IIAR Hazard Analysis

IIAR Warns that U.S. Ammonia Systems, Regardless of Size, Must Have Hazard Analysis per the General Duty Clause

The EPA has notified the IIAR that the agency is focusing on whether facilities using ammonia have conducted a hazard analysis.

In the U.S., while both the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) have strict safety requirements for operators using more than 10,000lbs (4,536kg) of ammonia (R717), there are still requirements that must be followed for smaller amounts of the chemical, the International Institute of Ammonia Refrigeration (IIAR) pointed out in a recent webinar.

In particular, section 112(r)(1) of the U.S. Clean Air Act, also known as the General Duty Clause (GDC), makes the owners and operators of facilities with regulated hazardous substances such as ammonia responsible for managing chemicals safely, “regardless of size or quantity,” said Tony Lundell, Senior Director of Standards and Safety for the IIAR at the May 17th webinar.

Recently, the EPA notified the IIAR that “one area of the agency’s focus is to determine whether facilities using hazardous chemicals have conducted a hazardous analysis,” Lundell said.

“We have verified an enforcement awareness of implemented EPA National Compliance Initiatives [NCI] that are effective 2020 through 2023,” said Lundell. NCI’s entitled “Reducing Risks of Accidental Releases at Industrial and Chemical Facilities” applies to anyone using ammonia.

In the notification to the IIAR, the EPA cited two applicable parts of the Clean Air Act Section 112(r), revised in 1990, to ammonia-based systems:

  • The Risk Management Program (RMP) for facilities using large quantities of identified hazardous substances, which in the case of ammonia is greater than 10,000lbs. (4,536kg).
  • GDC for facilities using any quantity of hazardous substances.

OSHA’s process safety management (PSM) program also requires strict safety measures for operators using more than 10,000lbs of ammonia. OSHA also has its own GDC clause, Section 5(a)(1) of the Occupational Safety and Health Act, requiring an employer to provide a workplace “free from recognized hazards that are causing or likely to cause death or serious physical harm to its employees.” This requires a hazard analysis for ammonia systems, said Lundell, adding that several states also have programs outlining a GDC that are identical to or refer to OSHA’s.

According to Lundell, the three bases of the GDC, especially for systems not regulated by EPA’s RMP, include:

  • Identifying chemical hazards and assessing the impact of possible releases;
  • Designing and building a safe facility to prevent accidental release of hazardous chemicals; and
  • Minimizing the consequences of an accidental release.

“If your facility does not have a hazardous analysis in place, we urge you to get this done soon,” said Lundell, advising end-users to contact their contractor to help meet GDC requirements. “If you are a contractor, consultant or equipment supplier for ammonia-based systems, we encourage you to notify end users, especially those with small facilities, concerning the [GDC] requirements of a hazardous analysis of the completed system.”

Potential violations

Lundell reported the following GDC violations seen by the IIAR in ammonia-based refrigeration systems that have caused exposure and damage resulting in investigations and fines:

  • No ammonia detector installed
  • The lack of tight-fitting doors with emergency egress push panels in machinery or equipment rooms
  • Piping damaged during maintenance
  • Systems not protected from facility traffic, including forklifts
  • No working emergency shower and eyewash accessible within 10 seconds or 55ft (16.8m)
  • A ceiling-hung evaporator or other equipment that fell
  • An over-iced evaporator vibrated a fan, cracking the hub and causing blades to damage the coil, resulting in a release
  • No hazardous analysis completed

When it comes to enforcement, Lundell indicated that if there is a hazard analysis violation and someone gets hurt, fines may be in the range of US$45,000 (€41,620). If there is no response from the system owner, fines will be charged per day, which can add up to hundreds of thousands of dollars.

Appropriate assessment techniques

“The appropriate hazard assessment techniques are based on size, uniqueness and complexity of the process [system],” said Lundell.

For a relatively uncomplicated system, asking what-if questions is an appropriate chemical hazard assessment technique, said Lundell, with a checklist approach for more complex ones. The “most widely used technique” combines what-if and checklist approaches. Other approved assessment techniques include a Hazard & Operability Study using guide words for direction, Failure Mode and Effects Analysis with a study of component failure and Fault Tree Analysis using qualitative and quantitative modeling or an equivalent method.

The IIAR offers guidelines and templates to meet GDC safety requirements based on system size with the Process Safety Management & Risk Management Program for systems with over 10,000lbs (4,536kg) of ammonia, the Ammonia Refrigeration Management for systems containing less than 10,000lbs (4,536kg) but more than 500lbs (227kg) and the Low Charge Ammonia Refrigeration Management for systems with less than 500lbs. (227kg).

In addition, Lundell is available to answer questions regarding GDC safety compliance at education@IIAR.org. Useful EPA documents include ECDIC-2000-011 and EPA 550-F-20-002 from April 2020, Lundell cited.

“The appropriate hazard assessment techniques are based on size, uniqueness and complexity of the process [system].”

Tony Lundell, Senior Director of Standards and Safety for the IIAR

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