IIAR

The purpose of the committee is to provide IIAR members with a strong understanding of how federal regulations affect the ammonia refrigeration industry. Don Stroud, who leads the government relations committee, said the group’s primary focus is to follow regulations and proposed rulemakings from the Environmental Protection Agency, EPA, and the Occupational Safety and Health Administration, OSHA.

Much of the committee’s recent focus has been on OSHA inspections of refrigeration systems, Stroud said, specifically OSHA’s use of inspection guidelines that originally evolved for the petrochemical industry. “We are starting to see problems with how these inspections are being conducted when it comes to OSHA trying to apply petrochemical standards to refrigeration,” he added.

The committee has been fielding quite a few questions from members on that subject. “We’re trying to educate compliance officers about good working practices to help them deal with the inspections,” Stroud said.

He noted that IIAR has been working closely with OSHA and the Global Cold Chain Alliance to resolve any issues with inspection processes.

The government relations committee has also been helping IIAR members understand the presidential executive order regarding chemical plant safety, which was issued in response to the April chemical plant explosion in West, Texas. The executive order seeks to improve coordination among federal, state and local officials with first responders.

“We’re monitoring closely the effects of that executive order,” Stroud said.

Meanwhile, the government relations committee followed developments related to OSHA regulations involving hydrostatic relief, he added. OSHA’s position on that subject was highlighted in a letter known as the Palmer Letter, which stated that hydrostatic relief is required when equipment containing a liquid refrigerant can be isolated.

The government relations committee recently worked with the IIAR staff to clarify the Palmer letter, which resulted in OSHA revising their position, an action that was reported in the IIAR member alerts newsletter earlier this year. The government relations committee also helps members understand the inspection process required under the National Environmental Policy Act, Stroud said. In many cases, IIAR members are paying NEPA-related fines when the citations that led to the fines were given in error.

“There are many instances where companies accept a NEPA-related fine because they do not have the resources to challenge the agency’s decision,” Stroud said. “We’re working to provide some direction on that issue.”