2020 IIAR State of the Industry Report

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2020

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CONTRIBUTORS Special thanks to all those who contributed to the 2019 State of the Industry Report.

Stephanie Smith, PE – Risk Management Professionals Beth Fox – EVAPCO Melissa Cassell – General Refrigeration Company Kristen De La Pena – GCAP, LLC (Garden City Ammonia Program) Eileen McKeown – IIAR Bruce Nelson – Colmac Coil/Chair of the IIAR Board of Directors Tom Melotik – Emerson Werner Paulus – Refrigeration Design & Service Inc.

AGENCIES OSHA Kansas City, MO Regional Office

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TABLE OF CONTENTS 4 | Industry Background: Recent History 5 | Industry Composition 6 | IIAR Green Paper 6 | Inspections 7 | USEPA National Response Center (NRC) Release Data 10 | OSHA Violations Data 13 | Regulatory and Standards Update 15 | Low-Charge Ammonia Systems 16 | Challenges for End Users 16 | IIAR and Its International Reach 18 | IIAR Educational Resources 20 | Government Relations Update 21 | Where is the Industry Headed?

22 | References 23 | 2019 Survey Responses 25 | 2020 Survey Questions 26 | Participate in IIAR Committees

LIST OF FIGURES 5 | Figure 1: IIAR Membership by Category 8 | Figure 2: 2013 to 2018 USEPA NRC Data – Ammonia Reportable Incidents 8 | Figure 3: 2013 to 2018 USEPA NRC Data – All Reportable Incidents 9 | Figure 4: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Discharger Type 9 | Figure 5: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Incident Cause 11 | Figure 6: 2013 to 2018 OSHA Violations by PSM Element 11 | Figure 7: 2013 to 2018 OSHA Violation Penalties by PSM Element 12 | Figure 8: 2013 to 2018 Annual OSHA Violations

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abstract The 3rd Edition of the State of the Industry Report has evolved to include more information on IIAR’s influence on the industry, including its international relations and guidance provided for other countries’ efforts to establish their own standards. The Green Paper, re-published in 2019, highlights IIAR’s efforts in providing information to the general public on the use of natural refrigerants.

Inspection data from the United States Environmental Protection Agency and the Occupational Safety and Health Administration is included and updated for 2013 to 2018. In addition, the regulatory updates include some details on the “New RMP Rule” and the California Cooling Act. Even for those outside of California, this new legislation may impact the purchasing ability in other states and, eventually, what is regulated nationally.

IIAR has added sections highlighting the challenges for end users in the industry, the state of government relations with IIAR, and the educational resources of IIAR. These new sections will continue to be developed and updated in future reports. Also new this year, is a preface from the Chair of the Board of Directors, Bruce Nelson.

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preface This very valuable 3rd Edition of the IIAR State of the Industry report is the result of many hours of research and hard work by our Marketing Committee and Staff. The report contains the very good news that ammonia release incidents as well as OSHA violations have declined significantly over the last 5 years. The data in the report also highlights the ongoing need to continue our focus on safety particularly in the areas of Mechanical Integrity, Process Safety Information, Process Hazard Analysis, and Operating Procedures.

The refrigeration and air conditioning industries in the United States continue to be driven by two distinct political forces and regulatory entities; the first being climate change and the USEPA, and the second being public health and safety and OSHA. Regulatory compliance has become a significant economic driver for companies, and it is expected to continue in the near term. This report is an important resource for decision makers considering their facilities and operations regarding safety and compliance issues.

The international activities of the IIAR and adoption of our safety standards by several Latin American countries is also mentioned and something we should all be very excited about.

Finally, the educational activities of our Academy of Natural Refrigerants are mentioned as a key component in the profoundly important work of creating competency in our industry.

Thank you for your interest in this important work and let this express my gratitude to the IIAR Marketing Committee and Staff for their good work.

Best Wishes, Bruce I. Nelson, P.E. 2019-2020 IIAR Chairman

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industry background: RECENT HISTORY Newer technologies have made processes become more efficient, require fewer or reduced inventory of hazardous chemicals, and provide additional safety for personnel and communities surrounding these facilities. The “regulatory burden� continues to challenge businesses to balance operations and compliance and has undoubtedly made an impact on the safe operations of systems regulated under these programs. The business culture surrounding these facilities has also changed to take a more proactive and preventative approach to operations and maintenance.

Natural refrigerants lead the industry as the most sought after refrigerants. Carbon dioxide (CO2) dominates the emergence of new refrigerants, but others are becoming more common as well. Natural refrigerants have low Ozone Depletion Potentials (ODPs) and Global Warming Potentials (GWPs), which makes them environmentally compatible by most standards. The IIAR Green Paper (updated publication in 2018 and discussed below) presents a comparison of refrigerants and benefits of using natural refrigerants.

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industry composition The industrial refrigeration industry is diverse. IIAR has over 2,500 members from over 50 countries around the world. Alliance organizations in Asia Pacific, Europe, Latin America, and North America make the international outreach very successful. Members of IIAR include design engineers, end users, contractors, students, scientists, and trainers.

The chart below shows the distribution of members within IIAR, not included are employees of IIAR and honorary life members. The data below illustrates that end users, contractors, and manufacturers make up 83% of the organization membership. For clarification, “End User 1” refers to members whose inventory is more than 10,000 pounds and “End User 2” refers to members whose inventory is below 10,000 pounds.

