October 24, 2017
Ice Arena Registered Refrigeration Plant Safety Bulletin
An Industry Specific Plan to Collectively Move Forward

The investigation into the Fernie, BC refrigeration plant room tragedy continues to unfold with the cause yet to be identified. Proactive Ontario Recreation Facilities Association (ORFA) members have been quick to reach out to the Association for guidance on how best to prepare for questions from community leaders, user groups, and other stakeholders on the efforts currently in place to reduce a refrigeration incident, and to reconfirm they are being diligent in current refrigeration operational activities.

Members who have attended ORFA training courses and adopted and/or implemented the regulatory and operational best practices for safe refrigeration operations will already be well positioned to effectively respond. In follow-up to an ORFA news release entitled “Are Ontario's Ice Rinks Safe?” the following additional information is being shared with media, related agencies and other interested parties on the topic. The information highlights industry best practice, as together, we reassure all who work and play in our arenas that we have, and will continue to be, diligent toward our duty-of-care for both the worker and general public. 

  1. Facility users and workers in Ontario’s recreation facilities should feel confident that there is a very strong network of checks and balances in place to ensure refrigeration safety. Key partners in safe refrigeration operations include, but are not limited to, agencies such as the Technical Standards and Safety Authority (TSSA), Ministry of Labour (MOL), Electrical Safety Authority (ESA), Ministry of Environment (MOE), Boiler Inspectors, Refrigeration Contractors, the ORFA and the professional staff who manage and operate these important community assets. Each of these partners are not only focused on their obligations and responsibilities – they are real life participants in worker and public safety as they, their friends, and families are also users of our buildings.
  2. The ORFA Basic Arena Refrigeration training course is considered a minimum requirement for all facility staff granted privilege by the “plant owner” under the Operating Engineers Regulation to enter a registered refrigeration plant room. This course has been industry-leading for over 60 years.
  3. The ORFA remains committed to worker and facility user safety. Recently, the Association recognized the regulated roles and responsibilities of the “owner” to develop and implement effective ice arena plant room maintenance documents, provide ongoing, internal, workplace specific plant operator training, and to work in partnership with the selected refrigeration contractor. To assist both the owner and arena plant operator in meeting these expectations, the ORFA created the Certified Arena Refrigeration Plant Technician (CARPT) professional designation and recommended that every “unattended guarded plant” have one such individual on staff. Further, the CARPT is recommended as ongoing professional development for all TSSA Refrigeration Operator Class "B" operators whose certificate is five years or older, and who work specifically in the ice arena industry.
  4. The call by some to ban ammonia due to its hazardous characteristics may be unrealistic. Ammonia is an inexpensive, environmentally-friendly substance that has performed efficiently in the refrigeration cycle since 1915. Since its introduction, all partners in refrigeration safety have worked to put mechanisms byway of operational regulator compliance obligations, ongoing inspection and a series of alarms and fail-safe devices to ensure safe operations, regardless of refrigerant types. Switching existing ice arena equipment to an alternative refrigerant is not a simple process. Pending the age and design of the current infrastructure, the change costs would be in the hundreds of thousands of dollars. It is also important to note that the switch does not eliminate risk as all refrigerant plants are under extreme pressures with any large escape of a chemical substance having the potential for significant human, and environmental impact.
  5. The commitment by manufacturers, suppliers and installers to provide refrigeration systems that are designed with safeguards that significantly reduce risk is ongoing. Regardless if the system is state-of-the-art or older technology, the ongoing safe operation rests with the refrigeration plant owner and operators. ORFA members are encouraged to remind owners of the plant of the importance in the investment of ongoing maintenance and upkeep. Refrigeration safety must include a business plan that indicates general upkeep and maintenance, as well as investment in life-cycle replacement of key components of the system and safety devices.
  6. The loss of a certified refrigeration mechanic in the Fernie, BC tragedy will require owners to re-evaluate their current relationships with all professional contractors that attend their buildings. Regardless of any past historical relationship, arena managers that have provided contractors with unrestricted access may wish to reconsider this practice. A reminder that these individuals under the Occupational Health and Safety Act are an extension of facility staff while on site and that their conduct must reflect internal health and safety policy and procedures. This relationship evaluation, or discussion, might be best added to a future Joint Health and Safety Committee meeting.
  7. Refrigeration plant monitoring is an essential safety activity. Facility staff play an important role by continually monitoring plant function. Properly trained staff will be able to identify small changes in plant operations that can be quickly acted on before a small problem becomes a larger issue. Knowing the cycle of refrigeration and being able to identify all safety devices, and their function, are essential monitoring skills. Making observations and recording findings by an operator who has limited understanding of the task they are performing has little benefit. Refer to: Developing a Registered Refrigeration Plant Room Inspection, Maintenance and Readings Program
  8. Knowing what to do when there is an emergency is not only diligent, but a legal responsibility under both the Operating Engineers Regulation and the Ontario Fire Code. Facility management must conduct an evaluation of staff’s current level of ability to respond should an emergency occur. Frontline staff and plant operators must self-evaluate their current level of preparedness. Refer to: Recreation Facility Emergency Planning Document and List of Ammonia Leaks CTV News
  9. To assist ORFA members, the following minimum, no/low cost, internal review of current registered refrigeration plant operations should be confirmed:
    1. Ensure that all SDS information is current, available, and up to date and; that all recommended PPE is available.
    2. That facility staff be given refrigeration plant risk and hazard awareness training (refresher). Refer to: Anhydrous Ammonia Exposure Worker Safety
    3. That facility management confirm that all plant fail safe devices are in proper working order.
    4. Ensure that the installed plant room exhaust fan continues to function at its highest level of efficiency. Many of these units are original installations.
    5. That all facility emergency alarm tests are up to date with confirmation of same on file.

