But even this document recognizes that PHA teams must have to freedom to either customize these guidelines or develop alternative scenarios and damage mechanisms to fit their unique operations.
(page 47) We agree that adding a definition for RAGAGEP could be useful to help owners better understand requirements under the standard.
A definition for RAGAGEP may also be helpful in reducing the instances of EPA inspectors citing standards that are not as applicable to a given type of facility.
Specifying the types of failure scenarios and damage mechanisms for PHAs and hazard reviews could be problematic.
The implication of such a policy is that EPA would be essentially stating that they know more about the processes and potential failure mechanisms than the experts within each industry.
The current Contractor section clearly lays out the requirements for Owners/Operators and Contractors and these requirements have been working in our industry.
Since the roles of contractors have not changed in our industry and since the overwhelming number of incidents does not involve contractors we do not believe additional safety requirements are necessary.
In addition, the International Institute of Ammonia Refrigeration (IIAR) is an ANSI accredited standards writing body whose standards are used as Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).
The questions posed in the RFI are of great interest to our organizations and member companies and we appreciate the opportunity to provide comment.
Safety Management / Risk Management Programs through defining of: Operating Limits (§68.69(a)(2)); assignment of responsibility (§68.69(a)(1)); equipment deficiencies (§68.73(e)); Pre-startup review (§68.77); Job Safety Analysis(29CFR 1910.132(d)(2). Additional requirements above what is currently stated and included in existing regulations and through industry standards would not ultimately improve the Facilities should be free to choose those management system elements which are applicable to the complexity of their operations and to their industry; they should not be constrained to use management-system elements which were developed under circumstances which may not apply to their operations.
Ammonia refrigeration industry contractors are essentially used in the same roles today as when the RMP regulation was first enacted.
Lowering the ammonia threshold quantity (10,000 lbs.) under the Risk Management program would require smaller independent companies to needlessly increase their operating costs and could inflict financial harm.