Ammonia refrigeration compliance audits — find the gaps before OSHA does
A third-party compliance audit of your ammonia refrigeration facility: all 14 OSHA PSM elements under 29 CFR 1910.119, EPA RMP under 40 CFR Part 68, and RAGAGEP conformance against the IIAR standards — performed the way OSHA performs it, on your schedule instead of theirs.
The audit is not optional — only the timing is
OSHA 29 CFR 1910.119(o) requires every covered facility to audit its PSM program at least every three years. Skip it and the missing audit is itself a citation — before the inspector looks at anything else.
But the real value of a compliance audit isn't the checkbox. OSHA PSM inspections at ammonia refrigeration facilities routinely produce six-figure penalty proposals, and most citations trace back to gaps a facility could have found and fixed on its own terms: outdated process safety information, incomplete mechanical integrity records, relief systems that don't match current IIAR requirements, MOCs that never closed.
We audit your facility the way OSHA does — element by element, documentation and field — so that when the inspection comes, there's nothing left to find.
Ammonia refrigeration is an OSHA emphasis area
OSHA has run National Emphasis Programs targeting chemical facilities and PSM-covered processes, and ammonia refrigeration facilities are frequent inspection targets. An inspection can begin from an employee complaint, a reportable release, or a programmed emphasis inspection — none of which happen on your schedule.
What triggers coverage
Not sure which side of the threshold you're on? Start with an inventory determination.
One audit, four lenses
14-element OSHA PSM audit
Every element of 29 CFR 1910.119 — from process safety information and operating procedures through mechanical integrity, MOC, and incident investigation — reviewed against the regulation and against how your facility actually operates.
EPA RMP compliance review
Your Risk Management Program reviewed against 40 CFR Part 68: registration accuracy, program level determination, hazard assessment, offsite consequence analysis assumptions, and five-year resubmission status.
RAGAGEP conformance audit
Field and documentation review against the IIAR standards OSHA treats as RAGAGEP for ammonia refrigeration — ANSI/IIAR 2 (design), IIAR 4 (installation), IIAR 6 (inspection, testing & maintenance), and IIAR 9 (existing systems).
Field verification
We walk the engine room and the system. Labeling, ventilation, detection, relief piping, emergency controls, and physical condition — verified against your process safety information, not just assumed from it.
What a RAGAGEP audit actually checks
OSHA PSM requires that covered equipment complies with Recognized and Generally Accepted Good Engineering Practice — RAGAGEP. The standard doesn't define the practices itself; it points to the industry documents that do. For ammonia refrigeration, those documents are the IIAR standards.
That means an OSHA inspector evaluating your engine room isn't comparing it to a generic checklist — they're comparing it to ANSI/IIAR 2, IIAR 6, and IIAR 9. If your relief system, ventilation, detection, or inspection program doesn't conform, and you can't document why, that's a finding.
Our RAGAGEP audit reviews your system against each applicable IIAR standard and documents either conformance or a specific, cited gap — the same evidence trail an inspector would build, assembled in your favor instead.
IIAR standards used as RAGAGEP
Design of safe closed-circuit ammonia refrigeration systems
Installation of closed-circuit ammonia refrigeration systems
Startup and commissioning
Inspection, testing, and maintenance (replaced Bulletin 110)
Operating procedures
Decommissioning
Minimum system safety requirements for existing systems
See our article on IIAR 6 inspection requirements for how ITM expectations have evolved.
A report you can act on — and show an inspector
Utah, California, and nationwide
NH3Edge is headquartered in Salt Lake City, Utah. We perform on-site ammonia refrigeration compliance audits throughout Utah and California — cold storage, food and beverage processing, and industrial refrigeration facilities — and travel to covered facilities anywhere in the United States. Document-phase work is performed remotely to keep on-site time and cost down.
Compliance audit questions
How often does OSHA require a PSM compliance audit?
OSHA 29 CFR 1910.119(o) requires covered facilities to certify that they have evaluated compliance with the PSM standard at least every three years. The audit must be performed by at least one person knowledgeable in the process, findings must be documented, and the facility must document responses to each finding.
What is a RAGAGEP audit?
RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practice. OSHA requires covered equipment to comply with RAGAGEP, and for ammonia refrigeration the recognized RAGAGEP documents are the IIAR standards — including ANSI/IIAR 2 for design, IIAR 6 for inspection, testing, and maintenance, and IIAR 9 for existing systems. A RAGAGEP audit compares your equipment, documentation, and maintenance practices against these standards, the same way an OSHA inspector would.
Does a compliance audit apply if my facility is below 10,000 lb of ammonia?
The full PSM standard applies at 10,000 lb and above, but facilities below the threshold are still subject to the OSHA General Duty Clause and EPA's General Duty Clause under CAA 112(r)(1) — both of which reference the same IIAR standards. Many sub-threshold facilities audit against IIAR 9 and IIAR 6 for exactly this reason. If you are unsure of your inventory, start with an ammonia inventory determination.
Where do you perform audits?
NH3Edge is based in Salt Lake City, Utah. We perform on-site compliance audits throughout Utah and California and travel to ammonia refrigeration facilities nationwide.
Audit on your schedule, not OSHA's
Tell us about your facility and we'll scope a compliance audit — full 14-element, RAGAGEP-focused, or targeted to the elements you're worried about.