      Operating Engineers Regulation (OER): (3) A refrigeration installation referred to in subsection (1) that is in a machinery room, as defined by CAN/CSA-B52, shall be equipped with a gas detector system that will activate the alarm system required by clause (2) (a) and start a mechanical ventilation system if there is a leak of refrigerant causing the airborne concentration of refrigerant to rise above the level value as defined by CAN/CSA-B52. O. Reg. 219/01, s. 45 (3). and Refer to: Sensing Equipment Maintenance and Calibration

    6. That log books are being properly completed. These documents record changes in the plant room. This information is vital for operator safety while providing guidance to the refrigeration mechanic as to how the plant is performing.

      OER 37. (1) Every user of a plant shall keep in the plant a log in the form of a book or electronic log. O. Reg. 219/01, s. 37 (1).

    7. That all required refrigeration plant room awareness safety signage is in place (and in good condition) – both in the building and on the exterior of any egress from the plant room. Refer to: Refrigeration Room Safety Identification of Risks and Hazards
    8. That the plant rooms procedures manuals are up to date.

      OER 46. Every owner of a plant shall keep on the premises of the plant an up-to-date, detailed operating procedures manual designed by or acceptable to the chief operating engineer or chief operator of the plant that sets out the procedures relating to training and the operation of all equipment and systems of the plant and all emergency procedures. O. Reg. 219/01, s. 46.

    9. It is noted that common practice has been to allow refrigeration contractors uncontrolled admittance for maintenance and repairs, with many working alone.  This practice should be reviewed. 
    10. All user groups must be reminded of the importance of evacuation when the building alarms sound. Advising them to return to the locker rooms for personal items, or to change attire is risky, and legally unacceptable.
    11. An important part of every work environment is not only stating what work is to be performed, but also stating what work is not to be attempted by unapproved staff.
    12. Management should consider the benefits of meeting with local EMS professionals to reconfirm emergency procedures and public safety. The results of this assembly should formulate the bases of an updated refrigeration plant emergency action plan. It is important to remember that this should be performed no less than annually and included in new staff orientation.
    13. That all applicable legislation documents be current and up to date. Operating Engineers Regulation   I   Canadian Standards Association B-52 Mechanical Refrigeration Code

As a benefit of membership, the ORFA offers many other refrigeration safety, operational best practices, and awareness resources located on-line at ORFA's Resource Centre.  Facility management is encouraged to consider these resources as effective low cost, no cost tools to assist with ongoing, workplace specific refrigeration plant staff training. Refer to: Guidelines and Best Practices. The ORFA also offers a 1-day Safe Arena Refrigeration Plant Operator course that may be of further support. 

The ORFA remains committed to assisting our members through ongoing provision of up to date information and guidance. The partnership forged between the Association and those who work frontline is an invaluable relationship that helps confirm that collectively we are focused on the same goals. We wish to thank members who share their experiences and workplace resources for the betterment of the industry. We continue to invite participation by contacting us at info@orfa.com or by calling 416.426.7062.