Tony Lundell, CIRO, PMP
Senior Director of Standards and Safety
International Institute of Ammonia Refrigeration (IIAR)
Tony Lundell, CIRO, PMP, is the senior director of standards and safety at the International Institute of Ammonia Refrigeration (IIAR), Alexandria, Va. Tony has more than 40 years of experience in utilities and facilities engineering, operations, maintenance and management with companies such as Oscar Mayer Corp., Sara Lee Corp., Nestle and Americold Logistics. At IIAR, he facilitates and develops IIAR standards, provides refrigeration industry technical assistance, develops and enhances the organization’s PSM/RMP activities, and helps review and develop the Academy of Natural Refrigerants (ANR) educational program modules. He is a veteran presenter at industry-related conferences and webinars.
Enforcement Awareness: General Duty Clause Requirements for Ammonia Refrigeration
The United States EPA National Enforcement and Compliance Assurance Program implemented several national compliance initiatives (NCIs) effective for FY2020-2023. One of these NCIs is titled “Reducing Risks of Accidental Releases at Industrial and Chemical Facilities.” IIAR has received notice from the EPA and several end-users that their focus is determining whether facilities using hazardous chemicals have conducted a hazard analysis. The EPA is citing the Clean Air Act Section 112(r)(1), which establishes the regulations of the Risk Management Program for facilities using large quantities of a hazardous substance. EPA also is citing the General Duty Clause, which is also a part of CAA 112(r)(1) and applies to facilities using any quantity of hazardous substances. In addition to its process safety management (PSM) regulations, the U.S. Occupational Safety and Health Administration (OSHA) also enforces a general duty clause that requires a hazard analysis.
Objective 1: Discuss why a hazard or safety review is required and must be done for an ammonia refrigeration system, no matter what size it is.
Objective 2: Describe Section 5(a)(1) of the Occupational Safety and Health Act (the "General Duty Clause").
Objective 3: Discuss the U.S. Environmental Protection Agency (EPA) General Duty Clause (GDC).
Objective 4: Express OSHA’s Process Safety Management and EPA’s Risk Management Plan requirements for a process hazard analysis for systems with 10,000 lbs or more of ammonia in a refrigeration system.
Earn: 1 PDH; 1 RETA PDH; 1 AIA LU/Elective, 0.1 IACET CEU;
Process Heating & Cooling Show Speakers
Process Heating & Cooling Show Agenda