FIGURE 1: IIAR MEMBERSHIP BY CATEGORY

IIAR Green Paper The IIAR Green Paper was originally developed as a position paper for the use of ammonia as a

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IIAR Green Paper The IIAR Green Paper was originally developed as a position paper for the use of ammonia as a refrigerant. Originally published in March of 2019, the Green Paper provided an argument for the environmentally-friendly nature of ammonia and attempted to assure the general public that ammonia, used under the right conditions, was a safe and viable option for industrial refrigeration. As new technologies and natural refrigerants began emerging on the market, IIAR set out to update the Green Paper.

In January 2019, an updated IIAR Green Paper was published. “Natural Refrigerants for a Sustainable Future� was spear-headed by the IIAR Marketing Committee and updated to reflect the current nature of the industrial refrigeration industry and emerging refrigerants.

The paper gave a brief overview of the industry and, then, discussed the benefits of ammonia, carbon dioxide, and other natural refrigerants over synthesized refrigerants.

inspections OSHA and USEPA are responsible for the inspections of regulated facilities within their PSM and RMP Programs, respectively. In addition, General Duty Clause (GDC), RAGAGEP, Respiratory Protection, and Lockout / Tagout programs are also subject to inspections by one or both agencies. The following sections discuss the National Response Center (NRC) and OSHA violations data.

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USEPA National Response Center (NRC) Release Data Release data was examined from the USEPA NRC where reporting data was acquired for analysis on trends with reportable releases. The USEPA NRC is the designated federal contact point for reporting various discharges to the environment in the United States and its territories. The reporting threshold for ammonia releases is 100 pounds. This report presents USEPA NRC data from 2013 through 2018 and was acquired from the Right-ToKnow Network (RTK) Network NRC reporting database (Right To Know Network, 2019).

Figures 2 and 3 are shown below and compare 2013 to 2018 incidents specifically reported for ammonia releases and incidents reported for all chemicals, respectively.

Overall, national incidents have been on the decline. Ammonia incidents have declined 58% from 2013 to 2018, which is about the same as all incidents. While the reasons behind the decline in reportable incidents is not studied, it is reasonable to assume that increased awareness of safety concerns, increased inspections by regulatory agencies, and technological advances to design inherently safer systems all have contributions to the decline in reportable incidents.

There was a total of 113 reported incidents for ammonia from 2013 to 2018. Figure 4 below demonstrates the breakdown by discharger type acquired from the RTK Network.

The percentages by industry have remained generally unchanged in the last seven (7) years. In Figure 5, the NRC data shows that the highest occurrence of incidents are caused by “other” causes (43%), equipment failures (33%), and “unknown” causes (17%). These causes make up a total of 93% of the ammonia incidents reported by the NRC. These percentages remain generally unchanged in the last seven (7) years.

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Know Network, 2019).

Figures 2 and 3 are shown below and compare 2013 to 2018 incidents specifically reported for ammonia

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releases and incidents reported for all chemicals, respectively. Overall, national incidents have been on the decline. Ammonia incidents have declined 58% from 2013 to 2018, which is about the same as all incidents. While the reasons behind the decline in reportable incidents is not studied, it is reasonable to assume that increased awareness of safety concerns, increased inspections by regulatory agencies, and technological advances to design inherently safer systems all have contributions to the decline in reportable incidents.

FIGURE 2: 2013 TO 2018 USEPA NRC DATA – AMMONIA REPORTABLE INCIDENTS

Figure 2: 2013 to 2018 USEPA NRC Data – Ammonia Reportable Incidents 30 24

25

24 20

20

20

14

15

10

10

5

0

2013

2014

2015

2016

2017

2018

FIGURE 3: 2013 TO 2018 USEPA NRC DATA – ALL REPORTABLE INCIDENTS

Figure 3: 2013 to 2018 USEPA NRC Data – All Reportable Incidents 5

35,000 30,000

29,168

28,503

26,915 24,189

25,000

24,447

20,000 15,000

11,948

10,000 5,000 -

2013

2014

2015

2016

2017

2018

There was a total of 113 reported incidents for ammonia from 2013 to 2018. Figure 4 below demonstrates the breakdown by discharger type acquired from the RTK Network. The percentages by industry have remained generally unchanged in the last seven (7) years. In Figure 5, the NRC data shows that the highest occurrence of incidents are caused by “other” causes (43%), equipment failures (33%), and

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“unknown” causes (17%). These causes make up a total of 93% of the ammonia incidents reported by the

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NRC. These percentages remain generally unchanged in the last seven (7) years.

