Chill - We Got This!
(Apologies for the late post – a scheduled post did not happen. These changes took place 3/8/24)
The Various ITPMR’s, the Walkthrough Form & SOP, etc. were all re-reviewed line-by-line to ensure closer compliance with IIAR 6. Many, many changes were made based on this review. A detailed changelog follows:
Tomorrow is Ammonia (7/17) Day!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century Swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
IIAR 9-2020 Addendum A (202x) First (1st) Public Review
Public Review Announcement
IIAR invites you to make comments for IIAR’s first (1st) public review of IIAR 9-2020 Addendum A (202x) Safety Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems.
Public Review Period: October 27th, 2023 through November 26th, 2023
Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on November 26th, 2023. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.
You can review the document and make your voice heard at this link.
CFATS Announcement
As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire.
Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. This means that CISA will not require facilities to report their chemicals of interest or submit any information in CSAT, perform inspections, or provide CFATS compliance assistance, amongst other activities. CISA can no longer require facilities to implement their CFATS Site Security Plan or CFATS Alternative Security Program.
CISA encourages facilities to maintain security measures. CISA’s voluntary ChemLock resources are available on the ChemLock webpages.
Today is Ammonia (7/17) Day!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century Swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
There are a lot of choices out there for fixed Ammonia Detection these days. Common brands include CTI, Manning / Honeywell, Danfoss, Bacharach, Draeger, Hansen, and CoolAir.
Obviously if you are installing a new detector in a General Duty or PSM/RMP covered process, you want to perform an equipment-level PSSR (pre-Startup Safety Review) for the detector. However, a common question we get is “does changing from one brand to another require an MOC?”
The root of this question is usually an attempt to justify the “change” as a “Replacement in Kind” and therefore avoid the paperwork of an MOC. But an MOC is not about PAPERWORK. An MOC is about thinking through the desired change (in a structured way) to see where problems can arise.
Put another way: Implementing the MOC procedure is how we answer the question of whether or not we need to document how we manage the change.
Let’s consider some things that might change when we replace one detector brand for another.
Sensor Type: Electrochemical, IR, Catalytic Bead, etc. Each of these types of sensors has benefits and drawbacks based on the conditions they are used for and in. If you are changing technologies, how does that change affect your process?
Sensor Range: Obviously the range of the sensor has an impact on how it works in your system. Replacing a 1-500ppm sensor with a 1-250ppm sensor without altering the system programming will report the wrong chemical concentration.
Signal Type / Range: Most sensor setups work on a 4-20mA signal, but some use Modbus or proprietary methods. You need to match your technologies or provide signal conversation.
Enclosure Rating / Environmental Considerations: Some sensors are subject to difficult environmental conditions such as blast-freezers and wash-down areas. You need to make sure that the sensor is suitable for the conditions you will expose it to.
Detector Placement: Manufacturer’s often provide recommendations on the height they want their detectors placed at. Make sure you are addressing those recommendations. If you are moving the Detector, are there any guarding considerations in the new location?
Inspections, Tests & Maintenance: Manufacturers have different inspections, tests and maintenance types and schedules. You must make sure you align to the manufacturers recommendations.
Bump Tests / Calibrations: Both the calibration method & frequency must be considered, including any unique calibration equipment and gases.
Conclusion: So, it’s possible that swapping a detector might well be a “Replacement in Kind” but there are a lot of things to consider before you arrive at that decision. You should use your MOC process to see if you need a formal, documented MOC.
The EPA has made a relatively small update to the process of submitting, updating, or correcting your RMP filing. The change is minor, but if not accounted for, it can slow down or stop your filing process.
What Changed?
It has always been a requirement for the Certifier (and Preparers) to have profiles established through the CDX portal, but the identity proofing and CDX Electronic Signature Agreement (ESA) components are new.
It’s possible that this identity proofing and signature agreement are already taken care of, but it would still be prudent to ensure your Certifier has met these requirements several weeks before your RMP submittal/update are due.
Who is Affected?
The Certifying Official for your process’s RMP filing is the only one affected. The EPA defines these people as:
“Certifiers are facility owners or operators who must certify the accuracy and completeness of the information reported in the RMP. They have signed and submitted a one-time Electronic Signature Agreement (ESA) to the EPA. The ESA legally binds the Certifier’s electronic submission to their signature. Only Certifiers can submit the RMP.”
This is usually a plant manager, owner, or some other member of upper management. In order to be respectful of their time, it would be good to let them work through these new requirements well before the filing is due.
If you believe that your Certifier has already met these requirements, here is what the EPA’s guidance suggests to verify:
”Some existing users may not be impacted if they previously completed identity proofing and signed a standard CDX ESA for another program service that uses the same CDX organization as their RMP*eSubmit Certifying Official role.
…
Existing Users who Registered Before February 24, 2023
Existing users who have not verified their identity or without a standard CDX ESA will be prompted to complete identity verification and ESA when they access the RMP*eSubmit for the first time. The one-time process can be initiated by logging into CDX and clicking on the “Certify Submission” role link. Users will be able to complete this process using one of the below methods:
Once the above electronic or paper process is complete, you will be able to access RMP*eSubmit.”
The EPA’s RMP eSubmit User Manual has more information, and detailed step-by-step instructions for any CDX portal or RMP filing questions you may have. (Link functional as of June, 2023)
As always, we will continue to track any changes we can find concerning Ammonia Refrigeration process safety. Any changes or updates will be posted here and accounted for in the OSPSM compliance templates. If you have questions or would like to find out more, please contact the RC&E Safety and Compliance team ([email protected]).
Looks like the Biden administration is going to continue the recent streak of attempting to change the EPA RMP rules that was started in the Obama administration.
On August 18, 2022, EPA Administrator Michael S. Regan signed the Safer Communities by Chemical Accident Prevention (SCCAP) rule, which proposes revisions to the Risk Management Program (RMP) to further protect vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The proposed rule would strengthen the existing program and includes new safeguards that have not been addressed in prior RMP rules. Some of the proposed requirements include identifying safer technologies and chemical alternatives, more thorough incident investigations, and third-party auditing, all of which should benefit nearby communities. When finalized, the rule is expected to make communities safer by reducing the frequency of chemical releases and their adverse effects.
The public may comment on the SCCAP proposed rule at www.regulations.govEXIT EPA WEBSITE (Docket ID No.: EPA-HQ-OLEM-2022-0174) until 60 days after publication in the Federal Register.
7/17 Day is this coming Sunday!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
Public Review Announcement
IIAR invites you to make comments for IIAR’s public review of IIAR 1-202x Definitions and Terminology Used in IIAR Standards and IIAR 3-202x Ammonia Refrigeration Valves.
Public Review Period: March 25, 2022 through May 9, 2022
Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on May 9, 2022. Substantive changes resulting from these public reviews will also be provided for comment in a future public review if necessary.
IIAR 1 is about definitions and may have some impact on those using the IIAR suite. IIAR 3 is about valves and is generally thought of as manufacturer-facing meaning it shouldn’t much affect you unless you are in the business of making refrigeration valves.
