IIAR

When anyone asks me how I can best describe my experience in nearly forty years at sea, I merely say, uneventful. Of course there have been winter gales, and storms and fog and the like. But in all my experience, I have never been in any accident…or any sort worth speaking about. I have seen but one vessel in distress in all my years at sea. I never saw a wreck and never have been wrecked nor was I ever in any predicament that threatened to end in disaster of any sort.”

– E. J. Smith, 1907, Captain, RMS Titanic

Despite our ability to assume that all is OK, humans are fallible and bad things happen.

It is the responsibility of each of us to perform our roles in a safe manner, for our own good, for the good of our colleagues, our customers, our families and for the community at large. In that regard, the building of the collaborative relationship between IIAR, the EPA and OSHA, all whom have safety at the core of their values, is worthy of our efforts and attention.

Both OSHA, through their National Emphasis Programs (NEP), and the EPA, through their National Enforcement Initiatives (NEI), have elevated their focus on ammonia refrigeration installations and can apply penalties, which are never welcomed by the recipient, as one potential outcome of such activities.

While we are all aware of the potential negative outcomes of punitive actions, it should be noted that the goal to be served is to ensure the safe use of ammonia. As such, the EPA and OSHA are strong supporters of many of the non-punitive developments undertaken by IIAR and are participating in several of them.

The expansion and codification of IIAR-2, our industry’s Safe Design Standard for ClosedCircuit Ammonia Refrigeration Systems, has enabled its’ recognition by both agencies as RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) for our industrial refrigeration applications. In September meetings held in Washington DC with both EPA and OSHA officials, they welcomed IIAR’s educational initiative and the development of our IIAR-2 Certificate Program, which enables consistent documented evidence of attainment of knowledge of the safe practices detailed in the Standard.

Through the efforts of the IIAR Government Relations Committee, as well as our industry colleagues with the IRC, GCCA and ASTI, we have supported and embarked on several educational initiatives for the field personnel of EPA and OSHA. This reflects our belief, and theirs, that knowledge of safe ammonia practices and ammonia system design benefits inspectors, emergency response providers, ammonia refrigeration practitioners and the communities we serve.

We have sponsored an education program, developed by IIAR Board Member, Doug Reindl, and the IRC, focused on building ammonia refrigeration knowledge for OSHA’s CSHO’s (Compliance, Safety and Health Officers). The program consists of weekly two-hour sessions, supplemented by homework assignments, extending over five weeks of instruction. The pilot program was attended by 30 CSHO’s and PSM Coordinators from OSHA and the January session has been fully booked, with 40 participants from OSHA.

Upon completion of the five week workshop, it is intended that the OSHA participants will have familiarity with the major components comprising an ammonia system and their principles of operation. They will have developed an understanding of the engineered safety systems applied by our industry, as well as applicable RAGAGEP. Further, they will have obtained an understanding of the common failure mechanics that can compromise the integrity of an ammonia refrigeration system. In further support of the knowledge attainment of the appropriate regulatory bodies, we have provided special access through our “government portal” to key elements of the IIAR website to representatives of OSHA, the EPA and the Department of Homeland Security. This enables review and study of IIAR Standards and Publications which serve as essential RAGAGEP for ammonia refrigeration.

With ASTI, we have developed an Ammonia Training Day targeting regulatory inspectors, local emergency planning committees and emergency response teams. The first of these, being held in EPA’s Region 8 Conference Center in Denver, Colorado was held on November 16th and will be followed by three similar sessions over the next year, with a planned Boston, MA based Ammonia Training Day being the next, scheduled in January.

IIAR’s portion of the Safety Day’s content, heavily focused on emergency response and emergency action plans, will be delivered by Dave Rule, IIAR President and Eric Smith, IIAR Vice-President and Technical Director. We are making the content of their presentations available to other regulatory agency employees through our website.

Four years ago, under the guidance of Joe Mandato, then IIAR Chair, we recognized the need for enhanced advocacy and “re-started” the activities of IIAR’s Government Relations Committee, which had been disbanded. Under the leadership of Don Stroud, Committee Chair and by the efforts of its members, the Committee has served to lead processes that build upon the common goal of IIAR, EPA and OSHA; the safe and reliable operation of ammonia and other natural refrigerant systems. The Government Relations Committee has become, again, a vital contributor to IIAR’s progress.

IIAR’s Vision and Mission both begin with the founding IIAR principle of advocacy. As a collective, with a membership reflecting a high percentage of engineers and technical leaders, our advocacy is not of the “pat on the back” variety. Rather the core of our advocacy is founded on development of sound engineering and operational principles, debate and consensus development of best practices and the education of all parties involved in moving our industry forward.

We have been well served by such an approach and we welcome and encourage the participation of all of our membership in continuing to keep our industry safe.