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Figure 4: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Discharger Type

FIGURE 4: 2013 TO 2018 USEPA NRC DATA – AMMONIA Figure 4: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Discharger Type INCIDENTS

BY DISCHARGER TYPE PRIVATE ENTERPRISE 2%

2%

PRIVATE ENTERPRISE

2%

2%

2%

UNKNOWN / BLANK

7%

UNKNOWN / BLANK

2%

7%

PRIVATE CITIZEN PRIVATE CITIZEN

PUBLIC UTILITY

PUBLIC UTILITY

OTHER / N/A OTHER / N/A GOVERNMENT (local GOVERNMENT (local / state / federal) / state / federal) MILITARY

MILITARY

POLICE

87%

DEPARTMENT POLICE DEPARTMENT

87%

FIRE DEPARTMENT Figure 5: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Incident Cause

FIRE DEPARTMENT

EQUIPMENT FAILURE FIGURE 5: 2013 TO 2018 USEPA NRC DATA – AMMONIA INCIDENTS Figure 5: 2013 to 2018 USEPA NRC Data – Ammonia Incidents by Incident Cause

BY INCIDENT CAUSE UNKNOWN 1%

1%

1%

2%

1%

EQUIPMENT FAILURE

1% 2% 2%

OTHER

UNKNOWN

OPERATOR ERROR

1%

OTHER

VESSEL SINKING OPERATOR ERROR

2%

VESSEL SINKING OVER PRESSURING

33%

33%

OVER PRESSURING

NATURAL PHENOMENON (Hurricane,

tornado, flood, earthquake) NATURAL PHENOMENON (Hurricane, tornado, flood, earthquake) DUMPING DUMPING TRANSPORT ACCIDENT

TRANSPORT ACCIDENT

DERAILMENT DERAILMENT

43% 43%

EXPLOSION EXPLOSION TRESPASSER

TRESPASSER

17%

17%

SUICIDE

SUICIDE

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DISORDERLY PASSENGER

DISORDERLY PASSENGER

AIRCRAFT DIVERSION

AIRCRAFT DIVERSION

OSHA Violations Data In addition toData incident and release data, this report summarizes OSHA violations data for the entire OSHA Violations United States. Violations are an important parameter to summarize because it provides insight into

In addition to incident and release data, this report summarizes OSHA violations data for the entire

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OSHA violations data In addition to incident and release data, this report summarizes OSHA violations data for the entire United States. Violations are an important parameter to summarize because it provides insight into compliance improvement within the industry. From 2013 to 2018, OSHA recorded a total of 3,951 violations of the PSM regulations. Initial penalties are those issued during the initial violation notification. OSHA allows facilities to negotiate lower fees for violations during informal conference. The agreed upon penalty after informal conference is referred to as the “current penalty.” During this time period, initial penalties were reported as $21.0 million and the current penalties were reported as $14.9 million, which is a 30% reduction in penalties.

Of the total violations, 906 were for 1910.119(j) – Mechanical Integrity (MI) and another 878 violations were for 1910.119(d) – Process Safety Information (PSI). Figure 6 below illustrates the distribution of the number of violations from 2013 to 2018 by PSM element.

What that data may demonstrate is that there are a great number of facilities that may not be properly maintaining their systems and documentation for Mechanical Integrity and Process Safety Information. In addition, 593 violations under section 1910.119(e) – Process Hazard Analysis and 602 violations under section 1910.119(f) – Operating Procedures were reported.

The 2018 OSHA data also provides some additional insight, as the data was broken down to further detail within each section. The highest number of violations in a single subsection (98 violations) were under 1910.119(d)(3), which requires information pertaining to the technology of the process. The next highest number of violations in a subsection (80 violations) were under 1910.119(f)(1), which requires the facility to develop operating procedures for each phase of operation. More data on other sections is available from OSHA.

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The 2018 OSHA data also provides some additional insight, as the data was broken down to further detail

within each section. The highest number of violations in a single subsection (98 violations) were under within each section. The highest number of violations in a single subsection (98 violations) were under

1910.119(d)(3), which requires information pertaining to the technology of the process. The next highest 1910.119(d)(3), which requires information pertaining to the technology of the process. The next highest

numbernumber of violations in a subsection (80 violations) were under 1910.119(f)(1), facility of violations in a subsection (80 violations) were under 1910.119(f)(1),which whichrequires requires the the facility to develop operating procedures for each phase of operation.

More data to develop operating procedures for each phase of operation.

More dataononother othersections sections is is available available from OSHA. from OSHA.

FigureFigure 6: 2013 to 2018 OSHA Violations

by PSM Element 6: 2013 to 2018 OSHA Violations

by PSM Element FIGURE 6: 2013 TO 2018 OSHA VIOLATIONS BY PSM ELEMENT 1910.119(j) MI 1910.119(j) MI 1910.119(d) PSI 1910.119(d) PSI 1910.119(f) - OP

147

1910.119(f) - OP

1910.119(e) - PHA

1910.119(e) - PHA

1910.119(l) - MOC

1910.119(l) - MOC

149 147

1910.119(h) - CON

1910.119(h) - CON

1910.119(o) - CA

34 034 01616

74 74

236

147

64 105105

64 906

906

149

147

236

1910.119(o) - CA

1910.119(g) - TRN

1910.119(g) - TRN

1910.119(m) - II

1910.119(m) - II

1910.119(n) - EP&R

1910.119(n) EP&R EP 1910.119(c) -

1910.119(c) EP 1910.119(i) PSSR 1910.119(i) PSSR HWP 1910.119(k) 1910.119(p) 1910.119(k) HWP TS

593

878

593

878 602

602

1910.119(p) - TS

Figure over each eachPSM PSMelement. element.

Figure7 7demonstrates demonstratesthe thedistribution distribution of of penalties penalties over

FIGURE 7: 2013 TO 2018 of OSHA VIOLATION PENALTIES Figure 7 demonstrates the distribution penalties over each PSM element.

