By Jeffrey M. Shapiro, PE., FSFPE

The Future of IIAR 2

Our Little Baby is Growing Up

First issued in 1974, IIAR 2 is about to reach its 40th birthday. As a connoisseur of codes and standards, I can think of no other document that better captures the values and the mission of IIAR. Written over the years by individuals with some of the most recognizable names in the industry, IIAR 2 provides the primary basis for IIAR’s self-determination of the regulatory environment for design and installation of ammonia refrigeration systems.

The decision to develop and administer our own regulations comes with tremendous responsibility to ensure fairness, openness and technical validity in achieving decisions that balance safety, equipment options, installation concerns, operational concerns and cost. IIAR has embraced these challenges in the ongoing development of IIAR 2, and as a result, the document has thrived to become firmly established as the de facto national standard for design and installation of ammonia refrigeration systems.

In the past few years, IIAR 2 has achieved “adoption by reference” status in both of the U.S. model mechanical codes, and we are now seeking similar recognition in model fire codes. “Adoption by reference” status means that IIAR 2 automatically assumes the force of law when a jurisdiction adopts a model code that includes the IIAR 2 reference.

For example, the 2012 International Mechanical Code (IMC) states in Section 1101.6 “Ammonia-refrigerating systems shall comply with this code and, except as modified by this code, ASHRAE 15 and IIAR 2.” Chapter 15 of the IMC then references a specific edition of IIAR 2 that is legally adopted and enforceable in any jurisdiction adopting the IMC. With the Uniform Mechanical Code containing a similar reference and model fire codes likely to do the same in 2015, IIAR 2 will be adopted as law in literally tens of thousands of jurisdictions throughout the United States and around the world. That’s an achievement that firmly establishes IIAR as the focal point of the ammonia refrigeration industry.

Next step…becoming an adult: Since its inception, IIAR 2 has remained aligned with its original purpose by closely focusing on equipment and machinery room design and installation. To address additional aspects of refrigeration safety, IIAR 2 has maintained a symbiotic relationship with ASHRAE 15, Safety Standard for Refrigeration Systems. That relationship includes IIAR 2 relying on ASHRAE 15 as a technical supplement and having ASHRAE 15 rely on IIAR 2 for regulations that are unique to the design and installation of ammonia systems. To facilitate harmony between the documents, the ASHRAE 15 technical committee includes representation from the ammonia refrigeration industry, and members of the ASHRAE 15 committee participate in the development of IIAR 2.

In the past few years, particularly with the increasing popularity of ammonia as a natural refrigerant, the need for clear and concise regulation of industrial ammonia refrigeration systems has never been greater. However, under the current system, we simply cannot achieve that goal. This is partly true because, to determine the regulations for designing and installing an ammonia system, you have to review IIAR 2, ASHRAE 15 and the applicable mechanical code. Then you must digest the order of authority for these documents when conflict or overlap occurs, with the mechanical code requirements taking precedence over their referenced standards. Next, there is an assumption that IIAR 2 should supersede ASHRAE 15 for ammonia systems based on the “specific prevails over general” rule that codes operate under (contrary to popular belief, the most restrictive provision doesn’t always apply…but that’s a topic for another article).

To those of us who are users of ASHRAE 15, it’s probably fair to say many will agree it’s a challenge to quickly find and figure out how to apply regulations that govern industrial ammonia refrigeration. That’s no particular fault of the ASHRAE 15 document itself, but rather a consequence of ASHRAE 15 having such a broad scope, applying to all refrigeration systems and all refrigerants in all applications. So, the question arises, can IIAR 2 assume a standalone role in the world of standards to become a single source document? It is my opinion that the answer to that question is “yes,” and it is further my opinion that IIAR 2 assuming that role is in the public interest.

Letting go of a teenager: Without suggesting that ASHRAE is a parent of IIAR 2, it is a fact that ASHRAE 15, with roots dating to the 1930s, has a few more years under its belt. The relationship between these two documents has been mutually beneficial, and strong ties remain between IIAR and ASHRAE. There is no reason for any of that to change. However, stepping to the next level offers new opportunities to both IIAR and ASHRAE.

For example, the technical committee that writes ASHRAE 15 is facing new challenges, particularly with respect to incorporating the new Group 2L refrigerant class. Much of the effort associated with integration of Group 2L refrigerants is focused on human comfort air conditioning systems; however, because ammonia is classified as Group 2L, any integration of this new category into ASHRAE 15 must be done with an eye on the affect on industrial ammonia systems. If ASHRAE 15 were modified to simply reference IIAR 2 for industrial ammonia systems, this issue and the challenge of sifting ammonia regulations out of the complexity of ASHRAE 15 would be resolved.

On IIAR’s side, the Standards Committee, which is charged with maintaining IIAR 2, faces a significant challenge of incorporating regulations for topics that have previously been entrusted to ASHRAE 15. That work is already well underway, and the current objective is to have this work completed for incorporation into the 2014 update of IIAR 2.

In summary, some may wonder whether things can simply continue as they have for the past 40 years, and the answer to that question is “yes.” But, the more important question is “can we do things better and better serve the public interest by developing IIAR 2 into a standalone standard for industrial ammonia systems?” The answer to that question is also “yes.” To get there will require a consensus of the industry that IIAR 2 is ready to come out from under the wing of ASHRAE 15, and that should be a popular topic of discussion over the next year or two.