IIAR

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.”

Accidents involving ammonia refrigeration systems, while rare, still occur. The initial guideline was developed to help avoid the inadvertent or accidental opening of manual valves which has been a cause of ammonia releases and should be avoided.

Although the U.S. Occupational Safety and Health Administration (OSHA) enacted the “The control of hazardous energy (lockout/tagout)” regulation in 1989 (Title 29 §1910.147), the industry has lacked clarity on applying this regulation to manually operated hand valves in ammonia refrigeration systems. “Historically, lockout/tagout programs have appropriately focused on hazardous electrical and mechanical energy,” Lundell said.

The Guideline for Developing an Energy Control Plan for Manual Hand Valves in Ammonia Refrigeration Systems was designed to fill a gap in the industry by describing best practices. “This publication provides guidance to owners, operators, maintenance personnel, and contractors on applying an energy control program to manual hand valves in ammonia refrigeration systems,” Lundell said.

IMPORTANT UPDATES
The main change in the second edition refines the definition and application of “exclusive control.” Because this update occurred soon after its initial publication, and the changes are important but not extensive, IIAR provided those who purchased the first edition with changes to insert into their guideline.

“The second edition was developed in response to some observations by end users who were uncertain about implementing methods that rely on ‘exclusive control’ as it was defined in the first edition,” said Eric Smith, vice president and technical director at IIAR. “Subsequently, the first edition was submitted to an attorney with extensive experience with industry applications of OSHA’s lockout/tag out regulations. The attorney recommended a few changes to the first edition that draws on language from OSHA’s regulations and an ANSI standard addressing energy control.”

The attorney suggested that IIAR “tighten up” the guideline’s definition of exclusive control by placing more conditions on it and aligning it more with OSHA’s 29 CFR 1910.147(a)(2)(ii). “This regulatory clause includes a note that certain ‘minor servicing activities’ are exempt from 1910.147’s LOTO requirements provided that several prerequisites are met,” Smith said.

These are 1) minor servicing must take place during normal operations; 2) be routine, repetitive and integral to the use of the equipment for production; and 3) utilize alternative measures that effectively protect employees. “Information was also drawn from ANSI Standard Z244.1 that addresses alternate energy control methods under certain conditions,” Smith said.

The IIAR Safety Committee proceeded to make some minor but important changes that enhanced the guideline’s definition of “exclusive control” and included some additional suggestions for training, both of which support the spirit of the OSHA rules and the ANSI standard’s language while maintaining a reasonable approach to simple operations involving little risk. The committee believes that using the guideline will provide LOTO methods acceptable to both industry and regulators.

Lundell said IIAR’s guidelines are continuously improved. “When input is received that can make the guideline clearer and/or provide additional value, it is considered for implementation in an addendum or the next revision,” he said, adding that this guideline is a tool to supplement an existing lockout/tagout program relative to manual hand valves in ammonia refrigeration systems.

Owners, owners’ designated representatives, such as operators and technicians, and hired contractors can also use the guideline for developing a new energy control plan for their ammonia refrigeration system(s) and/or for a lockout/tagout procedure for a specific portion of the system(s) or for pieces of different equipment.