The IIAR has just announced a Public Review of their IIAR 2 standard. IIAR 2 is the “Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems” so it’s worth reviewing. 

September 11, 2020
To:	IIAR Members
Re:	Second (2nd) Public Review of Standard BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems.
A second (2nd) public review of draft standard BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary. BSR/IIAR 2-202x specifies the minimum safety criteria for design of closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of ammonia refrigerating system(s) and basic ammonia refrigerating practices and principles. This standard is intended for those who develop, define, implement and/or review the design of ammonia refrigeration systems. This standard shall apply only to closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes) where provisions in these may take precedence. IIAR has designated the revised standard as BSR/IIAR 2-202x. Upon approval by the ANSI Board of Standards Review, the standard will receive a different name that reflects this approval date. We invite you to participate in the second (2nd) public review of BSR/IIAR 2-202x. IIAR will use the American National Standards Institute (ANSI) procedures to develop evidence of consensus among affected parties. ANSI’s role in the revision process is to establish and enforce standards of openness, balance, due process and harmonization with other American and International Standards. IIAR is the ANSI-accredited standards developer for BSR/IIAR 2-202x, and is responsible for the technical content of the standard. This site includes links to the following attachments: Background information on BSR/IIAR 2-202x, Public Review Announcement, Public Review Draft, On-line Comment Form for BSR/IIAR 2-202x The 45-day public review period will be from September 11, 2020 to October 26th, 2020. Comments are due no later than October 26th, 2020. Thank you for your interest in the public review of BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems.

Make your voices heard and comment to the IIAR! 

Below is a quick review of the significant suggested changes and my thoughts on them. 

1.3.3) Now requires “alternative means and methods” to be approved by a designed that is a licenced engineering professional. – This was common practice and helps you build a defensible case. 

2) Definitions. Added a definition of car-seal. I’m happy the IIAR has finally acknowledged this industry practice!

3.3) Moved a reference to IIAR 7 on SOPs to the Informative appendix. Not sure this matters much as IIAR 2 still refers to IIAR 6 which references IIAR 7. 

5.5.3) Saturation Pressures and Minimum Design Pressure. – They seem to have fixed the weird situation where your calculated low-side pressure could be higher than your minimum high-side pressure. 

5.8) Clarified that purging piping shall be compatible with NH3. This was requirement always in there, you just had to bounce around the standard to find it. 

5.11.4) Seems to add a new explicit requirement to document “the basis for the support design including the anticipated loads, demonstration that the support design is adequate for the anticipated loads, and that the supports meet or exceed the equipment manufacturer’s recommendations”

5.12.4.2) Clarifies that accessibility to “isolation valves identified as being part of the system emergency shutdown procedure” must be provided for people in emergency response PPE. 

5.14) Removed wind indicators as being required by IIAR 2

5.14.1) System signage requirements to reference “maximum intended inventory”, remove the quantity of oil requirement, and replace test pressures with design pressures. – That “maximum intended inventory” is going to cause a ton of confusion when the sign says the “maximum intended inventory” is 20,000lbs but the actual inventory documentation shows 17,500lbs. 

5.14.3) Changes the requirement for Emergency Shutoff Valve Identification from “uniquely identified” (which you could meet with valve tags) to “uniquely identified as emergency shutoff valves” both on the valves themselves and on the system drawings. This is going to be a major change for most people. I don’t think this change is worth the trouble it will cause. 

6.10.2) New requirement that “Machinery room doors shall open with the use of only the panic hardware and shall not require the use of other hardware or switches to exit the room.” which was a pet-peeve of mine. 

6.12.1) Requires the E-stop to be “manually reset” 

6.12.2) Removes the “protected from inadvertent operation” requirement for ventilation switches

6.13) Essentially this section strongly advocates for 2 NH3 detectors in the machinery room but does provide provisions for only 1.

6.13.2.3) Now requires audible alarms to be “manually reset by a switch located in the machinery room or alternatively in an area remote from the machinery room.” – This will be a significant control change for most people.

