JAN/FEB 2026 RETA Breeze

of IIAR 9, Addendum A, which is repro duced on the right.

A.1.4 IIAR 9 Flow Chart

IIAR 9 Regulatory Basis

PURPOSE OF IIAR 9 Let’s delve a bit more into the provisions of IIAR 9. IIAR 9 was originally developed in 2018–2019 and was based upon the provisions found in IIAR 2 up through the 2014 edition. IIAR 9, Addendum A, pub lished in 2024, did not significantly change the technical provisions of the standard but merely clarified the due date for the gap analysis that we are discussing. IIAR 9’s provisions are no more stringent that IIAR 2-2014, and, in fact, may be less stringent, if a particular requirement is based upon an earlier edition. For instance, IIAR 2-2014 requires that ammonia leak alarms activate initially at no higher than 25 ppm, while IIAR 9 allows them to activate initially at no higher than 50 ppm, which was the allowable level prior to the 2014 edition based upon the Threshold Limit Value-Time weighted Average (TLV-TWA). So, what happens if a facility was designed and constructed to IIAR 2-2014, or even IIAR 2-2021? Because the require ments of these standards are equal to or more stringent than those in IIAR 9, the facility is under no obligation to adopt IIAR 9-2020 as RAGAGEP. Remember, as long as the RAGAGEP chosen addresses the hazards of the process in a suitable manner, the company is free to choose whatever RAGAGEP they deem fit. In fact, a facility that was designed and constructed to IIAR 2-2014, or even IIAR 2-2021, must have performed a gap analysis against whichever of those standards was used for the system design as part of their pre startup safety review (PSSR) when the system was commissioned. Wait, what? What in the world are you talking about, Bill? I’ll explain. As I stated earlier, both OSHA—in 29 CFR 1910.119(d)(3)(F)—and the EPA—in 40 CFR 68.65(d)(1)(vi)—require that a facility’s PSI include the design codes and standards that were used in the construction of the covered process. Therefore, the engineer of record for the new construction would have identified those codes and standards and designed the system to meet them. Jumping to the Pre-Startup Safety Review (PSSR), both OSHA—in 29 CFR 1910.119(d)(3)(F)—and the EPA—in 40 CFR

Is the original Code/ Standard provision more restrictive than Technical Provisions in IIAR 9?

Original Code/Standard remains Regulatory Basis except as specified in IIAR 9, Section 7.2.10 & Section 7.3.13.2

Do you know the original codes/standards that governed?

YES

YES

NO

NO

IIAR 9 Technical Provisions are the Regulatory Basis

technical design, operation, or mainte nance manual and should not be used as such.” So, as long as we have identified the applicable design codes and standards for our system, we are still under no obligation to adopt IIAR 9 despite it’s being “law” in some areas. This can be further argued by the fact that if a gap is identified between its provisions and the facility’s system, any changes made to bring it into compliance must meet the provisions of the edition of IIAR 2 that is adopted by reference by the AHJ in that location. IIAR 9-2020, Addendum A, set January 1, 2026 as the deadline for completing the gap analyses. Already, we see posts on social media saying, “You are out of compliance. Call us. We can help.” Just pay us money. If you haven’t done a gap analysis against the provisions of IIAR 9-2020 by now, before you sign that check, evaluate whether or not IIAR 9 is appropriate RAGAGEP for your facility. It may very well be, but there is also a chance that it is not.

68.65(d)(1)(vi)—state that the PSSR “ shall confirm that prior to the introduction of highly hazardous chemicals to a process: Construction and equipment is in accordance with design specifications. ”This means that the PSSR must ensure that the design and construction meet the requirements of the applicable codes and standards. In other words, a gap analysis must be performed. OLDER FACILITY CONSIDERATIONS What about a facility older than 2014? Can they choose not to adopt IIAR 9-2020? In reality, this applies even for those facilities that were designed against IIAR 2 editions, or even ASHRAE-15 editions that predate IIAR 2-2014. A facility can simply choose to adopt the current edition of IIAR 2 as their safe design standard. If they do so, they must perform a gap analysis between the original design standards and whatever the current edition of IIAR 2 is in order to meet the requirements of 40 CFR 68. 67(c)(10). Now, one might bring up the fact that the 2024 International Fire Code (IFC) adopts IIAR 9-2020 by reference, making it law. So, once an AHJ uses that edition of the IFC as the basis of their adopted fire code, IIAR 9 becomes law. So, we have to adopt it, right, Bill? This is a conundrum, because, on the surface, the answer is, yes, it is law. However, here is the truth. IIAR 9 is “NOT intended to serve as a comprehensive

Please feel free to email me with questions at NH3isB2L@gmail.com.

Bill Lape is Project Director for SCS Engineers. Bill is a Certified Assistant Refrigeration Operator, a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and is the current International President of RETA-RSES.

RETA.com 25

JANUARY/FEBRUARY 2026