Figure 7: 2013 to 2018 OSHA Violation Penalties by PSM Element

BY PSM ELEMENT $6,000,000 $5,000,000 $4,000,000 $3,000,000 $2,000,000 $1,000,000

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Figure 8, below, illustrates the total violations broken down annually. It is important to note that the number of violations can greatly differ depending on the availability of inspectors and how many inspections are conducted in a single year. In the last five years, 2013 had more violations than any other year and an increase in violations occurred between 2015 and 2016, which may correlate to OSHA’s

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Figure 8, below, illustrates the total violations broken down annually. It is important to note that the number of violations can greatly differ depending on the availability of inspectors and how many inspections are conducted in a single year. In the last five years, 2013 had more violations than any other year and an increase in violations occurred between 2015 and 2016, which may correlate to OSHA’s National Emphasis Program (NEP) and directive CPL 03-00-021 for inspecting facilities under the PSM Program (Directorate of Enforcement Programs, 2017). We saw a similar increase in violations in 2018 following the directive.

FIGURE TO 2018 Figure 8: 20138:to2013 2018 Annual OSHAANNUAL Violations OSHA VIOLATIONS 1200

1000

800

600

400

200

0

2013

2014

2015

2016

2017

2018

Regulatory and Standards Update It’s been an everchanging regulatory environment since 2017 as the USEPA’s new RMP Rule was promulgated and reconsidered. The RMP Reconsideration Final Rule Fact Sheet is now available. Some of the new RMP Rule requirements were rescinded, others retained, and yet others retained with modifications. Facilities should be diligent in reading about the changes and what compliance

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requirements they have for the future. Below is a brief summary of the retained requirements.

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Emergency response coordination between the facility and local responders is required annually, regardless of what type of emergency preparedness plan is selected, and coordination activities are to be 3RD EDITION JANUARY 2020

documented. Local responders must be provided a copy of the Emergency Response Plan, updated emergency contact information, and other information deemed relevant by the local responder for

regulatory and standards update It’s been an everchanging regulatory environment since 2017 as the USEPA’s new RMP Rule was promulgated and reconsidered. The RMP Reconsideration Final Rule Fact Sheet is now available. Some of the new RMP Rule requirements were rescinded, others retained, and yet others retained with modifications. Facilities should be diligent in reading about the changes and what compliance requirements they have for the future. Below is a brief summary of the retained requirements.

Emergency response coordination between the facility and local responders is required annually, regardless of what type of emergency preparedness plan is selected, and coordination activities are to be documented. Local responders must be provided a copy of the Emergency Response Plan, updated emergency contact information, and other information deemed relevant by the local responder for emergency response. The compliance date was March 14, 2018 and facilities should already be complying. Annual notification drills in coordination with emergency responders must be done and compliance is required by five (5) years following the date of the Final Rule publication.

Field and tabletop exercises are due by four (4) years following the date of the Final Rule publication. Owners/operators are also required to develop plans to conduct the emergency drills and exercises. Tabletop exercises are required every three (3) years and the first exercise must be completed by seven (7) years following the Final Rule publication.

Field exercises are required at a frequency that the local emergency responder deems appropriate and there is no established deadline, except for the coordination required to determine a frequency.

The US EPA revised the requirement for public meetings so that the facility is only required to have a public meeting following an incident when that incident has off-site impacts.

Meetings must be held within 90 days of the incident and compliance for this requirement starts for incidents occurring after March 15, 2021.

The US EPA rescinded the third-party audits, Safer Technologies and Alternatives Analysis (STAA), incident investigation root cause analysis, and facility chemical hazard information requirements. These items are listed in the RMP Reconsideration Final Rule Fact Sheet.

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Recognized and generally accepted good engineering practices (RAGAGEP) continues to be a “hot topic.” IIAR has released the ANSI/IIAR Standard 9 Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems at the 2020 IIAR Natural Refrigeration Conference & Heavy Equipment Expo to address minimum safety standards for ammonia refrigeration.

The “California Cooling Act (CCA)” (SB 1013) was passed by California legislature on August 30, 2018 and required that businesses begin the transition from listed hydrofluorocarbons (HFCs) starting January 1, 2019. The bill authorized financial incentives for low-Global Warming Potential (GWP) refrigeration systems, likely in an effort to phase our ozone-depleting synthetic refrigerants. The bill preserved the original EPA deadlines to eliminate HFCs. Facilities should be aware of the impacts of SB 1013 if they are located in California or supply their refrigerant from California.

In an effort to improve safety, the Environmental Protection Agency (EPA) Region 1 (New England) developed a pilot initiative to improve compliance with the Clean Air Act’s General Duty Clause at facilities that have small ammonia refrigeration systems beginning in June of 2019.

According to the EPA at least 4 out of 5 refrigeration facilities using ammonia in Region 1 are not covered by the EPA’s Risk Management Program (RMP) rule, meaning that they are operating at less than 10,000 lbs of ammonia at each facility.

Some of the most dangerous facilities that EPA inspected were not aware of the hazards that their refrigeration systems posed to people. To address this problem, Region 1 has launched a pilot initiative to improve smaller facilities’ compliance with the first prong of the General Duty Clause, which requires facilities using extremely hazardous substances to identify hazards that may result from accidental releases using appropriate hazard assessment techniques.

Prior to launching the initiative Region 1 had been collecting information on low charge ammonia refrigeration facilities in the area mostly through a grassroots outreach effort. The

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EPA has been sending targeted information requests to selected facilities that it has reason to believe may be out of compliance. The objective is to ensure that facilities that operate above 1,000 lbs of ammonia and below 10,000 lbs has performed a proper hazard review. The EPA has not yet expanded this program to other regions of the United States.

The Chemical Safety Board (CSB) released its Final Rule on accidental chemical release reporting on February 5, 2019. The rule creates a new reporting requirement for facilities that experience a chemical release. The Final Rule states that the CSB’s focus will be on education and compliance. The rule makes it unlawful for any person to fail to report any accidental chemical release resulting in a fatality, serious injury or substantial property damage. The key take-away from this Final Rule is that facilities are now responsible for notifying the CSB of reportable incidents. You will still need to report appropriate incidents to the EPA and OSHA as well.

low-charge ammonia systems Low-charge systems are becoming more popular due to their physical size and their ability to work effectively and stay under most regulatory threshold limits. Smaller systems save space and smaller inventories can be used and combined with secondary coolants (i.e., CO2, glycol, air, water, etc.). While with smaller systems, businesses may be able to avoid the EPA RMP and OSHA PSM regulations, it is important to note that the GDC still applies to those who are not over the established threshold limits. Low-charge systems are being utilized for office building or retail ventilation systems, which brings ammonia use into the commercial application.

IIAR finalized its Low Charge Ammonia Refrigeration Management (ARM-LC) Summary Guide and Guidelines for end users required to meet minimum safety and regulatory compliance for systems with 500 pounds or less of ammonia. ARM-LC provides guidance on how to meet regulatory requirements and appropriately address elements needed to maintain a safe system. The intention is that this guidance will assist facilities in meeting GDC requirements.

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challenges for end users The continued challenge for end users is the public perception of specific refrigerants.

What most of the public doesn’t fully comprehend are the pros and cons to all refrigerants.

While some may be non-toxic, they have no odor and present higher asphyxiation hazards. Others are more flammable. The IIAR Green Paper reviews different types of systems and refrigerants, and provides the reader with a balanced view of the pros and cons of natural refrigeration.

The other monumental challenge is the cost of regulatory compliance. As regulations become more complex and expand to new chemicals, the burden because ever-increasing.

Managing documentation and maintaining records can be an unsurmountable effort on its own. With the emergence of additional refrigerants, end users have more options to evaluate and decide what is best for their system and operation. The ideal end-goal is to be able to effectively manage the costs and burden by balancing the refrigerant used, the regulatory requirements, and the cost of running the business.

IIAR and its international reach IIAR currently has active international chapters in Argentina, Chile, Columbia, Costa Rica, Ecuador, Mexico, Peru, and other parts of Central America. In addition, IIAR is in the process of establishing chapters in Brazil, Paraguay, Spain, and Uruguay. IIAR continues collaboration efforts with both India and China. The IIAR has seen an increase in membership due to outreach and activity conducted through chapter programs.

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Over the last 20 years, IIAR has created strong alliances with many international associations and has been able to extend its reach worldwide through these partnerships.

IIAR has active international alliances with the Australian Refrigeration Association, Chinese Association of Refrigeration, eurammon, ACAIRE, Cámara Chilena de Refrigeración y Climatización, and CIEMI. As the IIAR has built up its international alliances and chapter programs there has been growing interest in the adoption and use of IIAR Standards and education materials within corresponding countries.

One of the first countries to begin negotiations on the adoption of IIAR Standards through establishment of an international chapter and work with local affiliates was Colombia.

IIAR in cooperation with ACAIRE has been working to incorporate parts of IIAR 2 into the country’s regulatory language. A formal agreement with ACAIRE was signed in 2019 to develop regulation on the use of natural refrigerants in Colombia which would be based on and refer to IIAR standards. Work is ongoing and includes collaboration with the Colombia Ministry of Environment.

Costa Rica has also begun to incorporate IIAR Standards in their code and regulatory language. CIEMI and the IIAR worked closely in 2019 to move toward adoption of IIAR 2 in regulatory language.

In 2018 Chile published a country-wide ammonia standard which was written in cooperation with the Chilean Chamber of refrigeration and air-conditioning association (CCRhYC) and Highland Refrigeration (McLaughlin, 2018) and incorporates much of IIAR 2. In cooperation with CCRhYC, the IIAR has participated in the development of a diploma course on refrigeration at the Universidad de Santiago de Chile.

Work is also being done in India and China to incorporate IIAR standards into local regulations. IIAR 2 has been translated into Mandarin.

IIAR continues to work with our chapters and alliance partners to establish events and education offerings throughout the world. If you are interested in attending or participating in any of IIAR’s international events, go to www.iiar.org/events/international

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IIAR educational resources The Standards Committee has finalized IIAR 9 and IIAR 6, receiving ANSI approval in March 2020 and May 2019 respectively. While updating/reviewing standards continues to be an important task for IIAR, providing educational resources has jumped to the forefront. IIAR has expanded its educational content to include certificate courses for IIAR 2, IIAR 6, IIAR 4/5/8, PSM & RMP Guidelines, and PHAs. IIAR is planning to expand its offerings on courses in 2020. Work on translating these programs in to Spanish has begun.

Due to its increasing use in industrial and commercial refrigeration applications, the IIAR will have a new CO2 Standard approved soon. Discussions and meetings have been ongoing in order to establish the scope and content of the standard. The IIAR has also established the Learning Management System for direct links to the certificate programs provided by the organization. An increased frequency of international events has also emerged, see the IIAR website for a current list of events.

IIAR has recently begun work on creating a standard for Hydrocarbons as well as the development of guidelines for the use of manual hand valves.

The 2020 plan is to have an online end user portal up and running. This portal will give end users access to regulatory information, an avenue for sharing ideas and solutions to common issues, and general information about changes within the industry.

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THE IIAR SUITE OF STANDARDS IIAR 1 – American National Standard for Definitions and Terminology Used in IIAR Standards. Provides a unified set of definitions for use in the IIAR Standards IIAR 2 – American National Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems. IIAR 2 is the definitive design safety standards for the ammonia refrigeration industry.

IIAR 3 – American National Standard for Ammonia Refrigeration Valves. IIAR 3 specifies criteria for materials, design parameters, marking and testing of valves and strainers used in closed-circuit ammonia refrigeration systems.

IIAR 4 – American National Standard for Installation of Closed-Circuit Ammonia Refrigeration Systems. IIAR 4 was written to serve as a standard for the installation of closed-circuit ammonia refrigeration systems and overpressure protection relief piping systems IIAR 5 – American National Standard for Start-up of Closed-Circuit Ammonia Refrigeration Systems. IIAR 5 provides basic minimum requirements for the safe start-up of closed-circuit refrigeration systems and additions and modifications made to such systems.

IIAR 6 – Inspection, Testing, and Maintenance for Safe Closed-Circuit Ammonia Refrigeration Systems. IIAR 6 provides the minimum requirements for inspection, testing, and maintenance (ITM) tasks and record keeping applicable to closed-circuit ammonia refrigeration systems.

IIAR 7 – American National Standard for Developing Operating Procedures for ClosedCircuit Ammonia Mechanical Refrigerating Systems. IIAR 7 defines the minimum requirements for developing operating procedures for closed-circuit ammonia refrigeration systems and is intended for those who develop, define, and/or review operating procedures for ammonia refrigeration systems.

IIAR 8 – American National Standard for Decommissioning of Closed-Circuit Ammonia Refrigeration Systems. IIAR 8 specifies the minimum criteria for removing the ammonia charge in conjunction with the decommissioning of closed-circuit ammonia refrigeration systems.

IIAR 9 – Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems. IIAR 9 provides a method for existing stationary closed-circuit refrigeration systems using ammonia as the refrigerant to evaluate and document new and revise codes, standards, and practices to determine what provision should be implemented in the existing system.

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government relations update As part of an ongoing effort to advance the mission of the IIAR and increase engagement with United States government agencies who may have regulatory purview over the refrigeration industry, key IIAR staff and committee members meet with interested government agencies, on some level, on an annual basis. From enforcement to legislation, the IIAR continues to monitor government agency programs affecting the refrigeration industry.

In the past year the IIAR has had ongoing discussions and active engagement with the Environmental Protection Agency (EPA), Occupation Health and Safety Administration (OSHA), Department of Homeland Security (DHS), and Chemical Safety Board (CSB) to name a few.

Active work within our staff and committees includes the review of ammonia IDLH levels along with emergency management guidance regarding use of APR with NIOSH and OSHA as well as review of ammonia release quantity limits with EPA. IIAR continues to work on standards which help promote the safe and sustainable use of natural refrigerants within refrigerated facilities.

IIAR has once again signed an alliance with GCCA and OSHA designed to provide training to government agency personal. These trainings and education sessions help inspectors better understand the unique aspects of industrial refrigeration facilities and the IIAR standards specifically developed to support them. IIAR is also supporting the Industrial Refrigeration Consortium (IRC) with a similar effort. The goal is to increase awareness within the regulatory community of the unique safety and operation of natural refrigeration systems.

IIAR continues to monitor government programs which impact the use of all refrigerants.

IIAR also continues to make government agencies aware of the benefits of ammonia and other natural refrigerants for their viability and potential for future use.

For more information on government programs please got to www.iiar.org/governmentandcode

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where is the industry headed?

There are many challenges that face the industrial refrigeration industry in the future.

Emerging regulations surrounding refrigerants, including changes to the USEPA and OSHA programs and California’s Refrigerant Management Program, may initiate further complications in reporting and the usage of alternative refrigerants.

With the phase-out of HFCs and the push for reduced amounts of high-GWP refrigerants, end-users are in a situation where they must decide which regulations they will choose to be governed by, rather than if they can remove their facility from a under a regulatory agency by restricting their inventory or using alternative refrigerants.

More encouraging, however, are the advances within the industry utilizing newer technologies and refrigerants as alternatives to ammonia. For example, many facilities have opted to design CO2 and hydrocarbon refrigeration systems, which is a low-GWP refrigerant and very efficient. Even with additional regulations that may surround the use of CO2, this refrigerant is increasingly studied for its sustainability in the industry. The largest consideration in utilizing any refrigeration system over another is the facility’s needs for loading, operations, and expansion.

