As a charter member of IIAR, I can witness that it has taken a long time to get model codes (IMC) to recognize ANSI-IIAR 2 as a code for ammonia refrigeration. I can remember when Hank Saye and I worked out the 1” valve bypass arrangement, and how skillfully Jeff Shapiro planned that that would set the stage for eliminating the hazardous valve boxes and the retention tanks. For all that effort, regardless of what Jeff was paid, I think he should be promoted to sainthood. If there was room in the Congressional Rotunda for another statue – Florida has two, one of whom is John Gorrie – we could put Jeff beside Gorrie.
As a practicing engineer, I have seen the full gamut and would like to share my concerns going forward.
While the momentum of code recognition does wonders for one’s ego, it took 30+ years to get IIAR 2 to the point of recognition. While all of us want the best for the industry, we are often blinded by our own little world of focus. I know the initiative of making bulletins into codes is well on its way. Hopefully everyone is starting to see and be concerned as to how this will be interpreted by government regulatory agencies, namely OSHA and EPA and state environmental agencies. While I maintain and assist many clients in engineering, I am also called in as expert witness, particularly where injury and death have occurred.
One of the primary concerns I have is not just the interpretation of ill-conceived bulletins, and now what could become codes, but also the misinterpretation of many of our “required” (“shall”) and not required (“should”) procedures. I was riding in a taxi to the annual IIAR meeting with one of the members who is in charge of eleven poultry plants. He had concerns regarding recent fines by EPA at one of his facilities for not testing the high pressure cutout valve for a compressor by closing the discharge valve. If he cannot get the fines rescinded, of course he faces the possibility of “double jeopardy” and willful violations. Whoever wrote this in our manuals obviously hasn’t stood by an old compressor, possibly a horizontal one, and closed the discharge, not knowing whether the high pressure cutout would even work, let alone the compressor come apart in front of him. In some of the old plants, closing the suction valve was a fine art used to prevent floodbacks. I was called in on one where the individual didn’t get it closed soon enough and was left blind the rest of his life. There are so many ambiguities in our well-meaning bulletins, and now-to-be codes, that if some specific clarification bulletins on these ill-conceived procedures are not created, EPA and OSHA won’t have to worry about being funded, the refrigeration industry will do it for them!
Ironically, a closed refrigeration system, by any standard, is not defined as a process; there are no chemical changes, and yet government agencies want to try and treat it like a process. Somewhere and throughout out bulletins and codes we need to convey this to these agencies. Many of the inspectors came straight from chemical plants, and next thing you know they want to use API, etc.; even some of our “technical members” want to throw API calculations into relief valve vent lines. We need to make it very clear that closed systems are not chemical processes. These agencies have to have materials sufficient to teach them the difference. They will always have new people, and our bulletins and codes are the only textbooks they have for reference.
So, having said all that, I am now questioning the wisdom of trying to make bulletins into codes in a three-year period, whereas it took 30 years to get IIAR 2 into a form that would be considered presentable (which, of course, there are some portions I still do not agree with). As I see it, we should have workshops where all the dreamers who think these bulletins should be codes can be the end users, and others can be OSHA and EPA agents levying fines for discrepancies between “perceived industry standards” or verbatim per some of our bulletins and now-to-be codes. In a very simplistic way, as a charter member, we saved ourselves from National Electric, and now we have decided to shoot ourselves in the foot. We need to spend more time developing what we would expect to be used for passing judgment on an ammonia refrigeration system. RR
To read the rest of the articles from the Spring 2015 Refrigeration Review, click the links below.