Training Provides Guidance and Insights for OSHA Field Personnel

IIAR, the Industrial Refrigeration Consortium (IRC), and the Global Cold Chain Alliance are continuing their work to provide information on ammonia systems, including their principles of operation, major subsystem components, and materials of construction, to the Occupational Safety and Health Administration’s compliance safety and health officers. Two trainings took place in 2023 and the groups plan to offer it again in 2024.

Mike Chapman, director of business operations for IIAR, said the training is invaluable to any inspector ith inspection responsibilities for Risk Management Programs and Process Safety Management Programs. “An educated inspector is much more valuable to our industry than an uneducated one,” he said. “Educated inspectors know what they’re looking, look for the stuff that needs to be found, and, if they find it, the facility can address it for the minimization of risks.”

The course provides in-depth coverage of IIAR’s standards, identifies IIAR guideline documents, and gives participants access to the IIAR Government Portal. “The course also covers some basics of mechanical integrity as it applies to ammonia refrigeration systems since this has been a significant point of confusion with compliance safety and health officers (CSHOs) in the past,” said Doug Reindl, professor of mechanical engineering and director of the IRC at the University of WisconsinMadison, and the course instructor.

OSHA’s National Emphasis Program includes provisions that require OSHA to conduct PSM inspections of ammoniarefrigerated facilities. “In the somewhat distant past, CSHOs did not have a foundational grounding in ammonia refrigeration systems and technologies and issues arose when they attempted to apply other kindred industry standards as RAGAGEP to these facilities,” Reindl said. “Part of the role of this training is to connect CSHOs with the RAGAGEP that applies to the ammonia refrigeration industry.

The target audience for the training is field personnel who will be conducting inspections of ammonia-refrigerated facilities.

The course’s learning objectives give CSHOs an understanding of: industrial ammonia refrigeration systems and their principles of operation; the types of engineered safety systems applied to ammonia refrigeration technology; the RAGAGEP that applies to industrial ammonia refrigeration systems; and the common failure mechanics that can compromise the mechanical integrity of industrial ammonia refrigeration systems.

Reindl said the feedback from the attendees has been positive. “End-users that have longitudinal experience in interacting with OSHA personnel before the training was available and OSHA personnel that have taken training note that their inspections/interactions with CSHOs are much more productive,” he said. “They can more clearly communicate with the CSHOs in a language both understand.”

This online CSHO training was an outgrowth of an F2F course the IRC has been delivering to EPA inspectors for more than a decade. “Some OSHA personnel were able to participate in the F2F class and found it very beneficial,” Reindl said. “That led to OSHA seeking an opportunity to receive a trimmed-down version of the EPA course but in an online synchronous format since they are much more travel-restricted.

Chapman said that, overall, inspectors are trying to make sure facilities are doing what they are supposed to do. “Facility operators want to do the right thing. With the right training, they can interface with inspectors better,” he said. “When the inspectors arrive and have a seamless interaction with facility operations personnel and each are using understandable jargon, it’s a win-win.”