ITM tasks against what is contained in IIAR 6 and adjust your MI program accordingly.
This is Part 5 of a series on IIAR 6. You can access previous blogs in this series below: