INDOOR ICE RINKS

Regulatory Requirements for Anhydrous Ammonia in Ice Rinks

Anhydrous ammonia poses significant safety risks and is subject to comprehensive federal and state regulations. Ice rink operators must comply with multiple regulatory frameworks to ensure safe handling and storage of this extremely hazardous substance.

Ice rinks with ammonia refrigeration systems must comply with OSHA’s 29 CFR 1910.111 standard for the storage and handling of anhydrous ammonia. Facilities with 10,000+ pounds of ammonia are subject to the Process Safety Management (PSM) standard, while smaller systems must meet the General Duty Clause, which requires a hazard-free workplace.

Most ice rinks fall under General Duty, and under OSHA, the requirements for the “General Duty Clause” (Section 5(a)(1) of the Occupational Safety and Health Act) mean employers must actively identify, assess, and control workplace hazards for compliance with a hazard-free workplace.

Industry Standards and Guidelines

Professional organizations provide essential safety standards that help EPA and facilities understand proper care requirements:

International Institute of Ammonia Refrigeration (IIAR): ANSI/IIAR Standard 2
American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE): ANSI/ASHRAE Standard 15

These standards, issued through the American National Standards Institute, cover safe installation, operation, and maintenance of ammonia refrigeration equipment.

Federal Environmental Regulations

Clean Air Act (CAA) Requirements

Under CAA Section 112(r)(1), known as the General Duty Clause, facility owners and operators must ensure the safe management of all extremely hazardous chemicals, including ammonia, handled or stored on-site.

Risk Management Plans (RMP): Ice rinks storing more than 10,000 pounds of ammonia must prepare and submit a comprehensive Risk Management Plan.

Emergency Planning and Community Right-to-Know Act (EPCRA)

Section 302 – Emergency Planning: Rinks must notify the state emergency response commission about the presence of extremely hazardous substances, including ammonia, as listed in 40 C.F.R. Part 355.

Section 312 – Annual Chemical Inventory: Facilities meeting certain thresholds must submit annual chemical inventory reports to:

State authorities
Local emergency planning committee
Fire department

For ice rink operators, developing a partnership with industry-experienced consultants is essential for navigating overlapping requirements and ensuring full compliance across all regulatory frameworks.

Contact HCG to schedule a consultation that meets your needs: