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industry dynamics

The continued challenge for end users is the public perception of widely used refrigerants. What most of the public does not fully comprehend are the pros and cons of all refrigerants. While some may be non-toxic, they have no odor and present higher asphyxiation hazards. Others are more flammable. Some of this reportedly is exacerbated by regulators, fulfilling their job duties, but also amplifies a negative public perception by concentrating on highly hazardous chemicals used as refrigerants when they may be more efficient and marketable than other refrigerants. Ammonia is a good example of one of these types of refrigerants.

The other monumental challenge is the cost of regulatory compliance. As regulations become more complex and expand to new chemicals, the burden becomes everincreasing. Managing documentation and maintaining records can be time consuming but manageable with support from non-regulating agencies providing guidance and standards. Especially since documentation must not only be completed, but also be accurate. Any change to the system and/or management/personnel may require a documentation review and update. 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.

The IIAR SOI Surveys from the past few years provided great insight into what other challenges end-users face in their operations. Overall, respondents are concerned that the regulatory community is putting too much burden on facilities that is not constructive. Suggestions included regulatory agencies taking a more constructive and helpful approach to facilities that are struggling with compliance, requiring that non-compliance fines be applied to improvement projects rather than just funding the regulatory agency and more alignment between state and federal agencies. There were also a few suggestions that regulatory agencies spend additional time training the inspectors for consistency on regulation interpretation/enforcement and specifically on ammonia facility operations, so they have more specific education on these types of systems.

IIAR has supported the Government Support Portal for many years. The portal allows access to IIAR’s most current Standards and the Basic Ammonia Refrigeration and Safety Series to Regulatory agents/officers. IIAR sponsors a regulatory training program through the Industrial Refrigeration Consortium (IRC) and also works with the Global Cold Chain Alliance (GCCA) and World Food Logistics Organization (WFLO) to support an OSHA Alliance training program for regulators. There is also a coalition between IIAR, the American Safety Training Institute (ASTI), the Refrigerating Engineers and Technicians Association (RETA), and GCCA to support a formal Safety Day training program which caters to first responders and the regulatory community. In addition, IIAR staff members are in contact with numerous government agencies to ensure they are aware of IIAR’s presence in the industry and the objectives of the organization.

Nation-wide licensing requirements for trained operators and maintenance personnel was also a common response in past surveys. While there are no regulatory requirements for licensing, there are licensing programs and certification programs available to establish a corporate hiring or promotion policy. By far, the biggest challenge identified by end-users revolved around staffing and qualified operator availability. Lack of skilled and qualified workers remains a challenge in the industry as apprenticeship programs graduates, skilled trades graduates, and college graduates are all still lagging in numbers due to the challenges of remote learning during the pandemic.

The IIAR Marketing Committee is currently completing work on a refrigeration informational portal. This portal will give members 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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