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IIAR Comments on Risk Management Programs

The undersigned organizations submit these comments regarding Docket ID No. EPA-HQ- OLEM-2022-0174 Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (Proposed Rule).

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OSHA Considering Revisions to Process Safety Management Regulation

The U.S. Occupational Safety and Health Administration (OSHA) has recently taken steps to advance the rulemaking process to update the Process Safety Management (PSM) regulation. The OSHA effort is taking place in parallel to EPA’s Risk Management Program (RMP) rulemaking, raising concerns about coordination and consistency between the two regulatory schemes. The underlying rulemaking was actually initiated during the Obama Administration.

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Its’ HOT!

Sometimes it may be difficult to understand but we all have free agency to believe what we want. Some people believe the earth is flat. Some believe we never landed on the moon. I suppose there are people who believe those amazing photos from various robotic machines on Mars are fake too.

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Don’t Curse the Purger

The goal of operators, contractors, and design engineers is to operate a closed loop refrigeration system as close to design intent as possible. The owner wants maximum value from the equipment and personnel employed at the facility. The presence of gases that do not liquify within the operating conditions add cost to the running of the system.

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The Covid Cold Chain

Before COVID-19, the cold chain wasn’t on most people’s radar, but shifting consumer demands, concern over food supply and specific healthcare needs during a pandemic put it in the spotlight. “It changed last spring when we started to see disruptions and challenges in the early days of the pandemic related to food,” said Lowell Randel, director of government affairs for IIAR and senior vice president of government and legal affairs for the Global Cold Chain Alliance. “The attention around the cold chain got even more intense with the vaccines coming online.”

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2022 Winter Olympics Embrace Natural Refrigerants, Set the Stage for the Future

For the first time, transcritical CO2 refrigeration will be used to make ice at a Winter Olympics, which will be hosted by Beijing in 2022, with the International Olympic Committee deciding to use CO2 refrigeration system for the most iconic venues for the Beijing Olympics. The decision, which the Beijing 2022 Organizing Committee announced as part of a joint alliance with the United Nations (UN) for the Climate Action framework agreement, led by the IOC, will decrease the overall carbon footprint of the Winter Olympic Games in Beijing.

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The ANSI-Approval Process: A Step-By-Step Guide

Well-developed standards are critical. They can empower and strengthen users with regard to marketplace position and even the global economy. They also ensure the safety of consumers and that the environment is protected.

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IIAR Improves Safety and Operations with Ongoing Research and Standards

As the world's leading advocate for the safe, reliable and efficient use of ammonia and other natural refrigerants, research is a critical component of IIAR’s work. IIAR’s ongoing research projects lead to improved safety and more efficient operations while also shaping industry standards.

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Colmac Coil Manufacturing Announces Leadership Change

Colmac Coil Manufacturing has announced that Joe Fazzari, P.E., has been promoted to the position of President, Colmac Coil Manufacturing, effective January 1st, 2021. Fazzari succeeds immediate former President Bruce Nelson, P.E. who has transitioned to a new role as Director of Innovation of Colmac Coil Manufacturing. Fazzari will have the oversight of all operations and strategic direction of Colmac Coil.

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CARB Moves Forward on Low-GWP Requirements for California Ice Rinks

At the December meeting of the California Air Resources Board, the board voted to approve the proposed regulation on hydrofluorocarbons that established a 150 GWP limit for new ice rinks and other types of large refrigeration systems in locations such as cold storage warehousing.

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Energy Performance Benchmarking: Considering the Efficiency of an Ammonia Refrigeration Installation

The number of countries ratifying the Kigali Amendment to the Montreal Protocol is steadily growing.

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Emergency Series Part 2: Emergency Shutdown and Response

This article has been updated from a previous version to distinguish the differences between a nuisance leak response and a HAZMAT response. Emergency response or responding to emergencies means a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.

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Unknowns

Participating in IIAR conferences, webinars, committees, and sub-committees has certainly increased my knowledge and my access to information. I have listened to and worked with very knowledgeable people from many backgrounds. Even after being involved in the ammonia refrigeration industry, and specifically IIAR for many decades, I am still learning. This reminds me of a famous statement I read in a book by Donald Rumsfeld, who served as George W. Bush’s secretary of defense.

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Biden Administration Takes Early Action on Regulatory Policy and Climate Change

Joe Biden began his presidency on January 20th by signing a series of Executive Orders impacting a wide range of policy issues. In just the first 10 days of his Administration, Biden took 42 individual executive actions, many of which reversed policies instituted by former President Trump. Regulatory review and climate change are among the major actions that will have an impact on the natural refrigerants industry.