6.14.7.6) New language “A means of proving emergency airflow shall be provided. Failure to prove airflow when the emergency ventilation fans are energized shall provide notice to a monitored location. Devices that can be used to prove emergency airflow include, but are not limited to: 1) pressure differential switches 2) sail switches 3) current monitors. ” – This reflects what most people are doing anyway. 

7.2.5) Stronger language: “Protection of Equipment from Physical Damage. Where ammonia equipment is installed in a location subject to physical damage from powered vehicles normally operating in the area, guarding or barricading shall be provided.”

15.1.2) Allows car-seals downstream of relief valves that relieve internal to the system. – This has been the practice for years, so it’s nice that the IIAR has finally acknowledged it. 

15.2.5) Removes the exception “The vapor relief connection on an oil drain pot and similar applications shall be located at the highest point on the vessel.”

15.2.6) New requirement “Pressure relief devices intended for liquid pressure relief shall be connected below the anticipated liquid ammonia level and shall discharge internal to the system. “

15.2.9.1) New language “The employee of that device manufacturer or company holding a certification who last set and calibrated the pressure relief device shall seal the valve with a car seal.” – Calling it a car-seal is going to cause a ton of confusion here. This language should revert to the old language as just being sealed. 

15.4.6) Stronger language added here “Liquids and other refrigerants shall not be vented into a common relief piping system used to convey ammonia vapor.”

15.5) They changed the formulas for relief discharge piping. According to our engineering department, it’s mostly semantics and not substantive.

15.6.4) I believe this new wording just states what was already required by other codes/standards “15.6.4 Liquid Overpressure Protection required. Relief valves used for liquid pressure protection of vessels and equipment constructed in accordance with the ASME B&PV code are required to be constructed and marked in accordance with the ASME B&PV Code.”

15.6.6) New section on “Pressure Vessels and Equipment with Non-Volatile Liquid” which we are taking to mean Oil Pots and the like. This allows isolation of the relief protection during pump-down. Again, this has been the practice for years, so it’s nice that the IIAR has finally acknowledged it. 

17.2.1) Power supply section reworded to no longer require separate power circuit for the NH3 detection. 

17.3) Adds two new RAGAGEPs for NH3 detection design and testing “UL-61010-1 Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use or ANSI/ISA 92.00.01 Performance requirements for Toxic Gas Detectors.” I’ve reached out to my NH3 detector contacts and will follow-up with a separate post on the implications of these requirements. 

17.7.1) Level 1 detection requirements revert to pre-PR1 

The IIAR announced that two standards are up for their second public review. IIAR 4 Installation of Closed-Circuit Ammonia Refrigeration Systems and IIAR 8 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems. 

My IIAR 4 2020 PR2 Comments and Notes

1.3.4 Installations without an AHJ

This section appears to be rewritten for clarity, but it also removes the requirements that “alternative shall be documented in the design documents and provided to the owner and the installer.” This will definitely become a problem down the road when end-users are asked to justify their apparent non-compliance without adequate documentation of the designers engineering rationale.

4.2 Supervisor of Installation (Installer Qualifications)

This section has been revised and adds a requirement that Installing Contractors provide documentation to the facility that they have the skills necessary to:

• • Receive, transport, and install refrigeration equipment, piping, and components.
  • Assemble a refrigeration system.
  • Not harm themselves, others, or damage the structure in which the equipment is to be installed

I imagine this will be handled by some sort of “Letter to File” from the contractor.

4.5 Welding of Pressure Containing Components (Repeated in 4.6)

This change requires the contractor to provide the Welding Performance Qualification Record (WPQRs) for the past six months rather than the previous requirement that they just verify the welder’s credentials were not expired. This is going to be challenge to contractors. End-users should aggressively soliciit this information if they expect it in a timely fashion.

4.8.6 now explicitly requires that insulated pipe be spaced to allow access for inspections / maintenance. This was always a good idea.

