Safety Standards for Refrigeration

Online comments: 3

• Daniel Bersohn

  The exception to 7011-01 (h)(3) and (5) are not workable. It is not possible to perform ASHRAE 15 9.13 testing on the outer pipe or duct of a pipe in pipe or pipe in duct enclosure that is “gas tight”. The intent of the language is clear: that any leaks in the enclosure go to other spaces that can manage the leak rather than the space through which the enclosure passes. The language should just state the intent directly to clarify the intent of “gas tight” as it relates to these exception and not require what is impossible testing of secondary enclosures to sec 9.13 of ASHRAE 15.

  I would rewrite (h)(3) exception as follows “If such piping is enclosed in construction that is 2-hour fire rated and is constructed such that refrigerant leaking from pipes within the enclosure will not leak into the space to be excluded from the calculation.”

  For similar reasons I would rewrite (h)(5) exceptions as follows “Refrigerant piping for Group A1 and A2L systems may be installed in public corridors if such refrigerant piping and fittings are enclosed in continuous pipe-in-pipe construction and a 2-hour fire rating such that refrigerant leaking from refrigerant pipes within the enclosure will not leak out of the secondary pipe into the public corridor.”

  It appears the difference between the (h)(3) and (5) exceptions are limited to a prescription of pipe-in-pipe construction for systems crossing a public corridor. Similar levels of safety would be achieved by using my proposed (h)(3) language in both places and allow for innovations in refrigerant linesets with prefabricated enclosures to divert leaks away from non-served, too small spaces.

  Generally, the regulations reference only A2L and remain silent on A2, A3, B2L, B2, and B3 refrigerants. To the extent that A2L-specific regulations (specifically around fire alarm integration) reflect a higher level of stringency or construction expense than other more dangerous refrigerants, either these requirements should apply to the more dangerous refrigerants or the less stringent requirements should apply to A2L. Language clearly resolving these conflicts should be included in the rule. This will ensure A2L systems are not unfairly burdened or necessary safety improvements are not withheld from more dangerous systems.

  I am a member of the last two cycles of the New York City Mechanical Code Committee and offer the following commentary with the weight of my experience in regulatory development and mechanical engineering expertise but these views are expressed solely on my behalf. These comments also do not reflect the views of any current or former employer or any other civic or professional organizations I am affiliated with.

  Comment added December 18, 2025 11:59am

• New York Coalition of Code Consultants (NYCCC) Codes Committee

  New York City Department of Buildings
  Office of the General Counsel
  280 Broadway, 7th Floor
  New York, NY 10007

  RE: NYCCC Comments on Proposed Refrigeration Rules

  To Whom It May Concern:

  The New York Coalition of Code Consultants (NYCCC) has reviewed the Department of Buildings (DOB) proposed rules to add new sections 711-01, 7015-02 and 7015-03 to Chapter 7000 of Title 1 of the Rules of the City of New York regarding refrigeration systems.

  As you may know, NYCCC is a non-profit membership trade organization and our members specialize in securing construction and development approvals from municipal agencies, as well as providing building code and zoning consulting. We provide expertise to real estate owners, developers, architects, and engineers; and our mission is to provide a unified voice of advocacy for the industry. We appreciate the opportunity to provide comments on the proposed rules, as we are in the trenches on a daily basis and will see first-hand how these rules will be implemented in practice.

  Over all the proposed rules are a big win for the industry. They create a pathway forward for design engineers and professionals. Once implemented, they will do much to alleviate uncertainty and help move New York City forward.

  That said, we believe the proposed rules can be modified to provide greater clarity; and request that the following be considered.

  1) We request that the exception under (h)(3) and (5) that A2L lines must run in 2hr rated conduit / enclosures be made clearer. This is already provided under circumstances such as fuel oil and leak detectors.

  2) It appears that under 15-2022 these detectors are also required in “occupied spaces”. We request that it be made clearer the extent of the sensor network to be provided in the local rule. It appears that apart from integral refrigerant detection systems, which seem specific to the system, detectors may only be required at the fan unit/coil and machine rooms.
  a. We request a clear exception for packaged units that meet standard. The industry preparing and providing the volume calculations for Effective Dispersal Volume Charge for R-2 would be difficult to provide. Additionally, the R-2 packaged units have audible alarm with visual display/indicator light and is a recommended way around the fire alarm annunciation.

  3) General comment: if 15-2022 is made applicable to R-2 by local rule and 15.2-2022 is excluded, then it would be an additional financial hardship to comply with these requirements especially for packaged systems. The idea is to reduce GHG emissions, and LL 994/2025 will apparently require owners to provide AC.

  4) We request that a minimum threshold be set for the minimum size and maximum size for the amount of refrigeration to be added. The applicants will need to design and demonstrate compliance with applicable sections of 15-2022 by stating the volumes of the performing unit. Therefore, the type of detection system will be properly sized.

  5) We request that the room which the refrigeration system is located in be provided with clarification of the following criteria: Provisions for mechanical rooms were provided under section (g). It appears 15-2022 8.9 may require items like two means of egress for mechanical rooms, out swinging doors, and minimum ventilation requirements. 8.11 elaborates on ventilation requirements to prevent a combustible mix being formed which would allow for regular (non-explosion proof) mechanical / electrical equipment to share the same room. Without vent 8.11 treats it like a hazard occupancy (explosion proofing).

