Regulation & Compliance

EPA Launches Region 10 Initiative for Facilities Under 10,000 lbs of Ammonia

The Environmental Protection Agency has launched an initiative in the Pacific Northwest to improve the safety of smaller ammonia refrigeration facilities – focused on facilities with under 10,000 pounds of ammonia. The initiative, which is being carried out by EPA Region 10, was developed with input from EPA region 1 and the International Institute of All-Natural Refrigeration. It is aimed at improving compliance with the General Duty Clause of Section 112(r) of the Clean Air Act. Section 112(r) specifies that owners and operators of stationary sources producing, processing, handling, or storing extremely hazardous substances, including anhydrous ammonia, have the duty to reduce the risk of chemical accidents.

Regulation & Compliance

Compliance Assurance and Enforcement Focus

The following fact sheet was published by the Environmental Protection Agency Region 10 to communicate details about the Region 10 compliance initiative for facilities under 10,000 pounds of ammonia. It is reproduced here for the benefit of IIAR members and non-members with facilities under 10,000 pounds of ammonia.

Regulation & Compliance

IIAR Enforcement Awareness: General Duty Clause Requirements: Facilities with Smaller Ammonia Refrigeration Systems

Most IIAR members will likely have a hazard analysis in place. However, if your facility does not, we encourage you to get this done soon. If you are a contractor, a consultant, or sell equipment or other goods, we encourage you to pass the word to your end-user clients, especially those with smaller facilities that might not have a hazard analysis in place.

Regulation & Compliance

President’s Message by Gary Schrift

The months after IIAR’s annual conference are always think about the next membership year ahead. While there’s always a lot going on in these last few days of summer, it’s nice to pause for a moment and reflect on what it means to be an IIAR member and what new plans we have for the future.

Regulation & Compliance

Assessing and Mitigating Risk

Managing risk is an important part of any business, but especially for those that work with refrigerants, which can create a safety hazard if they aren’t handled properly. However, the best ways to manage and estimate risk aren’t always clear cut.

Regulation & Compliance

OSHA Announces New Emphasis Program Targeting Warehouses and Distribution Centers

On July 13th, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced a new national emphasis program (NEP) targeting workplace hazards in warehouses, processing facilities distribution centers, and high-risk retail establishments.

Regulation & Compliance

IIAR Task Force Keeps Members Up to Date on the AIM Act

The American Innovation and Manufacturing Act (AIM) Act is expected to increase the long-term use of natural refrigerants and bring significant new opportunities to the natural refrigerant industry. To ensure those in the industry are aware of the changes and opportunities the AIM Act will bring, IIAR has formed the AIM Act Task Force, which is being led by Miguel Garrido, executive president, Günter U.S.

Regulation & Compliance

Regulatory Outlook for 2022 by Lowell Randel, IIAR Government Relations Director

As the Biden Administration enters its second year, agencies such as the Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) are preparing to take significant regulatory actions that will impact the industrial refrigeration industry.

Regulation & Compliance

President’s Message by Gary Schrift

Our first in-person Annual Conference since the pandemic began was a great success, and now that the flurry of committee meetings, networking events, and technical discussions have ended and we’re all back at work, it’s time to set some new goals and carry the momentum of our recent meeting into the rest of the year.

Regulation & Compliance

IIAR Forms AIM Act Task Force

The American Innovation and Manufacturing (AIM) Act regulations promulgated by the Environmental Protection Agency will restrict refrigerants’ allowable global warming potential throughout the United States and it is expected to increase the long-term use of natural refrigerants. IIAR has formed the AIM Task Force to help learn more about the AIM Act’s requirements and how the association and its members can support the act.

Regulation & Compliance

IIAR Announces Regulatory Initiatives

IIAR dedicated time to updating members on the latest regulatory initiatives during its annual conference. Lowell Randel, director of government affairs for IIAR, discussed several areas of focus for the association and the natural refrigerant industry.

Regulation & Compliance

EPA Continues Work to Implement AIM Act

The Environmental Protection Agency is continuing its work to implement the American Innovation and Manufacturing (AIM) Act of 2020.

Regulation & Compliance

IIAR Releases Second Edition of Guidelines on Manual Hand Valves

The IIAR Compliance Committee has updated the Guideline for Developing an Energy Control Plan for Manual Hand Valves and released a second edition. “After a guideline has been out and used in the industry, members and users will ask questions and provide input for consideration to make the guideline even clearer to use or capture additional information that enhances its value as a practice,” said Tony Lundell, senior director of standards and safety for IIAR. “An addendum typically will have minimal changes which could include simple edits, and/or provide statements that can add value to the guideline.”

Regulation & Compliance

Natural Refrigerants Continue to Grow in Retail

Adoption of natural technologies in new and existing retail space is increasing as companies work to increase sustainability while meeting consumer, employer and shareholder expectations. “Many retailers, especially national chains, are prepared to make very large investments to significantly reduce their carbon footprint by converting to naturals in existing stores,” said Danielle Wright, executive director of the North American Sustainable Refrigeration Council.

Regulation & Compliance

Circuit Court Supports Tampa Electric’s Response to a Release

The Eleventh Circuit has rejected an appeal from the Occupational Safety and Health Administration in the case against Tampa Electric Co. and its response to an ammonia release at a power generating facility in 2017. The court of appeals upheld the finding that the release was controlled and the clauses pertaining to emergency response were not applicable.

Regulation & Compliance

Climate Change Policy in the Spotlight By Lowell Randel, IIAR Government Relations Director

President Biden has made addressing climate change a signature priority for his administration. Since his election, climate change policies have been at the forefront of agency actions, Congressional deliberations, and, most recently, before the Supreme Court.

Regulation & Compliance

EPA’s Proposed Amendments to RMP Burdensome on Industry

The Environmental Protection Agency has proposed amendments to its Risk Management Program regulations, which include several changes to the accident prevention program requirements, enhancements to the emergency preparedness requirements, and increased public availability of chemical hazard information.

Regulation & Compliance

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).

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.

Regulation & Compliance

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.