Technical Corner

May 1, 2025

Introduction

ORFA members have shared that results of recent Ministry of Labour, Immigration, Training and Skills Development (MLITSD) inspections have resulted in site specific direction regarding plant operators wearing personal refrigerant detection devices when in the refrigeration plant. The ORFA reminds owners and operators that personal chemical detection equipment has significantly improved with respect to accuracy and comfort. The price point for these devices is also now considered reasonable. The ORFA has not, nor does not, plan on adopting an industry best practice for ice sheet industrial refrigeration operators wearing such devices. These decisions would be best determined through an internal risk assessment through the building owner and Employer Joint Health & Safety Committee.

Further, the ORFA is not aware of any blanket provincial direction from any governing agency to adopt this practice. ORFA members are reminded that all inspectors have the authority to interpret legislative responsibility based on site specific risk and hazard conditions and take corrective action for worker safety. The development of a provincial wide directive to clarify or strengthen the understanding of any legislative responsibility is a complicated process that can take a significant amount of time. ORFA members are also reminded that they have the opportunity to appeal any inspector’s direction or to offer alternative solutions that could reduce the risk or hazard.

Background information on these directives may consider that refrigeration plant room age and design.  Some will be older in design, construction, and life-cycle of equipment which is a common theme based on Canadian ice sheet industrial refrigeration aging assets. The takeaway for other ORFA members to these inspection experiences should include the need to evaluate their refrigeration plant rooms and take the necessary steps to ensure operator safety in advance of a MLITSD or TSSA inspection. The ORFA recommends that owners and operators of older ice sheet industrial refrigeration plants have these assets evaluated by a qualified person to determine the gap between original design and construction methods and current requirements for new plant rooms as defined in the CSA B-52 Mechanical Refrigeration Code. The plant room responsible person would also be considered diligent in their effort to raise awareness with the plant owner of significant design and construction methods when compared to current plant conditions. Recommending investment to improve operator safety is a reasonable, proactive, supervisory due diligence.

The ORFA is committed to providing the necessary membership support through education and professional development/accreditation. However, safe and effective operation and management of these assets must be driven internally through awareness and assurance of compliance that exceeds minimum regulated responsibility. [More]