IIAR

In this edition of the Condenser we’re shining the spotlight on the work of the IIAR Standards Committee, which develops, updates, and publishes current and comprehensive standards that members across the industry can trust.

To that end, the committee has taken on a huge project in recent years: writing and maintaining a suite of standards that serve as a comprehensive reference for good engineering practices for all aspects of ammonia refrigeration systems. “The goal for all of our standards is to publish them as American National Standards Institute, or ANSI standards,” said Robert Czarnecki, Standards Committee chair, adding that this reinforces IIAR’s standing as a valuable provider of information to the ammonia refrigeration industry worldwide.

“We’re using these standards to replace many of the IIAR bulletins so that they become the documents for reference and requirements.”

The Standards Committee, which is made up of 14 voting members and 28 corresponding members, said it hopes to complete each of the standards by October 2014.

This effort further establishes IIAR’s prominence as a standards developing organization, and continues IIAR’s tradition of providing standards that serve as credible and valuable resources.

The Standards Committee, which has already published four of the eight standards, is incorporating input from individuals involved in all aspects of the industry. In fact, the committee is made up of manufacturers, engineers, contractors, end-users, and academics. That broad array of individuals ensures the standards will be wellrounded and comprehensive, said Czarnecki. “It gives all the different perspectives.” The committee is also providing the public with an opportunity to share their perspectives. Upon completion of each standard, the committee releases it for public review.

“In each case, we take all the comments, rewrite the document, incorporate all the answers, and send it out for public review again,” he said.

“Then, the IIAR standards committee presents that work to the consensus body, which is a balanced group of experts that weigh in with final comment and approval.”

President Obama Signs Executive Order on Chemical Facility Safety and Security

On the first of August, President Obama announced the signing of an Executive Order entitled: Improving Chemical Facility Safety and Security. The action was in response to the explosion earlier this year at a fertilizer facility in West, Texas. A Chemical Facility Safety and Security Working Group will be formed to direct the federal government’s efforts to implement the Executive Order.

The working group will be cochaired by representatives from the Department of Homeland Security, Environmental Protection Agency and the Department of Labor. Other representatives on the working group will be from the Department of Justice, Department of Agriculture and Department of Transportation. The Executive Order outlines four major goals to improve chemical safety and security:

• Improve operational coordination with state and local partners
• Enhance federal agency coordination and information sharing
• Modernize policies, regulations and standards
• Work with stakeholders to identify best practices While many of the efforts undertaken in support of the order will be focused on improving how federal agencies work together and share information, it is possible that the effort will result in additional regulations impacting the cold chain industry. For example, the order states that within 90 days EPA and OSHA shall review the chemical hazards covered under the Risk Management Program and Process Safety Management and determine if either of these programs need to be expanded. EPA and OSHA would also be required to develop a plan to implement and enforce such expansions.

IIAR Government Affairs will continue to actively monitor developments regarding the Executive Order.

DHS Issues Letters to Facilities Regarding CFATS Program

The Department of Homeland Security, DHS, has recently sent a large number of letters out to facilities regarding potential non-compliance with the Chemical Facilities AntiTerrorism Standards, or CFATS. The letters are a result of DHS engaging in an increased information sharing effort across Federal and State governments to better understand the universe of chemical facilities. They have attempted to cross-match DHS facility data with that of other agencies such as the Environmental Protection Agency.

The potential non-compliance referenced in the letter stems from whether the facility filed a Top-Screen with DHS. Notwithstanding certain exemptions, facilities with a chemical of interest, COI, at a screening threshold quantity, STQ, must file a Top-Screen with DHS within 60 days of acquiring a threshold quantity of the chemical. Anhydrous Ammonia is classified as a chemical of interest and the threshold quantity is 10,000lbs. Members receiving such a letter from DHS are encouraged to review their facility history to determine whether a Top-Screen has been filed with DHS, or if the facility is exempt.

Current exemptions from the TopScreen requirement are:

• The facility does not possess a chemical of interest at a threshold quantity
• The facility is regulated under the Maritime Transportation Security Act of 2002
• The facility is a wastewater or drinking water facility
• The facility is owned by the Department of Defense, Department of Energy or subject to the Nuclear Regulatory Commission
• The facility is an agricultural production facility subject to the current indefinite extension to the Top-Screen requirements Facilities that have either filed a Top-Screen previously or are exempt are directed to contact DHS at Compliance. Assistance@hq.dhs.gov or IP/ ISCD, Mail Stop 8100, Department of Homeland Security, Washington, DC 20528-8100 as soon as possible.

Facilities with questions can call the DHS CSAT Helpdesk at 1-866-323- 2957. Be sure to have your letter from DHS with you when you call. Facilities that are not exempt and have not filed a Top-Screen should move quickly to get into compliance. The letter provides a deadline of September 9, 2013 for facilities to complete their filing. More information on the CFATS Top-Screen process can be found in the CSAT Top-Screen User Manual.