One of my pet-peeves is CONTROLLING ACCESS to process battery limits. Even OSHA and EPA felt this was so critical that they actually mention it TWICE in their process safety standard/rule. They cover it in Operating Procedures for all company personnel and again in Contractors for those visiting the facility. But there is one group of “visitors” who MUST have access to your covered process battery limits at ALL TIMES. Most chemical processes are “open-air” design; however, most mechanical refrigeration processes in the food industry have an engine room/mechanical room that are REQUIRED to be secured by the industry RAGAGEP such as IIAR 2. So with the requirement in the RAGAGEP be that these rooms are secured, what happens when the local FD responds to an odor complaint and no one is on site? Are we required to provide access to the FD at all times? How many know what this contraption is?
In most states, this contraption is a “code requirement”. Specifically, those states that have adopted a revised version of the International Fire Code (IFC) and they have a Mechanical Refrigeration process where Ammonia is the refrigerant, this device is required by 605.5 Access…
SECTION 606 MECHANICAL REFRIGERATION
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605.5 Access
Refrigeration systems having a refrigerant circuit containing more than 220 pounds (100 kg) of Group A1 or 30 pounds (14 kg) of any other group refrigerant shall be accessible to the fire department at all times as required by the fire code official.
NOTE: Ammonia (R-717) is a B2L refrigerant, so a process that has just 30 pounds of ammonia will have to provide access to emergency responders 24/7/365.
We so often focus on keeping non-essential personnel out of our engine rooms that it is easy to forget how we will provide access to emergency responders during those times the site is unoccupied by refrigeration personnel. If your facility is “occupied” 24/7/365 by someone who can provide access to the engine room, then a Knoxbox may not be necessary, as the critical path here is to ensure responding personnel can gain access to the engine room if/when they need it.
But don’t be surprised if your Authority Having Jurisdiction (AHJ) requires the installation of a Knox Box just to be sure.