The future of IIAR holds some promising potential as it works to establish a worldwide standard for industrial facilities building. Internationally, more countries are following the US and Europe’s lead for safety standards surrounding natural refrigerants and are partnering with US and European resources to do so.

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references Directorate of Enforcement Programs. (2017, January). OSHA Directive CPL 03-00-021.

Retrieved from OSHA: https://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-021.pdf Global Cold Chain Alliance. (2017). ChemNEP & Ammonia Refrigeration Enforcement Update.

McLaughlin, C. (2018, October 17). Ammonia21. Retrieved from http:// ammonia21.com/articles/8622/chile_ammonia_standard_to_be_published_ soon?utm_source=shecco+natural+refrigerants&utm_campaign=f6d03a8947Bi-Weekly+Newsletter_20180731_COPY_23&utm_medium=email&utm_ term=0_9db972ca57-f6d03a8947-291720833 Right To Know Network. (2019, November 12). NRC Incidents Report Search. Retrieved from Right To Know Network: http://www.rtk.net/erns/search.php

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OF THE industry 3RD EDITION JANUARY 2020

2019 survey responses When IIAR launched the inaugural State of the Industry Report at the 2018 IIAR Natural Refrigeration Conference & Expo in Colorado Springs, CO, we asked that our members participate in a survey created to serve as a year over year benchmark for our industry. We appreciate the response we received from our 2019 survey. We have seen participation in the survey jump precipitously. We would appreciate your feedback.

Question 1: For those who have classified reportable incidents to the NRC as “other” or “unknown,” can you describe the nature of those releases? Why were they not easily classified?

In 2018 all responses were considered non-applicable to the respondent. In 2019, while most responses indicated that this question was non-applicable to the respondent, we did receive some valuable insight from a few respondents. Responses indicated that in the matter of NRC reporting all releases are generally reported no matter what due to the fact that proper classification “requires more information than can be gathered within 15 minutes.”

Question 2: What new technologies, other than “traditional” ammonia closed-circuit refrigeration systems, are end-users implementing in their facilities (i.e. cascade systems, low-charge systems, CO2 Transcritical etc.)?

For the second year in a row low charge system have dominated the response to this question. Other responses include CO2 Cascade using low charge ammonia primary systems, transcritical CO2, subcritical CO2, low carbon, zero carbon, secondary systems, and packaged systems. One response indicated that a change from Ammonia to CO2 as the primary refrigerant was being made because permits for building CO2 facilities are easier to obtain than for Ammonia.

Question 3: If the membership could make one (1) change or suggestion to the regulatory community, what would you change or suggest?

For the second year in a row, out of our five survey questions, this question received the most responses. Respondents expressed interest in the standardization of codes and regulation across North America. They also found that PSM and RMP requirements were too punitive when applied to ammonia facilities. One respondent expressed confusion that ammonia, which has 0 ODP and 0 GWP, is heavily and onerously regulated even

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though freon is being phased-out due to environmental issues. Other respondents expressed interest in having the regulatory community mandate lower charges for refrigeration facilities.

Charge limits on hydrocarbons were an area of concern. Most respondents indicated that better communication between the regulatory community would be a benefit to them.

Question 4: What is the biggest challenge faced for end-users in the industrial refrigeration industry?

Respondents suggested that end users should be educated on the dangers of use of all refrigerants, not just ammonia, since all acceptable refrigerants have some hazardous traits. Respondents expressed that regulatory compliance was a pain point, both the cost to keep up with compliance paperwork and the cost of penalties with regard to minor infractions to compliance.

Manpower was also an issue specifically in how to hire and retain a trained workforce.

Question 5: EPA requires any release of ammonia greater than 100lbs to be reported within 15 minutes of said release. Have you ever failed to report an ammonia release within 15 minutes because it was not possible to identify the specific quantity within that time? What was the type and dollar value of the citation you received?

When respondents answered yes to this question, they indicated that fines had prompted policy changes within their organizations to over-report. Due to the severity of potential fines, all facilities which were cited for this infraction enacted policies to report any release of ammonia from the system regardless of the amount within 15 minutes to the EPA NRC. The consensus was that 100 lbs was not easily calculated and could lead to inaccurate or late reports. Fines reported for failing to report an ammonia release over 100 lbs within the first 15 minutes ranged from $20,000.00 USD to $75,000.00 USD. Question 6: What information would you like to see in future reports?

Respondents requested that the State of the Industry include a table of incidents with all refrigerants, a breakdown of system types installed per year and more information on regulatory efforts to lesson the compliance burden.

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OF THE industry 3RD EDITION JANUARY 2020

2020 survey questions Based on the response we received for the 2019 survey, we have reworked and expanded our question set for 2020. Again, we would appreciate your input in this year’s survey. Information collected in this survey will be reported in the 2021 IIAR State of the Industry Report.

Question 1: For those who have classified reportable incidents to the NRC as “other” or “unknown,” can you describe the nature of those releases? Why were they not easily classified?

Question 2: What new technologies, other than “traditional” ammonia closed-circuit refrigeration systems, are end-users Implementing in their facilities? (i.e. cascade systems, low-charge systems, CO2 Transcritical etc.)

Question 3: If the membership could make one (1) change or suggestion to the regulatory community, what would that change or suggestion be?

Question 4: What is the biggest challenge end-users face in the industrial refrigeration industry?

