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January 2021 Newsletter

IIAR-6 changes could spell issues for facilities using anhydrous ammonia

Are you aware of IIAR-6?

IIAR-6 establishes the minimum requirements for inspection, testing, and maintenance (ITM) applicable to safe closed-circuit ammonia refrigeration systems.

It is meant to aid in identifying what components should be inspected, tested, and maintained and how frequently these tasks should be performed.

Components of IIAR-6 include: Management Responsibilities, Record Keeping, Inspection, Testing, and maintenance.

IIAR 6 states “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.”

In practical terms, this means management must ensure that the ITMs are being completed according to the IIAR 6 standard, which includes providing the necessary training, equipment, and any other resources required to perform the ITMs.


29 CFR 1904

The time is now to begin completing the OSHA recordkeeping that is required to be posted, and later e-filed with OSHA in the coming months.

  • The OSHA Form 300 is the Log of Work-Related Injuries and Illnesses that is maintained on an annual basis. The log must be updated with 7 days of a “recordable” employee injury.  Annual OSHA logs must be kept on file at the facility for five years.
  • The OSHA Form 300A is the Summary of Work-Related Injuries and Illnesses. This document needs to be posted at the facility (in a place where employees can easily see it) annually from February 1st until April 30th.

 The OSHA Form 301 is the Injury and Illness Incident Report, and can be substituted with company incident reports, medical provider notes, and related injury claim information.

Reporting Deadlines

EPA Tier 2 – March 1, 2021

OSHA 300a – March 2, 2021

“An incident is just the tip of the iceberg, a sign of a much larger problem below the surface.”

Don Brown – Owner, Director of Software Products and Services for BasicSafe.

Need Help?

HCG Associates will ensure your company’s OSHA recordkeeping is prepared correctly, contains all required information, and only includes incidents that are considered work-related. Every year, companies are targeted and penalized because their OSHA incident rate (OIR) exceeds the industry average of their peers. Many times, this is due to improper recordkeeping. Let us help!

Contact us for peace of mind in completing your OSHA logs.

Did You Know?

  • The deadline for e-filing your OSHA logs through the online reporting tool is March 2, 2021.
  • Temporary Workers need to be included on a company’s OSHA log if the company assumes supervision over those temps in lieu of on-site supervisors from the temp agency; their total hours are also included in the tally on the 300A form.
  • If salaried employees work on-site more than 40 hours/week, you may calculate and include those hours on the 300A form.


While there are no specific COVID-19 regulations or standards issued by OSHA, the agency is taking the position that COVID-19 hazards fall under OSHA’s General Duty Clause, as well as triggering other program requirements, such as:

  • Recordkeeping
  • PPE
  • Employee Training
  • Respiratory protection
  • Bloodborne Pathogens
  • Access to employee exposure and medical records


How ready are you for the next wave of COVID-19? You will not know without an audit. HCG Associates perform on-site evaluations to monitor the effectiveness of COVID-19 workplace controls. Let us help you maintain your business operations and keep your employees safe.

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