4.9.1 now requires complete thread engagement rather than “3 exposed threads”

6.2.1 removes “reasonably free of rust” and replaces it with “free of pitting.” Internally, you should probably stick with the old requirement.

6.3.5 no longer allows valves connecting to atmosphere to be “locked closed” as they must now be capped, plugged or blind flanged. I don’t know of anyone that allowed a valve open to atmosphere to be locked closed without a plug / cap so this isn’t much of a change in the field.

IIAR 4 Links

• • Background information on BSR/IIAR 4-202x,
  • Public Review Announcement,
  • Public Review Draft,
  • On-line Comment Form for BSR/IIAR 4-202x

My IIAR 8 2020 PR2 Comments and Notes

Note: Please keep in mind that, according to IIAR 1, decommissioning is “The permanent deactivation of a closed-circuit refrigeration system or part thereof.”

4.6 Documentation

This section moved the suggested methods to the appendix where they belong. Well-implemented PSM programs will likely handle all this documentation as a matter-of-course through their existing MOC, PSSR & PHA policies.

4.10 Operating Procedures

This change ONLY affects procedures for decontamination, but it removes the requirement that such procedures comply with IIAR 7. Those procedures would still likely be judged under 1910.119(f). Whenever there is some grey area as to whether a procedure falls under 1910.119(f)(1-4) or 1910.119(j) it’s always wise to link back both. My preferred language is something along the lines of “This procedure must be used in conjunction with the equipment SOP which provides Important Safety, Health, Environmental and Equipment Considerations as well as Controls, Instrumentation, Safety Systems, Valve Designations, Operating Limits, Consequences of Deviation, Steps Required to Correct or Avoid Deviation and an Emergency Shutdown procedure.”

4.12.2 Training Records

They’ve reworded this section to require a “sign off sheet” to document that people “received” the training rather than using the PSM/RMP language that you document the “means used to verify” that they “understood” the training. IIAR 8 doesn’t over-ride the existing PSM/RMP requirements, so this has little impact.

5.2.3.3 removes the prohibition on “fuel burning appliances” and provides some bromides about conducting such work “safely.” Our template program will continue to prohibit this. While there are obviously situations – especially during decommissioning activities – that may warrant their use, we want to ensure that such activities are run through an MOC (or similar administrative control) before their use.

5.3.1.1 changes the requirement that you track chemicals to their ultimate disposal to one that you document that they’ve left the facility. This is sensible and welcome.

IIAR 8 links

• • Background information on BSR/IIAR 8-202x,
  • Public Review Announcement,
  • Public Review Draft,
  • On-line Comment Form for BSR/IIAR 8-202x

If you have comments on the IIAR’s suggested changes, don’t forget to hit up the comment links above.

Nearly 3 years ago we posted an answer to the question “What training does my refrigeration operator need?”

In our experience, to get a good understanding of the Overview of ammonia refrigeration – the fundamentals of how it works – facility provided one-on-one hands-on training is the most effective training approach. This is the approach used for the vast majority of the skilled trades and it is proven effective. Unfortunately, if you don’t already have in-house expertise, there’s nobody to provide the training! A facility lacking on-site talent to act as trainers is when 3^rd party providers can provide some value.

We’ve been getting a lot of questions lately centered around getting the best “bang for your buck” when using outside training providers. This post is solely about operator training. That is, the training we need to provide for our refrigeration operators that can be done by outside training providers – Process Safety training will be addressed briefly at the end.

If you don’t already understand that the training these providers offer is usually only going to address a small portion of the overall PSM training requirements, please read “What training does my refrigeration operator need?” before proceeding. I’ll reinforce a key point from that post though: The standard classes offered by most ammonia “schools,” even if they are done properly, only address a portion of the training burden – a small piece of the Overview of the Process requirement. You cannot send your personnel off to some 4-day class and get a qualified operator in return. (Buying a laminating machine doesn’t give you any authority to certify operators, but that’s another post. If you want credentials that matter, go to RETA)

We’re going to answer this question in three parts:

• What kinds of programs are there?
• What are the benefits and drawbacks of each training approach?
• What training approach do we recommend?