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Pressure Relief Design Considerations From a PSM Compliance Standpoint (Part One)

Pressure relief design documentation is often the most misunderstood portion of the Process Safety Information required under 29 CFR 1910.119(d) (3)(i)(D) and 40 CFR Part 68.65(d)(1) (iv). The two regulations state that the relief system design AND design basis shall be included in the process safety information pertaining to the equipment in the process. The word “design” is fairly straightforward. The Cambridge Dictionary defines the word design, when used as a noun, as “a drawing or set of drawings showing how a … product is to be made and how it will work and look” or “the way in which something is planned and made.” Sounds simple, right? We need to have the technical specifications and physical arrangement of the relief design documented. Easily done.

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Pressure Relief Design Considerations From a PSM Compliance Standpoint (Part Two)

In the first article of this series, some of the factors that affect the relief capacity of a relief system that are often overlooked were highlighted to raise awareness of what is needed to properly document the safety relief design. In this article, we will discuss some of the pitfalls associated with internally relieving relief valves. It has long been held that the best way to relieve overpressure in an ammonia refrigeration system is to have the safety relief valves (SRVs) relieve into another part of the system, often simply on the opposite side of the downstream isolation valve. While this can be a viable option, it is often fraught with pitfalls.

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EPA Takes Aim at the Future Proposed rulemaking Jumpstarts HFC phasedown

The U.S. Environmental Protection Agency has been given statutory authority to move forward with phasing down hydrofluorocarbons as part of the American Innovation and Manufacturing Act (AIM), which is expected to increase the long-term use of natural refrigerants. The agency has taken rapid action, and on May 3, it released its first proposed rulemaking under the AIM Act to establish an allocation system for the HFC phasedown.

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IIAR Brings Synchronous Learning Opportunities to Industrial Refrigeration

COVID-19 has changed the way learning takes place across the globe with virtual opportunities and distance learning taking off as social distancing and travel restrictions have kept people out of classrooms. IIAR is among those groups that pivoted to provide valuable learning opportunities to those within the refrigeration industry. In March, IIAR partnered with Don Fenton, a professor of mechanical and nuclear engineering at Kansas State University, to bring the 54th offering of the Industrial Refrigeration Workshop to participants through online synchronous learning, which allowed participants to interact with instructors in real-time.

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Industry Joins Together to Provide Valuable Training to OSHA Inspectors

Occupational Safety and Health Administration compliance officers are continuing to benefit from ammonia refrigeration education presented by the Industrial Refrigeration Consortium. The training, which is funded by IIAR, the Global Cold Chain Alliance, IRC, and OSHA, first launched in the fall of 2014.

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IIAR’s Annual Conference to Feature a Deep Dive on the Ammonia Piping Handbook

During the 2021 Natural Refrigeration Conference and Expo, IIAR will offer a four-hour training on the IIAR Refrigeration Piping Handbook. “It will examine all the parts of the handbook and provide an overview of the content,” said Eileen McKeown, vice president for marketing and sales for IIAR. The educational session, Ammonia Piping Handbook Education Program: Exploring an Essential Tool for Designers, Contractors, and Operators, will take place on Thursday, June 24 at 11:00 a.m. Eastern time.

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IIAR Annual Conference Continues with Virtual Platform

The International Institute of Ammonia Refrigeration 2021 annual Natural Refrigeration Conference & Expo will continue with its virtual format, providing four days of technical knowledge, networking, and industry sponsored events for those involved in the natural refrigeration industry. The event first went virtual in 2020 due to the COVID-19 pandemic.

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Technical Papers and Workshops at a Glance

Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) are written documents intended for use in the design, installation, operation, and maintenance of process equipment. There has been a move in the ammonia refrigeration industry towards standardization, yet there are historical variants which often cause confusion. This session will examine RAGAGEP variants and discuss the importance of adhering to IIAR standards. We’ll also look at tools for keeping RMP/PSM programs on-track and ensuring that a process adheres to RAGAGEP standards. Uriah Donaldson, Resource Compliance

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The Industry at Rest: How SEC Benchmarking will Create New Momentum in the Refrigeration Sector for Mixed-Use Refrigerated Warehousing.