Question 5: EPA requires any release of ammonia greater than 100lbs to be reported within 15 minutes of stated release. Have you ever failed to report an ammonia release within 15 minutes because it was not possible to identify the specific quantity within that time? What was the type and dollar value of the citation you received?

Question 6: What information would you like to see in future reports?

Question 7: As an equipment manufacturer, facility designer or end user, please describe ways in which you were able to increase energy efficiency in equipment and/or facility operation.

To participate in the survey, go to www.iiar.org/iiar/stateoftheindustry.

Email publications@iiar.org for more information.

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participate in IIAR committees CO2 COMMITTEE – Chair: Luke Facemyer, Stellar – The IIAR CO2 Committee maintains a close working relationship with our National and International members to; update information, review code requirements, update material, provide methods of application, research, safety and new component development.

COMPLIANCE GUIDELINES COMMITTEE – Chair: Jeanna Emmons, PSM RMP Solutions – Manages and updates the IIAR regulatory publications. The committee maintains the PSM/RMP Manual, ARM Manual, Ammonia Data Book and new regulatory publications.

EDUCATION COMMITTEE – Chair: Mark C. Stencel, Bassett Mechanical, Inc. – The Education Committee works to expand knowledge about natural refrigeration industry by aiding in creating and distributing publications including, codes, videos, workshops seminars and more.

GOVERNMENT RELATIONS COMMITTEE – Chair: Jeffrey P. Carter, General Mills, Inc. – Dedicated to government relations, the Government Relations Committee was formed to work directly with the Institute’s government affairs representative. As IIAR continues to work on behalf of the industry with government officials both in the U.S. and in other countries, the committee addresses issues important to IIAR members and continues the organization’s tradition of advocacy on behalf of the industry.

INTERNATIONAL COMMITTEE – Chair: Adolfo Blasquez, Sr., A. Blasquez Refrigeración Industrial – The International Committee expands IIAR activities around the world, recruits new members, translates IIAR publications and increase global distribution of IIAR publications through appropriate refrigeration organizations worldwide.

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OF THE industry 3RD EDITION JANUARY 2020

MARKETING COMMITTEE – Chair: Beth Fox, EVAPCO, Inc. – Promotes the use of ammonia refrigeration, reinforces IIAR’s image within the ammonia refrigeration and related industries through advertisements and advertorials in industry publications; ensures that industry information is disseminated to members, industry and the general public; works with the headquarters staff on maintaining the marketing plan; develops and administers effective programs to ensure continued growth of IIAR.

PIPING COMMITTEE – Chair: Gordon B. Struder, EVAPCO Inc. – Develops and publishes consensus specifications for pipe fittings and pipe materials used in the construction of ammonia refrigeration piping systems. Reviews other areas of interest that concern piping systems such as cleanliness, welding procedures, insulation and pipe sizing and recommends appropriate response to review issues which may include issuing publications.

RESEARCH COMMITTEE – Chair: Wayne F. Wehber, Vilter Manufacturing LLC – Identifies and develops work statements that when implemented will benefit the ammonia refrigeration industry and assists the IIAR staff in the development of these work statements into completed research projects.

SAFETY COMMITTEE – Chair: Joseph M. Fazzari, Colmac Coil Manufacturing, Inc. – The Safety Committee develops and implements projects intended to inform as well as educate the ammonia refrigeration industry and related parties on the proper and safe use of ammonia as a refrigerant and the proper and safe operation and maintenance of ammonia refrigeration systems.

STANDARDS COMMITTEE – Chair: Robert J. Czarnecki – Updates and interprets the IIAR standard(s), review and interface with other standard writing organizations that include ammonia and ammonia refrigeration systems within their standards, develops ideas for and writes new standards (and other publications of interest to the industry) to be sponsored by IIAR and work with the American National Standard Institute (ANSI) and IIAR staff in moving standards through the ANSI approval/review process.

ENERGY & SUSTAINABILITY COMMITTEE – Chair: Stefan Jensen, Scantec Refrigeration Technologies – The Energy & Sustainability Committee is newly formed in 2020. This committee will focus on energy efficiency and sustainability topics that have attracted significant interest across the world. Rising costs of utilities including both energy and water, new energy and water efficiency standards, international agreements pertaining to reduction of emissions and the phase-down of certain synthetic refrigerants are all topics that the committee intends to address.

For more information go to www.iiar.org/committees

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IIAR is the world’s leading advocate for the safe, reliable and efficient use of ammonia and other natural refrigerants. IIAR members share their collective knowledge and experience to produce consensus documents that address various aspects of the natural and industrial refrigeration industry.

IIAR has broad industry representation including manufacturers, design engineers, contractors, end users, academics, scientists, and trainers. IIAR sets the standard for providing advocacy, education and the most up-to-date technical information to the ammonia and natural refrigeration community.

We help professionals develop their skills and further their careers by promoting the common interests of members.

OUR VISION AND MISSION Our vision is to create a better world through the safe and sustainable use of natural refrigerants Our mission is to provide advocacy, education, and standards for the benefit of the global community in the safe and sustainable design, installation and operation of ammonia and other natural refrigerant systems.

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OF THE industry 3RD EDITION JANUARY 2020

MARCH 28-31, 2021 PALM SPRINGS, CA

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