When the Building Burns: Planning Beyond the Machinery Room | Blog No. 145

Five Emergency Planning Lessons from Recent Ammonia Refrigeration Facility Fires

A fire in an ammonia refrigeration facility creates challenges that extend well beyond extinguishment. Fires can damage structures, interrupt utilities, block access to controls, and compromise refrigeration equipment. These scenarios should be evaluated during applicable Process Hazard Analyses (PHAs) and addressed through preparedness efforts before an incident occurs.

Recent incidents in Oregon, California, and Ohio provide useful reminders of why these scenarios deserve attention. While these events involved ammonia refrigeration systems, they do not establish ammonia as the cause of the fires or the source of every reported hazard. They do, however, highlight the importance of preparing for conditions that can complicate emergency response.

My perspective comes from more than 30 years operating ammonia refrigeration systems, serving as a Process Safety Management (PSM) coordinator, and supporting industry clients, along with more than 26 years in hazardous materials response training, fire prevention, and confined space entry programs. That experience has reinforced a simple lesson: emergency procedures must remain workable when portions of a facility become inaccessible.

Lessons from Three Facility Fires

Newport, Oregon

According to Oregon Public Broadcasting, a fire at Pacific Seafood in Newport prompted evacuations because of concerns about the facility's ammonia refrigeration system. The Newport incident highlights a common challenge during refrigeration-facility fires: protective actions may be required before responders have fully assessed the condition of the ammonia system. Planning should account for those early decisions when information is incomplete.

For facility operators, the challenge is determining how quickly responders can identify ammonia inventories, understand system vulnerabilities, and evaluate which equipment could be affected by fire, utility failures, or structural collapse.

Los Angeles, California

The Lineage warehouse fire in Boyle Heights generated significant public discussion regarding possible ammonia releases during the response. Reporting by LAist and Capital & Main highlighted differences between dispatch records, monitoring activities, and subsequent public statements.

For operators and responders, uncertainty about monitoring data can be almost as challenging as uncertainty about the condition of the refrigeration system itself. Regardless of the ultimate findings, the event demonstrates the importance of clear communication during an emergency. Public confidence depends on understanding what was measured, where samples were collected, when measurements were taken, and what uncertainties remain.

Public communications are most effective when monitoring methods, sample locations, timing, and data limitations are clearly explained. Conclusions regarding community exposure should be supported by available monitoring data and communicated with appropriate context.

Fairfield, Ohio

A fire at Koch Foods resulted in a worker fatality and prompted a shelter-in-place order because of concerns involving the facility's ammonia refrigeration system. Subsequent OSHA citations focused in part on emergency action plan deficiencies, including employee instruction related to evacuation procedures and assembly locations following plan revisions.

While citations do not determine the cause of a fire or establish that ammonia contributed to a fatality, the employee-preparation issue is clear: changes to evacuation procedures and assembly locations must be communicated to affected employees on every shift.

The incidents in Newport, Los Angeles, and Fairfield involved different circumstances, outcomes, and unanswered questions. What they share is that each highlights conditions that can complicate emergency response: incomplete information, restricted access, potential system damage, evacuation decisions, and public communication challenges.

These are not merely emergency response concerns. They are hazards and response limitations that should be evaluated during applicable PHAs and addressed through emergency planning.

Five Process Safety and Emergency Planning Priorities

1. Evaluate Building Fires During the PHA

Fire is often viewed as a separate emergency from a refrigeration-system release. In reality, a building fire can create process-safety consequences that should be evaluated during applicable PHAs.

These evaluations should consider impacts to refrigeration equipment, utilities, structural components, alarm systems, communications, relief systems, and access to emergency controls.

Facilities should assess whether roof collapse, falling debris, loss of power, or damaged piping could defeat safeguards or limit emergency response options. Emergency plans are most effective when they are built from scenarios already examined during the PHA process.

2. Verify Relief System Performance Under Fire Conditions

Depending on equipment design and fire exposure conditions, elevated temperatures can increase system pressures and activate relief devices. Facilities should have a qualified refrigeration professional verify the system's design basis, discharge locations, and expected performance under credible fire scenarios.

Emergency plans should clearly explain the hazards associated with installed relief arrangements and identify how those hazards will be evaluated during an incident. An intact vessel does not necessarily eliminate the possibility of a release elsewhere in the system, and determining whether a release originated from relief-valve operation requires incident-specific evidence.

Understanding how the system is expected to respond during a fire helps operators and responders make decisions based on system design rather than assumptions.

3. Verify Safe Access to Shutdown and Isolation Controls

Emergency shutdown procedures are only useful if qualified personnel can safely reach and operate the required controls.

Site drawings should identify isolation valves, emergency shutdown devices, vessel inventories, relief discharge locations, and access routes. Facilities should evaluate whether designated controls remain accessible during a fire, structural failure, or power outage.

No emergency procedure should depend on personnel entering an unsafe machinery room or fire-damaged area to complete a shutdown. Emergency shutdown does not eliminate the need to evaluate remaining ammonia inventories and pressure hazards.

4. Validate Procedures Through Exercises

Identifying hazards during a PHA is only part of the process. Facilities must verify that employees and responders can execute their responsibilities under realistic emergency conditions.

For facilities subject to EPA Risk Management Program requirements, emergency response coordination, notification, and exercise obligations may apply depending on the facility's classification and emergency response status.

Beyond regulatory requirements, facilities should conduct tabletop exercises that simulate conditions such as blocked access routes, damaged refrigeration equipment, or loss of utilities. The objective is to identify gaps before an actual emergency occurs.

5. Prepare Reporting and Public Communication in Advance

Even the best technical response can be undermined by poor communication. The time to develop communication procedures is before an incident occurs.

Facilities should establish notification responsibilities, identify reporting thresholds, designate spokespersons, and develop procedures for communicating monitoring results. When sharing data, include sampling locations, timing, measurement units, averaging periods when applicable, and the basis for any health-related comparisons.

Transparency is especially important when information changes during an incident. Clear explanations of what is known, what remains uncertain, and what actions are being taken help maintain credibility with employees, responders, regulators, and the community.

Regulatory Considerations

Regulations and industry standards continue to evolve. Facilities should periodically review applicable OSHA, EPA, IIAR, state, and local requirements to ensure process safety and preparedness programs remain current.

Facilities below federal ammonia thresholds should not assume they are free of responsibilities. General duty obligations, emergency planning requirements, and state or local regulations may still apply.

A 30-Day Fire Readiness Check

• Review the PHA for credible building-fire and structural-collapse scenarios affecting ammonia equipment.

• Verify safe access to emergency shutdown and isolation controls.

• Update site maps, ammonia inventories, responder contact information, relief discharge locations, and isolation point documentation.

• Walk the facility with local responders and discuss fire-related ammonia hazards.

• Conduct a tabletop exercise involving operations personnel and emergency responders.

• Confirm employees on every shift understand evacuation, accountability, and assembly procedures.

• Review release reporting, incident notification, and public communication responsibilities.

  
  

Conclusion

Building fires affecting ammonia refrigeration systems are credible process hazards, not simply emergency-response events. Facilities that perform best during these incidents are often those that have already evaluated the hazards during the PHA process, incorporated the findings into preparedness and response programs, and validated their assumptions through training and exercises before the alarm sounds.

Macha PSM can help organizations evaluate fire-related ammonia hazards, review PHAs, and strengthen emergency planning programs.

Previous Blog: Opportunity in Ammonia Refrigeration: Own Your System, Own Your Future | Blog No. 144

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For comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com. For comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com.