RAGAGEP: Historical Variants and the Importance of IIAR Standards | Part 8: Summary and Conclusion
Uriah Donaldson, OHST, presented a technical paper at the 2019 RETA National Conference and 2021 IIAR National Conference titled RAGAGEP: Historical Variants and the Importance of IIAR Standards.
This is the eighth and final post in a series of blogs which include excerpts from his technical paper.
Summary and Conclusion
Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) are written documents intended for use in the design; installation; startup; operation; and inspection, testing, and maintenance of process equipment. Over the last several decades there have been a myriad of documents published which are rightly considered RAGAGEP but differ in requirements at different times in history.
In recent years, IIAR has attempted to become the primary standard writing organization for ammonia refrigeration by developing and publishing ANSI certified RAGAGEP documents. The importance of its suite of standards cannot be overemphasized as they are now referenced in the major model codes adopted by local jurisdictions throughout the United States.
While the primary content of this paper has been to study a small sampling of historical RAGAGEP variants, its goal has been to emphasize the importance of properly documenting the codes and standards used and adhered to at a facility. It is obvious from this short study that RAGAGEP requirements have changed throughout history. Because there is legal precedent in the PSM regulation to document an ammonia system has been designed (as well as operated and maintained) in accordance with RAGAGEP, the implication is that if codes and standards used at a facility are not clearly documented, that facility may be required by regulatory enforcement to upgrade their system (or parts thereof) to the newest codes and standards.
As an example, if an expansion project designed and completed in 1999 included a new machinery room, the emergency ventilation fan could acceptably have been a down-blast type. If, however, this facility did not document the fan was designed and installed in accordance with the governing codes and standards of the time (e.g., IIAR 2-1984 and 1997 UMC, neither of which required emergency ventilation fans to be of the up-blast type), an OSHA compliance officer performing an inspection in 2021 could theoretically require the facility to upgrade its fan to meet today’s codes and standards.
This example highlights two important realities: (1) most facilities should have multiple RAGAGEP documents from different years which apply to their process, depending on the years of initial design and installation and subsequent modifications. (2) most facilities have not kept meticulous records of these historically applicable RAGAGEP documents and therefore may be liable to regulatory enforcement. These realities underscore the importance of ANSI/IIAR 9-2020 “Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems.”
The need for such a unifying standard for existing facilities has been great for many years, as this paper’s historical analysis of RAGAGEP variants has clearly shown. Now, with the publication of ANSI/IIAR 9-2020, if a facility is unsure which codes and standards were used and adhered to in its original design and installation, or subsequent modifications, it can use the Minimum System Safety Evaluation contained in Chapter 8 of ANSI/IIAR 9-2020 to document its refrigeration system has been designed in accordance with recognized and generally accepted good engineering practices.[1]
While complexity often results in confusion, the simplicity of the IIAR’s suite of standards will hopefully lead to unified communication between engineers, end users, and regulatory enforcement.[2]
When the history of a facility is unknown, using IIAR 9 will substantially help to mitigate regulatory liability. This could prove particularly useful when facilities were constructed prior to the initial promulgation of the PSM/RMP regulations, when documentation of RAGAGEP was not required.
[1] ANSI/IIAR 9-2020 §8.3.1 requires a Minimum System Safety Evaluation to be performed for all existing facilities within 5 years of its initial publication in May 2020.
[2] It should be noted that while a facility can rely on IIAR 9 for minimum safety requirements, facilities are still obligated to follow the RAGAGEP in place at the time of construction, unless such RAGAGEP is superseded by IIAR 9. In other words, complying with the minimum requirements stated in IIAR 9 does not necessarily relieve a facility from following other provisions that might have been required at the time of construction. So, for example, a facility constructed using the latest version of IIAR 2 cannot simply revert to IIAR 9, where many of the provisions of IIAR 2 are not addressed. IIAR 9 serves to level the minimum safety requirements and provide a means to evaluate existing systems against these minimum requirements.
The previous blogs are available in the following links:
- Part 1: Introduction
- Part 2: Defining RAGAGEP and Historical Perspectives
- Part 3: The IIAR’s Vision for the Future
- Part 4: Emergency Shutdown Controls
- Part 5: Ammonia Discharge Termination
- Part 6: Ammonia Detection & Ventilation Control
- Part 7: Machinery Room Ventilation
Leave a Reply