What kinds of programs are there?

Broadly speaking, the available options break down into three groups:

1. Self-directed
2. Instructor based ON-site
3. Instructor based OFF-site

Self-directed: You give your employee access to refrigeration books (such as the excellent RETA series) and they teach themselves the topic. You might also supplement this with online training which provides feedback and automated testing such as the RETA online training.

Instructor based On-site: Various training providers offer classes taught by an instructor at your facility.  These classes usually run 8-10 hours a day for 3-5 days.  With your approval, the class can use your refrigeration system for any illustration or “hands-on” purposes. If you have enough students, you can make these classes private – meaning only students from your company attend. This allows you to customize the content to reflect your policies. It also allows you to be a little more open about your practices and shortcomings in class discussions.

Instructor based Off-site: Various training providers offer classes taught by an instructor at the training companies “school.” These classes usually run 8-10 hours a day for 3-5 days.  Some of these training providers have built small refrigeration systems (“labs”) that they use to illustrate concepts during “hands-on” sessions. Like the on-site classes, if you have enough students, you can make these classes private.

What are the benefits and drawbacks of each training approach?

What training approach do we recommend?

Unless your operators are natural autodidacts (PSM people often prefer learning out of books, for example) self-directed training is not a good fit for most operators. For most organizations, your best bet is instructor-based learning.

As with any training, the more relevant you can make it to your day-to-day operations, the more effective it will be. When you don’t have the on-site expertise to provide training, we think Instructor based ON-site training is the best choice for most organizations. It tends to be more focused on your equipment, procedures & policies and it is more cost effective than off-site training.

One last note: Be extremely mindful of your selection of a 3^rd party provider for ANY training, because the instructor’s attitude and knowledge may well affect your safety culture.

PSM-ONLY Note: if you are looking for PSM training – training on how to be a PSM coordinator, or simply to better understand Process Safety systems – then we’d recommend the same as for operator training. But, most organizations don’t have someone sufficiently skilled to provide one-on-one training, so we’re left to seek a 3^rd party. Unfortunately, most facilities don’t have enough people for a full class either, so you either need to combine with other facilities in your company (which allows you to have customized training on your policies & procedures) or combine with other organizations to get enough people for an in-house class. Because this is difficult to do, the Instructor based OFF-site option becomes the only one available. While we don’t provide Operator Training, we do offer PSM training.

Bonus editorial content: How important is “hands-on” training?

For the purposes of these classes, it is my opinion that the “hands-on” portion of these classes, as it is usually provided, is of little to no value. WHAT!? Allow me to explain:

• Learning Styles: “But my operators all claim to prefer a ‘hands-on’ learning style!” or “Our operating staff are tactile learners” you say. The idea of learning styles is most likely a “neuromythology” – a popular idea that endures despite having little evidence to support it. In any case, these classes usually don’t really let them “operate” the system in any meaningful way so the “benefit” of “tactile” learning due to “hand-on” training is minimal…
• “Hands-On”: I used to be an instructor in an organization that provided a lot of classes in the on-site and off-site instructor-based model. The organization provided a lab with “live” ammonia refrigeration systems. Typically, the students spent about a third of their time in this lab, in a group setting. In my opinion, this lab time had very little value for most students. Again, these classes usually don’t really let them “operate” the system in any meaningful way so they are just turning a few valves and conducting exercises in locating valves on PIDs. Certainly, you can manage that level of “hands-on” training at your facility! (I’m sure you can understand why: the liability in letting students operate equipment is HUGE.)

Furthermore, this lab equipment is not the same equipment in your facility, and I can assure you (unless you are woefully non-compliant with General Duty, General Industry standards and PSM/RMP) that their procedures & policies are not YOUR facilities procedures & policies. Most of the benefit that can be gained from “hands-on” training should be done at YOUR facility with YOUR equipment using YOUR procedures and policies. This is how and where the vast majority of your training should actually happen.