RETA Breeze Sept/Oct 2025

Vol. 3b GROWING UP “COMPLIANT”

By Sarah Selzer, CARO

In Part 1 of this third volume on compliance, Sarah Selzer addressed the vital importance of having a Process Safety Management (PSM), Risk Management Program (RMP), and the value of process chemistry, block flow diagrams and materials of construction (MOC). Part 1 was published in the 2025 July/August RETA Breeze . Here, Selzer describes the importance of design code standards, safety systems, data reports and on how to remain up-to-speed on IIAR-4 and IIAR-9.

Design Codes and Standards Em ployed— many facilities approach it in different ways. Some facilities list the design codes by project for every project ever done at the facility. This means every MOC would require updates to the design codes and standards. Other facilities use general statements like, “The facility was constructed utilizing codes and standards in use at the time of construction.” So, what is the best solution? I like the approach of having a set of design codes for the facility. These codes are in use through a set time period. Every time the codes change, you can update the standard. Then, you can prove what design codes and standards were employed by comparing the MOC initiation date with the history of his design codes and standards. This cuts down on the number of updates and provides a good list that can be given to contractors bidding on projects. Material and Energy Balances for Processes Built after May 26, 1992— many people believe that just because a building was constructed prior to 1992, they don’t need a material and energy balance. Some inspectors may agree. Some inspectors will argue that if the facility has

first is the SOP outlining the operation of the engine room ventilation system. The second is an SOP on the operation of the ammonia detection system(s). The third, which may be the most important, is the overall refrigeration SOP. Per ANSI/IIAR-9: The following equipment documentation and system component documentation shall be obtained and on-file at the facility. Manufacturer Data Report(s) Compressor oil separator Compressor oil cooler (if applicable) Condenser (if applicable) Pressure Vessel Heat Exchanger (if applicable)

undergone substantial changes, a material and energy balance is required. I approach it from a practical side. Does the material and energy balance provide useful information? If so, I think I need one. Sometimes, these are referred to as a load balance. Load balances are a great troubleshooting and design tool. The load balance is what tells us if we have enough compression or condensing for an evaporator expansion, as an example. I think this is an extremely useful tool and well with the effort to develop and maintain. Safety Systems (e.g., interlocks, detection, or suppression systems)— these are normally included in the program as part of the standard operating procedures (Technical Operating Specifi cations [SOP/TOS]). They are very important. These safety systems give the operators information on what the safeties are and how they work. This can be extremely beneficial in troubleshoot ing. What about the safety systems that do not apply to a SOP/TOS? Well, in my opinion, that is a sign that you don’t have enough SOPs (I know, don’t come for me). I find several SOPs missing on a regular basis. The

Materials of Construction Compressor

Condenser Evaporator Auto Purger Ammonia Refrigerant Pump Heat Exchanger

Manufacturer Documentation for System Components Valves Instrumentation Controls

16 RETA.com

SEPTEMBER/OCTOBER 2025