Newton’s first law in part states that an object at rest will remain at rest unless acted upon by an external force. And this is where we are at the moment. Our industry, specifically in the mixed-use refrigerated warehouse sector is at rest. Or differently expressed, at a standstill when it comes to ongoing improvements, new ideas, and implementation of new technology that has the potential to make systems and plants more energy-efficient and creates ongoing savings for our clients.

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OSHA Ramps Up COVID Enforcement By Lowell Randel, IIAR Government Relations Director

Responding to the COVID-19 pandemic continues to be a high priority for the Biden Administration. Despite increases in vaccinations and lower cases in many parts of the country, President Biden is calling on the Occupational Safety and Health Administration (OSHA) to ramp up its enforcement efforts to regulate workplaces. Biden was critical of OSHA during the Trump Administration for not being aggressive enough in protecting workers from COVID-19.

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Scholarships Provide Multiple Learning Opportunities for Recipients

The Ammonia Refrigeration Foundation, which supports research and education programs benefiting the industrial refrigeration industry, is currently accepting applications for IIAR’s Founders Scholarship. The scholarship is awarded annually to collegiate juniors exhibiting exceptional character and interest in pursuing an engineering or related technical degree leading to a career in the refrigeration field.

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IIAR Standards: A Look Back

Bob Czarnecki can’t remember exactly when he started as chairman of IIAR’s Standards Committee, but he thinks it was 10 to 12 years ago. “The former chair had some medical issues, and I was filling in for him. So, I’m blurred as to when I started,” Czarnecki said. “When I first started, the mandate was to develop, maintain and interpret standards. At the time, we had two standards that were ANSI approved. Since then, we have developed eight other standards that have gotten ANSI approval.”

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Reporting Release Rates: How to find the middle ground

Estimating the amount of ammonia lost due to an accidental release can be a complex process and when they do occur, end-users want to avoid underpredicting or over-predicting release quantities. Presently, there is not a single reference guideline that provides details for calculating ammonia quantities released as a consequence of incidents.

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International Fire Code to Defer to IIAR for Ammonia Issues

After years of work, it is more than likely that all code bodies will now refer to IIAR for ammonia refrigeration requirements by 2024. IIAR has made significant progress towards this goal over the past 20 years, but there was one outlier—the International Fire Code. However, the IFC’s technical committee has approved a proposal for the 2024 edition of its model code, deferring all matters related to ammonia refrigeration to IIAR.

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Ammonia System Evacuation — How Low Do You Go?

Removal of non-condensables and excess water is essential when starting up new refrigeration systems or large retrofits. Non-condensables contribute to higher than necessary head pressure, and excessive water in a system can cause inefficiency and operational problems. In all refrigeration systems, non-condensables and water vapor are removed from systems by vacuum pumps prior to charging with refrigerant. Removing liquid water (dehydration), can be done by “pulling” a deep vacuum – enough to boil the standing water and remove the vapor through the vacuum pump.

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IIAR Hosts Successful 50th Annual Meeting

IIAR 2021 Natural Refrigeration Online Conference & Virtual Expo brought technical education, industrial trend insights, and information on products and services to natural refrigeration professionals in June. This was the second time IIAR presented its annual meeting online as COVID-19 continued to create potential disruptions and planning challenges.

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IIAR Petitions EPA for Increased Hydrofluorocarbon Restrictions

The International Institute of Ammonia Refrigeration and its industry partners have petitioned the Environmental Protection Agency to use its authority under the American Innovation and Manufacturing Act to restrict the use of hydrofluorocarbons within the refrigeration sector. The AIM Act is a new climate law passed in December 2020.

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Is the Era of Ammonia Liquid Overfeed Ending?

In four years, it will be the centenary of the liquid overfeed patent issued to YORK Corporation. The liquid overfeed plant came into widespread use around the middle of the last century. This coincided with an upsurge in the consumption of frozen foods that led to the construction of very large freezing plants that warranted the practical introduction of the liquid overfeed concept.

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The Case for Hazard and Operability Methodology

There is a vigorous debate within the industrial refrigeration industry surrounding whether or not the use of hazard and operability methodology, referred to as HAZOP, should be considered the industry standard for hazard reviews and process hazard analyses. While there are advocates for and against employing HAZOP methodology, Stephanie Smith, senior engineer II with Risk Management Professionals Inc., said her research and experience show that the benefits generally outweigh the costs.