  6) We are concerned that the system needs to have a direct vent to the exterior; and additionally does the system need to be separate from the building’s ventilation and exhaust system – it appears 8.9.7 would require an independent vent. Section (f)(1) seems contradictory. How do we vent independent of the building if no outside air is required?

  7) Additionally, we are concerned on page 4 sec: 7011-01, how is the air safety levels measured? Does the licensed engineer or design applicant take full responsibly for these calculations? They are measured in accordance with ASHRAE standard, and there are sensors on the market that work with that standard. It is unclear if those same sensors can speak with fire command centers or the other annunciation systems specified throughout the rule.

  8) We request that on page 6 system application requirements be written clearer. Would the “fresh air” just be recirculated contrary to 15-2022 if that section states that outside air is not required?

  9) We request clarification on page 7 – emergency alarm regarding whether or not the refrigeration system needs to have a separate detection system and connected to the fire alarm panel.

  10) Does the refrigeration detection system require its own separate filing or can it be included with the fire alarm filing? We request that this be made clear.

  11) We also seek clarification regarding the FDNY’s position on monitoring built-in refrigeration gas detection system within package HVAC or refrigeration Systems and acceptable means of testing of refrigeration gas detectors. On a recent project, FDNY indicated they will not accept the integration of built-in refrigeration detection into the fire alarm system. Instead, they require the use of separate refrigeration gas detectors that must be connected to the fire alarm system and include a means for testing, such as by gas or other approved methods (e.g., an approved test button). However, as of now, such means of testing refrigeration detectors by a test gas or mechanisms (i.e., test buttons) do not appear to be commercially available. Given this situation, we request that the regulation be updated to reflect the practical challenges in complying with the FDNY’s requirements too, which would otherwise pose significant issues for implementation.

  Thank you for your consideration of our recommendations.

  Comment attachment
  NYCCC-Comments-on-DOB-Proposed-Refrigeration-Rules-.docx

  Comment added December 23, 2025 10:20am

• Daniel Bersohn

  Further to my initial comment submitted 12/18/2025 I offer the following additional commentary again on behalf of myself only and with the weight of my code development and professional experience behind me. Also Happy New Year!

  With reference to the numbered items in NYCCC’s comments submitted 12/23/2025, I offer the following commentary:
  1) I share this concern and have offered detailed solutions to this problem
  2) I disagree that a an explicit exception is required. A technical bulletin or industry training materials could be issued addressing how air flow/permanent openings for mechanical rooms for packaged equipment, for example might address this issue.
  2a) Checking EVDC for R2 is important. VRF systems with extensive piping networks shared between multiple dwelling units and with higher charges are common and cost effective in this building typology. A prescriptive option that simply applies a release mitigation valve on the branch to each fan coil in each room would be a workable alternate to designers performing calculations and would generally comply with the intent of ASHRAE 15. It may make sense for a partnership between the City, industry and manufacturers to conduct fire testing based on our stringent passive fire safety and sprinkler requirements to vet the possibility of NYC specific and R2 specific exceptions.
  3) I disagree with this assertion. The scope of ASHRAE 15 is applicable to multifamily buildings. It is entirely possible to comply using unitary systems or central hydronic systems without needing to invest in field provided detection systems.
  4) A prescriptive compliance path based on minimum legal room sizes or with minimum room size limitations could reduce designer workload in limited situations, however this is really not required and probably not appropriate given the fundamental structure of the standard around room volume and effective volume calculations. Instead, the City could partner with the local ASHRAE chapter, ACEC, and other industry organizations to develop typical situation compliance guidance.
  5,7,9,11 ) The rule should be clarified to allow a relay, BACnet, modbus or other communication interface between the refrigerant detection system and the building’s fire alarm system which will ultimately report conditions to a central monitoring service and FDNY. The rule should not require or enable any agency to require duplicative systems.
  6,8) I disagree with this comment. The comment author seems to misunderstand the intent of refrigerant dispersal mechanisms of ASHRAE 15 in spaces other than machinery rooms. The point is to disperse and slow the release of the charge to safe levels within the building.
  10) I would suggest that the refrigerant detection system be shown on the mechanical drawings and be within the scope of the mechanical permit. The interface to FAS should be shown on FA drawings and be part of the FA permit. An advantage of clarifying the scope demarcation between refrigerant detection systems and the FAS which reports events to FDNY would be to align commercially available systems to the permit and filing structure. Also staff working for PEs on fire alarm drawings are generally unfamiliar with the design of refrigeration systems. By showing only the monitoring interface to the refrigerant detection system on the FA drawings, mechanical engineers will not have to work on FA drawings along side electrical engineers.

  It should be made clear that a ventilated shaft enclosure is not required for refrigerant piping systems where they are fire-stopped at horizontal assemblies and the piping system complies with section 9.13 of ASHRAE 15 (ref versions -2022 and 2024 (incl addendum A) for 9.12.1.5). Where designers elect to route piping vertically thorough shafts, then and only then must they be ventilated in accordance with . There is no reason to have a ventilated shaft enclosure for an A2L refrigerant with a limited mass of material which is difficult to ignite when we have no ventilated shaft enclosure requirements for vertical fuel gas piping which contains an unlimited quantity of material that can easily reach explosive concentrations that are easy to ignite.

  Comment added December 31, 2025 12:19pm