Policy
But executive order 13650 could lead to some constructive
government,” he said. “We’re communicating back to the
changes, Randel said. “It includes improved coordination
agencies that micro-management is not the intention of these
with federal agencies and improved information sharing,
standards.”
also improved coordination between state and local officials, including the first response community.”
Randel expects a lengthy process. “I think the EPA is going to move more quickly; their stated goal is to have a proposal by
Randel described the executive order as “a real chance for
this fall and a final rule by the end of 2016, as they’re trying to
OSHA and the EPA to advance some policy issues they’ve been
get things done before the end of the Obama administration,” he
thinking about for quite some time.” This includes expanding
said. “OSHA is going to move more slowly and part of that is the
the elements that underlie OSHA’s Process Safety Management
procedures that they have to go through, including what they call
(PSM) standard, including “different metrics that might be
a panel for small business impacts. The IIAR has a big role to
useful,” he said.
play there too.”
In addition, with the increasing adoption rate of indirect
Meanwhile. IIAR-2 -- IIAR’s industry standard on equipment,
(secondary) refrigeration systems that confine ammonia to the
design, and installation of closed-circuit ammonia mechanical
engine room, OSHA is reviewing the PSM regulation on charge
refrigeration systems -- is under major revision and out for public
limits. In another presentation at the IIAR Conference, Evapco
review through mid-2015. One of the reasons the standard
Vice President Kurt Liebendorfer said that while OSHA was
has undergone a major rewrite is to help close the gaps
unlikely to change charge limits as part of the current review, it
with ASHRAE-15, Uniform Mechanical Code (UMC), NFPA-1,
may do so in future.
International Mechanical Code (IMC) and the International Fire Code (IFC). The results will have implications for packaged and
Meanwhile, as part of its Risk Management Program, EPA has
low-ammonia-charge systems, and include new definitions for
put out a request for information relating to formal rule-making
equipment enclosures and secondary coolants.
changes. The IIAR has responded by forming a task force that includes the Global Cold Chain Alliance, International Association
Following Randel’s presentation, IIAR code consultant Jeff
of Refrigerated Warehouses, American Frozen Food Institute,
Shapiro urged attendees to support the IIAR as its first source
American Meat Institute, North American Meat Institute and the
for 2015 model codes and standards. “There are some minimum
US Poultry and Egg Association.
requirements you should meet if you’re operating an ammonia facility and we should be the ones to prescribe that, not another
Randel believes some of the potential changes could be
organization.”
costly. “We feel you know your facility better than the federal
Codes and Low-Charge At the IIAR Conference, Liebendorfer of Evapco, which
“The regulations and the codes have been coordinated over
supplies its own range of low-charge-ammonia refrigeration
the years and I found in reading all these codes that they
systems, summarized his paper, “Regulatory and Code
contain many common requirements and this is a good
Implications for Low-Charge Ammonia Systems.”
thing,” Liebendorfer said. “However, there is a real lack of [a common threshold-quantity definition] related to ammonia
Liebendorfer said the main reason low-charge systems are
charge size or ammonia charge management. Therefore, an
becoming so important is that the threat of ammonia releases
effort should be made between all major code writing bodies
still drives the regulatory burden. Codes and standards such
to communicate and coordinate better support of charge
as OSHA, IIAR, ASHRAE, International Building Code, IMC and
reduction, which I think is what everyone is after because it
UMC all have various design references to the quantity of
should reduce the risk and it should reduce the regulatory
refrigerant in a system. Yet despite impressive coordination
burden.”
as a whole, there remains a lack of consistency on the definition of low-charge size.
continued on p.40
April 2015 Accelerate America
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