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From Dry to Hybrid: A 360 Degree View of Cooling Technologies

Cooling technologies affect price and cooling capacity, and there are a variety of fundamentally different dry cooling technologies available for cooling water/glycol mixtures. The decision for or against one of these technologies during the planning stage of a project has an impact not only directly on the investment sum but also on the subsequent operating costs of the plant across the entire life cycle.

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A Great way to Learn

The following incident had many lessons learned for both the facility and the outside responders. Think about what would happen, or what actions would be taken if this happened at your facility.

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Identifying and Quantifying Fugitive Emissions from Industrial Refrigeration Systems

Industrial ammonia refrigeration systems vary widely in their engineering design, size, scope, and technology features. However, they universally experience some level of refrigerant loss throughout their operational life. Refrigerant losses from industrial ammonia refrigeration systems originate from any number of sources including uncontrolled releases from incidents and accidents, intentional releases during maintenance activities, and fugitive emissions.

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Building the Base: IIAR RELEASES CO2 STANDARD, IIAR-2 UPDATE, NEW GUIDELINES

The International Institute of Ammonia Refrigeration’s history is rooted in standards, and the association has released its latest update to IIAR-2, which was first released in 1974, and its first-ever safety standard for carbon dioxide IIAR CO2.

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IIAR-2 Updates Address Detection, Ventilation and More

The International Institute of Ammonia Refrigeration has released the latest version of IIAR-2, which covers the design of safe closed-circuit ammonia refrigeration systems. IIAR-2 was first released in 1974 and received its last major update in 2015.

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EPA Grants IIAR’s Petition for Increased Hydrofluorocarbon Restrictions

The Environmental Protection Agency has granted a petition from the International Institute of Ammonia Refrigeration and its industry partners to use the agency’s authority under the American Innovation and Manufacturing Act to restrict the use of hydrofluorocarbons within the refrigeration sector.

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CO2 Standard Provides Guidance on Growing Segment of the Industry

The International Institute of Ammonia Refrigeration has released its safety standard for CO2 closed-circuit systems. The standard covers all phases of the CO2 system lifecycle, from design, installation, and start-up to inspection, testing, and maintenance. It encompasses the CO2 portion of a cascade system, systems using CO2 as a secondary fluid, systems operating part- or full-time in the transcritical cycle, and heat pumps.

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IIAR Releases Critical Task Guideline

The International Institute of Ammonia Refrigeration (IIAR) has recently published the first edition of a new guideline titled “Critical Task Guidance for Ammonia Refrigeration System Emergency Planning.”

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As HFCs are Phased-Down, Disincentives for Ammonia Must be Avoided

With the passage and ongoing implementation of the American Innovation and Manufacturing (AIM) Act at the federal level, some states are also taking actions to phase down hydrofluorocarbons (HFCs). As policymakers move away from HFCs, it is also important that ammonia policies be kept in an appropriate balance, to avoid unintended consequences of policies that may serve as disincentives for facilities to move to natural refrigerants.

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Improving PHAs With Sample-Safeguards Checklists

For many ammoniarefrigeration systems, a what-if/checklist processhazard analysis (PHA), with brainstorming about unique situations enhanced by a comprehensive safeguards checklist, provides a robust method for identifying hazards, analyzing risks, and developing any needed recommendations.

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Ready? Really Ready?

Having a well-thoughtout and functional emergency plan can be challenging. I have seen some very good emergency plans, but I have also noticed that several plans are not as complete as they could be. This seems to be a tough lesson to learn, and you may have experienced this. Let me start with an example of a conversation similar to what I have heard many times, and then give some considerations for improving an emergency plan.

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IIAR Participates in Coalition Amicus Brief to the Court Regarding Release Investigations

The Occupational Safety and Health Administration (“OSHA”) is appealing to the U.S. Court of Appeals for the Eleventh Circuit a recent decision by the Occupational Safety and Health Review Commission (“OSHRC”), and an administrative law judge that favored the Tampa Electric Company (“TECO”). The case surrounds actions that TECO performed when responding to a release of ammonia that occurred at a power generating facility.

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Hawaii and Energy Efficiency

Mark Twain once wrote that Hawaii was “The loveliest fleet of islands that lie anchored in any ocean.” I first visited Hawaii just a few years after the world had experienced its second “energy crisis”. In 1979 the Iranian Revolution had disrupted the world’s oil supply and overnight the price of oil doubled to $39.50 per barrel.

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IIAR TECHNICAL PROGRAM UNITES INDUSTRY

One of the most interesting and important programs at the IIAR annual conference in Orlando is the presentation of technical papers. At this year’s conference, industry experts from both the industrial and commercial sides of the business will present technical papers at the IIAR Technical Program.

