IIARThe Official Magazine of the All-Natural Refrigeration Industry
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.
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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.
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Have you ever thought about your understanding of the equipment and tools we use as well as the entire refrigeration system(s)? Many times, or maybe all of the time we assume we or someone else understands until something happens. This may be like the definition of confidence I have heard, which is “That feeling you get just before you understand the situation.”
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On April 7, 2023, the Occupational Safety and Health Administration (OSHA) submitted its latest injury and illness recordkeeping proposal to the Office of Information and Regulatory Affairs (OIRA). Submission to OIRA usually marks the last step in the rulemaking process before a Final Rule is published. Injury and illness recordkeeping has been the subject of regulatory attention by the last three administrations.
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I am sure that many of us have seen ammonia refrigeration systems that have operated for several decades, with equipment and system components functioning well past recommended operating life. This is a credit to manufacturers, installers, service technicians, and operators. Aging equipment and piping at some point will eventually require replacement. Or the system or portion of it may be decommissioned due to a business discussion. Due to various conditions, it may become necessary to decommission a system or portions of it, which is defined in ANSI/ IIAR 8- 2020 – Decommissioning of Closed-Circuit Ammonia Refrigeration Systems as: “The permanent deactivation of a closed-circuit refrigeration system.”
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The United States EPA National Enforcement and Compliance Assurance Program implemented several national compliance initiatives (NCIs) effective for FY2020-2023. One of these NCIs is titled “Reducing Risks of Accidental Releases at Industrial and Chemical Facilities”. IIAR has received notice from the EPA and several end-users that one area of their focus is to determine whether facilities using hazardous chemicals have conducted a hazard analysis.
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As a global organization with members across the world, IIAR gives members the opportunity to learn from those with different experiences and points of view as well as improve the overall safety of the industrial refrigeration industry.
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Being aware and paying attention to what’s around you, where you are, and what’s happening can be really important. Sometimes for whatever reason, we miss something that we may be looking right at, hearing, smelling, etc. I’m sure that we all have some lack of awareness and/or have not been paying attention at various times. Lack of awareness and attention can be caused by several factors such as exhaustion, sickness, demands on your time, stress, boredom, hunger, etc.
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What happened to the IIAR Bulletins? Short Answer: The IIAR Bulletins were all “Superseded!” Let’s discuss the history of the onset of IIAR Bulletins and how their material was eventually distributed and captured to become superseded.
Read More>>>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.
Read More>>>Industrial and commercial refrigeration systems use different types of heat transfer fluids (HTF), many of which are toxic and/or bad for the environment when they leak. The most common HTF refrigerants are Ammonia and hydrofluorocarbons (HFC), however while ammonia has a Global Warming Potential (GWP) of 0, the HFC’s all have a very high GWPs and are currently being evaluated by the EPA for phase down as per the US Government’s December 2020 AIM Act and per the recent United States ratification of the Kigali agreement.
Read More>>>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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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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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.
Read More>>>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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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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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.
Read 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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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.”
Read More>>>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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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.
Read More>>>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.
Read More>>>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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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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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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This year looks to be a busy one for the Occupational Safety and Health Administration. Two major initiatives pertaining to Process Safety Management and injury and illness recordkeeping are already under consideration by the agency and the long awaited proposed rule on Injury and Illness Prevention Programs appears to be on the horizon.
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