IIAR

Throughout this edition of the Condenser, you’ll see a common theme: Progress. I couldn’t be more excited about where IIAR – and the industry as a whole – are heading.

Over the past few months, IIAR, and the ammonia refrigeration industry, have experienced several signs of promise and growth.

From new research projects that promise to deliver practical tools that have the potential to improve day-today operations; to new partnerships and events in Latin America that broaden our reach; to growing awareness within regulatory agencies of IIAR’s resources and expertise, we’re forging ahead to meet new opportunities and realize new goals.

One of the most exciting new goals I’ll point to is our continued emphasis on developing a stronger relationship with regulatory agencies.

We’re making stronger headway than ever before on this initiative, opening new avenues of communication with the Department of Homeland Security, Occupational Safety and Health Administration, and Environmental Protection Agency.

Recently, IIAR participated in formulating responses to two Requests for Information from OSHA and EPA, respectively. And we’re preparing to answer a similar request from DHS, recently issued as a Notice of Proposed Rulemaking.

These notices are attempts by our regulatory agencies to collect information from a variety of chemical sector industries. Their intent is to help all three update regulations and provide new guidance as a result of Executive Order 13650, which was a presidential directive to improve chemical facility safety and security.

President Obama issued the EO following the tragic accident last year in West, Texas. At its core, the EO is intended to enhance the safety and security of chemical facilities and reduce risks associated with hazardous chemicals to facility workers and operators, communities, and responders.

Since the signing of the EO, a group of federal agencies led by DHS, OSHA and EPA has been working to implement the order and identify additional actions to improve chemical safety and security.

Some of the potential policy changes could have a significant impact on the cold chain, particularly companies with over 10,000 pounds of ammonia subject to Process Safety Management and the Risk Management Program.

That’s why our involvement as an industry has never been more important. We’ve already had follow-up discussions with OSHA on the comments we provided via our response to the agency’s RFI, and we’re looking forward to similar conversations with EPA and DHS.

But it’s not just in the regulatory process where we’re seeing increased involvement. IIAR is also working closely with all three agencies to find ways to develop educational and training materials that will promote the best practices of our industry and inform regulators on a broader level.

Of course, securing our homeland against terrorist threats has never been a more important initiative, and it’s one that our industry takes very seriously.

That’s why we’ve also started to build stronger lines of communication with the Department of Homeland Security.

Beginning last February, with his visit to Nashville to attend and speak at our annual conference, David Wulf, DHS Deputy Director of the Infrastructure Security Compliance Division within the Office of Infrastructure Protection, made it clear that he is committed to listening to our input on regulatory development and learning about our industry.

I’m happy to announce that our increased level of participation between IIAR and DHS will continue into next year. DHS has already been scheduled to deliver a major workshop at our next conference in San Diego, and you can read more about David’s approach to our industry in a special interview with him that appears in this issue of the Condenser.

The bottom line when it comes to these activities is simple: your voice matters. As an IIAR member, you are closest to the operations and procedures these regulatory agencies are taking a renewed look at.

I’m confident that IIAR members are better equipped than any other group to help agencies address compliance issues. And the larger that group becomes, the clearer our voice is heard. If you work closely with colleagues who are not IIAR members, now is the time to become an advocate for your organization.

The more individuals we can reach, the more knowledge we can share and spread throughout the world. I’m looking forward to seeing IIAR grow in the coming months, and to seeing our industry continue to expand in positive ways thanks to the hard work of all of you.