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India Eyes IIAR Standards, Other International Efforts See Success

While much of the efforts of IIAR’s International Committee in the past few years have been focused on Latin America, the committee recently began activities to develop contacts and influence in India

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IIAR Membership Advances Industry with Committee Work

The past year was a productive one for IIAR’s numerous committees. From in-depth technical research to international outreach, IIAR’s membership has been busy advancing the industry. Here’s a detailed catalog of each committee’s activities, and what they hope to address in the next year and beyond.

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Welcome to the 2020 IIAR Natural Refrigeration Conference & Exhibition!

It is my pleasure to welcome all of you to the 2020 IIAR Natural Refrigeration Conference and EXPO here in Orlando. Your IIAR Staff and Executive Committee have worked very hard to provide you with the largest technical program ever offered at an IIAR conference along< with many opportunities to network with all of your IIAR friends and colleagues.

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IIAR Unveils New Energy and Sustainability Committee

Amid a high level of interest from members, IIAR’s newly established Energy and Sustainability Committee will have its inaugural meeting at this year’s annual conference in Orlando. At last year’s IIAR Annual Conference, after much discussion and deliberation, the IIAR chairman appointed a task force to investigate the needs of the industry’s enduser community with regards to energy and sustainability in their facilities, said Bruce Nelson, speaking on behalf of the committee.

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CSB Establishes New Chemical Incident Reporting Rule

On February 5, 2020, the Chemical Safety and Hazard Investigation Board (CSB) released its Final Rule on accidental chemical release reporting. The rule creates a new reporting requirement for facilities that experience a chemical release. The enabling legislation that established the CSB included a requirement that the agency develop a reporting mechanism to help identify incidents that warrant CSB investigation.

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COPING WITH COVID-19 How the Refrigeration Industry is Safeguarding Employees and Operations

The COVID-19 pandemic has created a global crisis and disrupted communities worldwide. Those in the refrigeration industry have also felt the effects as they work to keep essential operations running, ensure employee and facility safety, and meet the needs of their cusromers.

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Regulatory Impacts of the COVID-19 Pandemic

The current COVID-19 pandemic is having significant impacts on individuals and businesses across the globe. While many businesses continue to be closed, or their operations changed or restricted, companies designated as part of the critical infrastructure have maintained operations throughout the crisis.

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ONSITE TO ONLINE. HOW THE PANDEMIC IS CHANGING TRAINING AND SUPPORT

As the COVID-19 pandemic sweeps across the globe, stay-at-home orders and social distancing have changed the way businesses operate. Every business function has been affected, including training, which is a critical component of the natural refrigerant industry. In response, people in the industry have turned to virtual options, leveraging technology that is already available and investing in additional tools.

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EPA Announces Termination of Enforcement Discretion, Region 1 Reports Results of GDC Pilot Program

On June 29th, EPA announced the termination date of its temporary enforcement discretion policy contained in a March 26th memorandum entitled: “COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program”. The policy was instituted with the recognition that travel restrictions and stay-at-home orders may impact the ability of some facilities to meet certain compliance requirements during the pandemic.

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Growing GREEN. HOW NATURALS ARE GAINING A SHARE OF NEW MARKETS

Hydrofluorocarbons occupy a market space that is very large and diverse ranging from residential through all types of commercial to industrial. While HFCs appear to be a good choice from a perceived safety benefit, they are still pollutants and increasingly regulated chemicals. Regulatory requirements are forcing HFC users to make a switch to lower global warming potential systems, and it is impacting different markets in different ways.

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Policy Implications of a Biden Presidency

While there are still some uncertainties about the final results of the 2020 elections, including key runoff elections for two Senate seats in the state of Georgia, it is important to look at the potential policy implications of a Biden presidency. As with all presidential administrations, there will be some policy changes that can be accomplished simply through executive action.

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OLD GAME, NEW CARDS

Maintenance costs, particularly for labor, are increasing, and the traditional material specified for piping and valve systems – painted carbon steel – is changing as end users search for solutions to minimize maintenance and increase reliability. “The presence of corrosion creates specific issues, particularly with uninsulated valves and controls, that must be managed by those in the refrigeration industry,” said Bob Czarnecki, a member of the International Institute of Ammonia Refrigeration board of directors.

