Accelerate America #5 April 2015

Page 39

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

39


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