IIAR

By Jeffrey M. Shapiro, PE., FSFPE

Recently, the IIAR Code Committee was asked to weigh in on the use of checklists for inspection of ammonia refrigeration systems. IIAR members had reported seeing local inspectors in some jurisdictions making use of checklists to guide code enforcement inspections, and concerns were raised about whether checklists are truly appropriate for this purpose. In addition, the Code Committee was asked to consider whether IIAR should develop our own checklists rather than leaving it to other individuals or organizations, who may be less knowledgeable, to prepare them. The following is a synopsis of the Code Committee’s discussion and some of my own thoughts on the subject.

Checklists are a powerful tool that help to ensure that important concerns are not overlooked in systems, processes and procedures. They are routinely used in quality control applications ranging from product manufacturing to hospital surgical procedures, and they’re common in safety applications ranging from electrical lockout /tag out programs to confined space entry procedures. Been on an airplane? Your safety during the flight was heavily reliant on pilots’ use of checklists to ensure that systems have been properly verified, and in the event of a mishap, a checklist would have guided emergency procedures. Planning on how to handle an ammonia emergency? The Ammonia Safety Training Institute (ASTI) makes extensive use of checklists as a basis for outlining response procedures for facility operators and emergency responders when an unplanned ammonia release occurs.

It may surprise you to know that checklists are also commonly used in code enforcement applications, from plan review to field inspection. In fact, the International Code Council, which publishes the International codes, also publishes checklists to guide inspectors in code enforcement activity; albeit, these documents tend to focus on general safety concerns as opposed to evaluating detailed code compliance of complex systems. For the International Fire Code (IFC), ICC’s inspection checklist is even published in a convenient “carry in your pocket” format so that it’s easy for field inspectors to use.

So, what about checklists for inspection of ammonia refrigeration systems? IIAR is aware of at least two code enforcement checklists that have been developed for evaluating compliance of ammonia refrigeration systems. One is being used in California and the other in Washington.

Although these documents may be well intended, the Code Committee’s review of their content identified many concerns based on how they were written, the most significant of which is the apparently intended use of a single checklist for inspecting both new and existing systems. The problem with that approach is its failure to accommodate the ever-changing nature of codes and standards.

Specifically, regulations in the current editions of the IFC, International Mechanical Code (IMC), ASHRAE 15 and IIAR-2 governing design and installation are generally intended to apply only to new installations. The only time that a current design or installation provision in one of these documents is applicable to an existing installation is when the provision previously existed in the edition of the code or standard that the equipment was installed to, with the exception of the IFC, which also has a special allowance for remediation of hazards that are determined to be a distinct hazard to life or property.

The code committee also identified:

• Checklist provisions in which guidance from an IIAR bulletin was being improperly applied as an enforceable requirement.
• Checklist provisions that went so far as to modify the cited recommendation or requirement without identifying that the material had been modified.
• Checklist provisions that were only partially extracted from the source code or standard, leaving behind important exceptions and limitations that affect how the section should be applied.
• Checklist summaries of requirements that simply misrepresented what is in the source code or standard.

It should be recognized that none of these issues is a fundamental defect with the concept of checklists themselves. Instead, they simply reflect checklists that were not properly executed for the intended purpose.

When it comes to the legalities of code enforcement, accuracy in application and interpretation of regulations is critical, both in ensuring that facilities meet the applicable safety requirements and in ensuring that owners and operators are not mandated to do more than meet the codes and standards that have been legally adopted by a jurisdiction. That’s an entirely different situation than using a checklist for a non-regulatory purpose, such as a safety or operational good practice procedure.

It’s a simple fact that developing appropriate checklists for regulatory compliance of ammonia refrigeration systems would be a tremendously complex task that would require accurately and comprehensively extracting applicable provisions from many source documents and would require different checklists for each adopted code edition. Then, the inspector would determine which code edition a particular system was installed to and select the proper checklist. Certainly, this isn’t an impossible task, but one would have to question the ultimate value of and investment in the exercise versus simply applying the codes and standards themselves.

The Code Committee ultimately decided that there is not a pressing need to develop an IIAR version of a checklist for ammonia refrigeration systems and that we, as an industry, should discourage the use of improperly conceived checklists for regulatory purposes.

In summary, checklists can be valuable assets as tools to guide an owner or operator in inspecting system installations, but as a weapon used by a code enforcer as a basis of citing a facility, there is a significant danger of improper application of the code.

If you find yourself dealing with a jurisdiction that uses a checklist for determining compliance of an ammonia system and you get cited based on the checklist, be sure to ask the inspector to provide the text of the specific code section that’s supposedly being violated and be sure to have them review the text of the actual regulation with you when the citation is issued. Since it’s unlikely that they’ll have the source document with them during the inspection (hence, one perceived benefit of the checklist…not needing to carry source documents), it’s a good idea to have on hand at your facility copies of editions of IIAR-2, ASHRAE 15, the IMC (or UMC) and the IFC (or UFC), as applicable in your jurisdiction, that were adopted when your system was installed.