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Supreme Court Declines to Hear HFC Case, EPA Proposes Removing HFC Leak Requirements

On January 18, 2019, President Trump signed legislation to extend the authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program. CFATS, administered by the Department of Homeland Security (DHS), was set to expire on January 19th unless legislation was enacted to continue its authority. Industry and DHS called for reauthorization to prevent a lapse in authority.

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Future-Proofing Refrigerants

Against a shifting regulator landscape, with restrictions of hydrofluorocarbon synthetic refrigerants growing by fits and starts, use of natural refrigerants is increasing among a widening range of companies seeking to ensure that their investments will be viable in the future.

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Green New Deal and Climate Policy

Climate policy is taking center stage with Democrats in Congress who gained control of the House of Representatives after the 2018 elections and the over 20 candidates vying for the Democratic presidential nomination in 2020. The debate, and rhetoric, is heating up and looks to continue as we head into the presidential election next year.

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Future Focus

As refrigerants with highglobal-warming potential are phased out, natural refrigerants are being considered for new applications, and the industry is seeing increased use of secondary refrigeration units that allow users to lower their ammonia charge.

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EPA Continues Compliance Focus on Ammonia Facilities

Compliance and safety in ammonia facilities continues to be a high priority for the Environmental Protection Agency (EPA). In 2016, EPA announced a series of National Enforcement Initiatives focused on improving safety in a variety of high hazard industries. Among these initiatives was an effort entitled “Reducing Accidental Releases at Industrial and Chemical Facilities”. EPA has placed specific emphasis on ammonia facilities as a part of the initiative, which has subsequently been renamed a National Compliance Initiative (NCI).

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IIAR Moves Forward on CO2 Standard

The use of carbon dioxide as a refrigerant has continued to increase, and the IIAR is moving closer to finalizing a new CO2 standard, which will address several critical aspects of CO2 refrigeration, such as installation, startup, inspection, testing and maintenance.

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Regulatory Reforms Advance in Canada and U.S.

Regulations are a major consideration for the industrial refrigeration industry in the United States, Canada and many other countries. IIAR has long worked to improve the regulatory climate in the U.S. and is now working to broaden its influence across the globe. In some cases, this takes the form of promoting IIAR standards in countries that do not have well established regulatory schemes. In other cases, IIAR is working to advance regulatory reforms to reduce regulatory burdens while maintaining safety.

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President’s Message by Dave Rule

It’s that time of year again, and I’m happy to welcome all IIAR members back to our most important event – the IIAR annual conference and exhibition. Before I get into the exciting things we’ve got in store for you as an organization this year, I’d like to take a minute to recognize all our sponsors and exhibitors. It is their support that provides the backbone for this annual event, sponsoring food and coffee breaks, not to mention our exhibit hall – and everything else that makes this one of the premier events in our industry.

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NH3 | CO2 TAKE GOLD

Ice rinks from community recreation facilities to the National Hockey League are moving to natural refrigerants such as ammonia and carbon dioxide as they replace aging facilities and deal with the mandatory phase out of R-22, a hydrochlorofluorocarbon that has been widely used at ice rinks across North America.

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Appeals Court Denies Rehearing of Ruling Against EPA Regulation of HFCs

On January 26, 2017, the United States Court of Appeals for the District of Columbia Circuit denied petitions requesting a rehearing by the full court of a decision finding that the Environmental Protection Agency (EPA) had exceeded its authority by regulating the use of HFCs through the Significant New Alternatives Policy program (SNAP).

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President’s Message by Dave Rule

This month you’ll be hearing from IIAR about one of our most important annual activities, our membership renewal drive. As an IIAR member, we all depend on you to take that essential first step to participate in the activism and advocacy of our industry, by

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UNLOCKING AMMONIA

Ammonia refrigeration systems are becoming more compact, portable and simpler to install, widening the potential for adoption of ammonia, carbon dioxide and other natural refrigerants in previously untapped industries.

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President’s Message by Dave Rule

Business as usual is a term that has never applied well to industrial refrigeration. Our economic sector is constantly changing to meet the demands of a rapidly evolving supply chain, as we examine in this month’s cover story. Regulatory change, new technology and equipment development has propelled us into ever broader markets and applications for natural refrigerants.

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FRESH &Fast: HOW NEW CONSUMER EXPECTATIONS HAVE STOKED RECORD COLD STORAGE DEMAND

Occupancy rates at cold-storage facilities are at an all-time high, said Corey Rosenbusch, president of the Global Cold Chain Alliance. “There is denitely growing demand,” he said. “The industry feels like we’re in a good position right now with supply and demand, but there is pressure for more space.

