I was recently asked by a news journalist what questions I would ask EPA if I had the opportunity. Not to steal their thunder, but this is what I would ask.
Why are closed cycle refrigeration systems regulated under OSHA? Just because ammonia is a refrigerant does not make the refrigeration cycle a process by any chemical definition. The refrigerant does not change chemically in any way as it circulates inside the system. The type of concerns for safety in the PSM program are intended for a chemical process, i.e. Upset conditions, energy balance, etc. Ammonia has a very good safety record compared to other chemicals. The incident rate from refrigeration systems is way below incidents from other chemicals such as natural gases, which, if anything, should be a process because when it is burned and used for heating it is a process where the chemical is changed.
The next question is why is there so much concern about ammonia in our environment? Tons of ammonia is produced by lightening each year, and all forms of life contain it. It is a root chemical in our plant and animal structure. Farmers inject it directly in the ground as the “cleanest” fertilizer possible. It has no run-off side-effects, etc. It is truly green. RR
To read the rest of the articles from the Spring 2015 Refrigeration Review, click the links below.
- The Noble Condenser
- IIAR 2 or ASHRAE 15
- Machinery Room Ventilation
- Comments to CSB Regarding the Safety Bulletin
- Questions for EPA
- Critical Flow