Regulation & Compliance

EPA Newsletter Issues RMP Deadlines Reminder

According to a reminder notification released by the Environmental Protection Agency in an EPA newsletter, P2/P3 RMP facilities need to conduct a notification drill by the end of this year. “Responding P2/P3 facilities need to conduct your first tabletop exercise by the end of 2026. In conducting these tasks, you should be working with your local emergency planning committees (LEPCs)-do you know who your LEPC is? Has your facility been working and meeting with your LEPC? This is the perfect time to start and be a partner with emergency management in your community,” the EPA said in the reminder.

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

Calibration Technologies Attends IIAR Guadalajara Conference

Calibration Technologies said it attended this year’s IIAR CAPÍTULO MÉXICO Refrigeración Industrial Conference in Guadalajara Mexico. Representing the company at the IIAR event were CTI employees Mike Cusanno and Miguel Lopez. The company said in a statement that ”CTI is excited to participate in IIAR’s international events. As nations around the globe are working towards lower emissions by adopting natural refrigerants, IIAR is providing the much-needed safety standards and CTI is providing gas detectors for NH3, CO2, and hydrocarbons.”

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.

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.