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Appeals Court Vacates Trump Rule Delaying RMP Changes

A federal appeals court in August vacated a delay in Obama-era changes to the Environmental Protection Agency’s Risk Management Program (RMP) that would add compliance requirements to regulated facilities. Shortly after taking office, the Trump Administration issued a series of delays to the effective date of the RMP amendments, resulting in a final effective date of February 19, 2019.

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President’s Message by Dave Rule

This issue of the Condenser is all about operations. As you can see from our cover, one of the most important factors in that equation is geographical location. The regional and local operating environments define the business and regulatory landscape across the country. And that definition, in turn, determines how we uphold our high standards for safety and efficiency. The role that the regulatory framework plays in our industry, and even more importantly, how we respond to and inform it, is a central focus for IIAR.

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THE LOCATION LANDSCAPE

The cost of real estate, an available workforce and proximity to transportation dictate where businesses build industrial refrigeration facilities, and those factors are more important than ever in recent years. As rising demand spurs cold chain growth, clear winner (and loser) locations are emerging from the patchwork of regional U.S. regulatory and business environments. Increasingly, those environments are taking center stage in decisions to build a facility or what refrigerant to use.

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President’s Message by Dave Rule

Now that we’ve all returned from San Antonio, it’s a new member year, and your staff is digging in to accomplish many of the new goals set out for 2017. First among them is planning the next successful conference. We’re looking forward to returning to the Broadmoor in Colorado Springs, and I hope to see you all there. Now is the time to take advantage of IIAR’s early membership renewal opportunities and get involved in the work of your committees.

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The Green Transformation

Refrigeration manufacturers said they would make production plans and future product development decisions according to the expected worldwide HFC refrigerant phase down put forth by the Kigali Amendment. The amendment, last year’s Montreal Protocol add-on, will specify phase-out deadlines for HFC’s, adding those refrigerants with high global warming potential to the group of ozone depleting hydrochlorofluorocarbons that are already being outlawed under the international agreement.

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President’s Message by Dave Rule

It’s the beginning of the summer and that means it’s time for one of IIAR’s most important activities – leading membership renewals. And while this may seem like a routine activity we all work hard to complete every year, I’d like to take the opportunity in my column this month to point out that, as an IIAR member, this is one of the most important contributions you can make to the success of our industry.

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The Internet of REFRIGERATION

The Internet of Things — an increasingly massive network of electronically connected systems, devices and people that enables cross-platform data sharing — is creating a large, connected ecosystem across many industries, including refrigeration.

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President’s Message by Dave Rule

In this issue of the Condenser, we’re looking at the exit strategies that end users and manufacturers alike are using – to move away from hydrofluorocarbons and hydrochlorofluorocarbons. As former IIAR chairman Bob Port mentions in our cover story “There is a lot of internal pressure to get out of [HFC’s and HCFC’s] from a sustainability standpoint, but it has to come at a reasonable cost and be a good business decision.”

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Making the Investment

As they move away from refrigerants with high global warming potential, commercial and industrial refrigeration users said they’re investing in new, natural refrigerant technology, including packaged ammonia systems and CO2 transcritical systems. The move to newer technologies is allowing them to ease some regulatory burdens, increase efficiency and improve safety.

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Closing the Flammability Gap

The safety of synthetic refrigerants versus anhydrous ammonia continues to provide a major point of debate within the refrigeration industry. Since ratification of the Montreal Protocol two decades ago, there has been a trend toward eliminating non-flammable synthetic refrigerants that have ozone depleting potential or global warming potential. At the same time, questions concerning the flammability and toxicity of replacement refrigerants have remained at the forefront.

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Court Rules Against EPA Regulating HFCs through SNAP Program

On August 8, 2017, the United States Court of Appeals for the District of Columbia Circuit issued a ruling in the case of Mexichem Fluor Inc. vs. the EPA finding that the Environmental Protection Agency (EPA) exceeded its statutory authority by promulgating a rule in 2015 that regulated the use of hydrofluorocarbons (HFCs). The 2015 regulation was issued by EPA through its Significant New Alternatives Program (SNAP) as a part of the Obama Administration’s plan to reduce greenhouse gas emissions

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President’s Message by Dave Rule

This issue of the Condenser is all about education and training. As you can see from our cover, IIAR is unveiling a new apprenticeship program which will help our industry safeguard the generations of institutional knowledge we rely on for the development of our future technicians, engineers and managers.

