The Natural Refrigeration

The timeliest issues in the industry – from IIAR-2’s relief calculation formula to hot work permits for sulfur sticks – are being discussed in standards subcommittee meetings. This year, at the IIAR Natural Refrigeration Conference & Expo, March 15 – 18, IIAR standards subcommittee leaders convened to give IIAR members a chance to ask their own questions. The Q&A format illuminated some of the biggest issues the industry is working on with regulators and settled some common misconceptions around standards.

Q: Safety showers are regulated by an ANSI standard and OSHA, so why are they in IIAR-2?

A: “The ANSI standard Z358.1 for safety showers is not adopted in the mechanical code. It’s a suggestion; honestly, until it’s adopted, we put it in IIAR-2 so it would be adopted. If you read that [ANSI] standard, it’s pretty vague where they want the showers to go. They don’t specify or state if a shower goes in this room or that room; they just give some suggestions. So that’s the reason we put it in IIAR-2, so that it’s adopted in the model code.” – Mark Bazis, IIAR-2 Subcommittee Chair

Q: Do sulfur sticks need a hot work permit?

A: The safety committee is looking at this issue and how to respond. “There is an OSHA interpretation that says sulfur sticks require a hot work permit, but we don’t agree with this interpretation. This is something we’re going to have to take up with OSHA.” – Eric Smith, IIAR, Vice President of Technology, Advocacy, Research, Publications

Q: In IIAR-2, why was the formula for relief calculations changed, wasn’t the old formula easier?

A: “It’s not always about being easier. There were a lot of gaps in the old formula. In the old formula, it was for technically just the discharge of the relief valve up to the header. The new formula really cleaned that up, and now we do the pressure loss calculations all the way back to each relief valve.” – Mark Bazis, IIAR-2 Subcommittee Chair

Q: Is IIAR-1 [Definitions and Terminology Used in IIAR Standards] only for use in standards or is it intended to be useful on its own?

A: “[The standard is] useful to look at and understand where this industry is focused, the definitions that are given are certainly a valuable investment of time to look at from an educational standpoint.” – Jake Denison, IIAR-1 Subcommittee Chair

Q: Once the new requirements come out for ventilation [in IIAR-2], will we have to update our rooms?

A: “Usually every mechanical code has a statement in there that says that if your system is being operated safely, you don’t have to update to the current mechanical code. Of course, every AHJ, or Authority Having Jurisdiction, has the option to require you to update to the most current mechanical code. So the short answer is no, but you would probably have to have a reason why you wouldn’t. And this applies to any standards that are adopted by the mechanical code in your AHJ. Anytime anyone puts in a new system, they have to follow the latest mechanical code in their area.” – Mark Bazis, IIAR-2 Subcommittee Chair

Q: What are the areas to be considered in the next version [of the CO2 Standard] with what has been learned with the increased use of small and medium-size systems? Is there a ballpark number estimate of the number of systems that exist that are using IIAR-CO2?

A: “Yes, we’ve seen a tremendous growth of CO2 systems being installed. In the last 20 years, we’ve gone from what might be counted in the dozens here in the U.S. to tens of thousands across the world. What we’ve learned is that there are certain areas where [that growth] has complicated things. The industry is looking for better direction and guidance on [several things]. I touched on reliefs as one of the primary needs; that’s an immediate area of focus for standards. Some of the other areas aren’t necessarily related to small and medium systems, but are general, safety and basic requirements.” – John Collins, CO2 Subcommittee Chair

Q: When is the CO2 standard expected to become enforceable?

A: “It is in the model codes in the U.S.;” IIAR-CO2 is enforceable now. “An addendum will be published this year.” – John Collins, CO2 Subcommittee Chair

Q: Referring to IIAR-8 [Decommissioning of Closed-Circuit Ammonia Refrigeration Systems], when is it recommended to decommission an ammonia plant? Is this decision based on the lifetime of the components or more related to safety?

A: “In my experience, this has been a business decision. Our subcommittee team has had other experiences where a system was dormant, or it wasn’t used for a long time, and that decision was made by a regulatory agency. So that just depends on the situation.” – Lesley Schafer, IIAR7Subcommittee Chair

Q: In IIAR-8, the standard mentions removal; what is the approach for removing contaminated oil?

A: “We do include provisions for removal. Basically, the standard, the way it is written, says ‘you need to figure out how to do this.’ A lot of the things in IIAR-8 have to do with what you have to do to dispose of chemicals. There are local and government requirements we have to follow. What’s included in the standard is what [you have to do], not how [you have to do it].” – Lesley Schafer, IIAR-8 Subcommittee Chair

Q: In IIAR-9, what is the timeframe to remedy a found gap?

A: “This is similar to risk ranking and your PHA’s. IIAR-9 provides you with a path to not close a gap. You can do a risk ranking, and if [there is sufficient justification], it allows you not to close [the gap].” – Eric Johnston, IIAR-9 Subcommittee Chair

Q: Please point me to a provision where IIAR-9 is more restrictive than IIAR-2 2014 or IIAR-2 2021.

A: “Right now, IIAR-9 requires that you have a cover over your vent switch in your machine room, and IIAR-2 does not require that. There are a lot [of examples]. One of the issues we run into is that IIAR-2 is constantly changing. IIAR-9 is always meant to be a minimum safety requirement; it shouldn’t have to change. When we originally developed IIAR-9, we looked all the way back to the early 90’s and chose the least restrictive things we could find.” – Mark Bazis, IIAR-2 Subcommittee Chair