Industry Stakeholders Continue Work on Critical Task Guidelines

The Critical Task Guidance for Ammonia Refrigeration System Emergency Planning is a key resource designed to support employers, government regulators, and public safety responders in preparing for and mitigating ammonia-related incidents. The guidance, which was released in 2021, promotes a proactive approach to safety in facilities where ammonia refrigeration systems are in use and is currently being revised in response to feedback from users, regulatory agencies, and committee review. 

“Like the first editions of many publications, many opportunities to improve and clarify the document were identified by both the compliance committee and OSHA reviewers,” said Eric Smith, vice president and technical director for IIAR. “This next edition enhances the first by clarifying the intent, providing reorganization of the material, including additional information on tasks and training, and providing additional references and resources.”

Background and Development

The first edition was developed by members of the International Institute of Ammonia Refrigeration (IIAR), Refrigerating Engineers and Technicians Association (RETA), Global Cold Chain Alliance (GCCA), and Ammonia Safety and Training Institute (ASTI). It incorporated input from multiple regulatory bodies and aimed to provide foundational safety practices.

“There are two main goals for this document. The first is to encourage facilities and employees to wear ammonia purifying respirators and personal ammonia detectors when performing high-risk tasks, such as initially opening a system,” Smith said. “The second main goal is to encourage facilities to react to small releases and stop them when it is safe to do so rather than relying solely on public emergency response teams.”

Many releases can be stopped quickly if personnel are prepared for the unexpected, and this document can help facilities prepare for such circumstances.

“The critical task guidance includes more clarity about how a trained technician or operator can engage emergency system control while working in environments that do not exceed Immediately Dangerous to Life and Health (IDLH) concentrations (300 ppm),” said Gary Smith, chief executive officer of the Ammonia Safety Training Institute “ “Performing these tasks would not place a facility into a HAZWOPER emergency response plan category.”

Three Core Areas of Guidance

The guideline focuses on three broad areas essential for effective emergency planning:

Reaction Planning and PPE Use: Facilities should have a well-defined reaction plan for unexpected ammonia releases and ensure workers are equipped with the appropriate personal protective equipment (PPE). This helps reduce or eliminate exposure risks during tasks with high ammonia hazard potential.

Medical and Rescue Preparedness: Emergency Action Plans (EAPs) and Emergency Response Plans (ERPs) must address the specific needs and procedures related to medical and rescue efforts, enhancing response outcomes in the event of an incident.

Training for All Stakeholders: Comprehensive training is vital, not only for employees but also for visitors, contractors, and others who may need to respond during an incident. Proper training helps reduce liability and ensures a faster, more effective response.

Critical Tasks Identified

The document also outlines three critical tasks for managing ammonia system emergencies: preparation, escape, and system emergency control, and rescue.

“The guideline can be used to help ensure that existing or new emergency action plans include appropriate personal protective equipment selection, training, emergency planning, and communication associated with these critical tasks,” Eric Smith said.

For organizations with well-established safety programs, adopting this guidance shouldn’t create a significant cost burden. “Those with minimal action plans and procedures may incur some expense and effort in training and upgrading personal protective equipment, but it would be a fraction of the cost of an unanticipated shutdown, even if such a shutdown is just a few hours,” Eric Smith added.

Voluntary, Yet Valuable

It’s important to note that this guidance is not an ANSI Standard and was not developed under ANSI/IIAR rules for standards development. “As such, its use is voluntary, and its content should not be considered normative requirements,” Smith explained. “However, IIAR intends to have this guideline reviewed by all IIAR committee members, which will ensure its broad acceptance both by the membership and the industry in general.”

The second edition is nearing completion and is expected to be ready for distribution by the third quarter of the year, pending final reviews.

Key Focus Areas for Enhancing Emergency Action Plans for Ammonia Releases

The goal of an emergency action plan is to prevent exposure, protect property, and safely manage potential ammonia releases through preparation and systematic response. To improve emergency action plans for ammonia releases, focus on these key areas:

Operational Readiness

  • Train all employees and visitors on ammonia awareness
  • Establish clear evacuation and shelter-in-place procedures
  • Create communication protocols for reporting releases
  • Develop a 30-minute emergency response playbook
  • Train ammonia refrigeration operators and technicians to “First Responder – Operations Level”

Equipment and Protection

  • Use air-purifying respirators (APRs) and personal monitors
  • Stage APRs in areas with potential access issues
  • Have escape hoods available

Response Procedures

  • Define what constitutes a “controllable release”
  • Train employees to safely slow or stop small releases
  • Use emergency exhaust fans and ventilation to reduce concentration
  • Establish clear roles for incident commanders and technicians

Coordination

  • Coordinate with local emergency responders
  • Develop clear leak investigation procedures
  • Create plans for remote release mitigation
  • Establish two-way communication during emergencies

Training

  • Provide awareness training for all site personnel
  • Train specific personnel on emergency control techniques
  • Conduct regular drills and scenario planning