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IIAR Launches Apprenticeship Program

Apprenticeship programs help businesses develop highlyskilled employees, reduce turnover, increase productivity and cut the cost of recruitment. They can also help employers attract new employees.

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Tax Reform Takes Center Stage

Tax reform has emerged as the top priority in Washington, DC as President Trump and Congressional Republicans set the goal for passing legislation before the end of 2017. Republican leaders are feeling pressure to secure a signature legislative victory following the failure to repeal and replace Obamacare.

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President’s Message by Dave Rule

This issue of the Condenser is all about change. Whether it’s the regulations phasing out HFC’s and the new decisions faced by many in the commercial and industrial world, or the innovations and new technology that are enabling those decisions – one thing is certain, we are moving rapidly into a new era of refrigeration.

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GREEN Dialing

A growing number of supermarkets are moving to replace hydrofluorocarbons with climate-friendly alternatives, such as propane, ammonia and carbon dioxide, ahead of the planned phase out of R-22 in the United States, but grocers are moving forward cautiously.

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Policy Changes Pave Way for HFC Reductions

The use of hydrofluorocarbons (HFCs) has recently been at the center of policy deliberations in the United States and globally. Many HFCs used in refrigeration have high global warming potential (GWP) and have become the target for reductions by the U.S. Environmental Protection Agency and the over 170 countries that are parties to the Montreal Protocol.

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President’s Message by Dave Rule

In this issue, we’re presenting news on one exciting new activity in our industry and our organization – to build and deliver IIAR’s first education program. IIAR is working harder than ever to deliver on its promise to membership: to broaden the reach of our member base by addressing major issues that are occurring in our industry to promote the ongoing growth and health of industrial refrigeration.

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INTRODUCING: ACADEMY OF NATURAL REFRIGERANTS

The IIAR Academy of Natural Refrigerants certificate program will allow design engineers, installers and responsible parties to show that they have received documented and standardized training. The program will begin with a training course on IIAR-2, the latest IIAR standard to be updated, and will expand to cover additional IIAR standards and other technical courses of study that are necessary for engineers working in the refrigeration industry.

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OSHA Convenes Small Business Panel on Potential Changes to PSM

In June 2016, the Occupational Safety and Health Administration (OSHA) convened a Small Business Advocacy Review (SBAR) Panel to get feedback from small businesses about potential changes to the Process Safety Management (PSM) regulation.

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President’s Message by Dave Rule

There’s a lot going on at IIAR headquarters these days. We’re growing and expanding with new initiatives, programs and goals for the new membership year. That growth just reflects the expansion of our industry in general.

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From Regulation to Operation. WHAT YOU NEED TO KNOW

Owners and operators of ammonia refrigeration equipment have a number of regulatorydriven documentation requirements, and the level of understanding regarding those requirements can vary from company to company.

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EPA Issues Proposed Rule on RMP

On March 14, 2016, the Environmental Protection Agency (EPA) published in the Federal Register a proposed rule to modernize the Risk Management Program. The rulemaking comes as a part of the Obama Administration’s efforts to implement Executive Order 13650 – Improving Chemical Facility Safety and Security. The Executive Order was issued in response to an incident at a fertilizer plant in West, Texas in April 2013.

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President’s Message by Dave Rule

The 2015 – 2016 membership year has been an exciting time for our industry. As regulations and technologies evolve at a rapid pace, we’re seeing new opportunities and applications for refrigeration grow like never before.

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RESIZING REFRIGERANTS

As hedrofluorocarbons and hydrochlorofluorocarbons are being increasingly phased out to meet government and regulatory requirements, natural refrigerants are candidates to fill the void, getting a closer look from many types of businesses installing smaller refrigeration systems, such as supermarkets and convenience stores.

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OSHA Initiates Small Business Review Panel on PSM Regulation

In February 2016, the Occupational Safety and Health Administration (OSHA) announced that it is initiating a Small Business Advocacy Review (SBAR) Panel in order to get feedback on several potential revisions to OSHA’s Process Safety Management Program (PSM) standard.

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President’s Message by Dave Rule

As you’ve likely noticed, this issue of the Condenser is all about the re-release of IIAR-2, the first comprehensive code standard for the safe, reliable and efficient design of ammonia refrigeration systems. We’re dedicating so much space to IIAR-2 because it is perhaps one of the most important, long reaching projects our association has completed in recent years.