IIAR
1110 North Glebe Road
Arlington, VA 22201
703.312.4200
Contact IIAR

IV. REGULATORY REGIMES FOR REFRIGERATION SYSTEMS

Industry codes and standards have been developed and revised over the years to address risks associated with refrigeration systems, and they incorporate appropriate systems requirements and personnel training. These industry-driven codes and standards, which have done the most to achieve acceptable levels of safety associated with ammonia refrigeration systems, include certain system engineering and design standards and operating codes developed by the International Institute of Ammonia Refrigeration (IIAR), American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) and the American National Standard Institute (ANSI): the 1999 American National Standard for Equipment, Design and Installation of Ammonia Mechanical Refrigeration Systems (ANSI/IIAR 2-1999); and the 1994 American National Standard: Safety Code for Mechanical Refrigeration (ANSI/ASHRAE 15-1994).

Three categories of federal regulations have application to activities involving ammonia.⁶¹ The Occupational Safety and Health Administration (OSHA) within the Department of Labor administers most workplace safety requirements and has promulgated standards addressing workplace hazards associated with ammonia and applicable to ammonia refrigeration systems. The Environmental Protection Agency (USEPA) administers most federal environmental requirements, including numerous reporting and risk management requirements applicable to ammonia refrigeration systems. The Department of Transportation (USDOT) administers most requirements applicable to the transportation of ammonia. In addition, multiple state and local codes are also applicable to ammonia refrigeration systems.

While these federal, state and local regulatory regimes attempt to address environmental and workplace safety issues, a more tailored application, reflecting an appropriate understanding of ammonia refrigeration, would reduce certain regulatory barriers that prevent the expanded use of ammonia as a refrigerant. A more tailored application of regulations would at the same time enhance the intended environmental and safety goals by channeling resources to the most critical aspects of systems operations and integrity.

Facilities in many countries that store or handle hazardous chemicals have established Process Safety Management (PSM) programs. PSM is a comprehensive program developed by employees and management at facilities to ensure that proper safety, maintenance, and standard operating procedures are followed. A PSM program is intended to examine and minimize potential hazards.⁶² Facilities have also developed Risk Management Programs (RMP) to prevent, detect and respond to accidental releases of hazardous chemicals and to inform local communities of the risks.⁶³ The PSM and RMP programs were developed to address highly hazardous materials and grew out of the Bhopal incident and others at petrochemical refineries. In the U.S., both are applicable to ammonia refrigeration only because of the hazards incident to the transportation of ammonia and ammonia's widespread use.

As currently applied under U.S. law, PSM and RMP requirements create regulatory burdens for ammonia refrigeration applications. Paperwork and document retention are particularly burdensome. Significant resources are required by facility operators to engage the regulatory compliance system. These regulations as presently constituted divert resources from more effective preventive measures and inhibit the expanded use of ammonia refrigeration systems. With an appropriate application of PSM and RMP programs to ammonia refrigeration systems, safety to individuals, communities, and the environment would be enhanced.