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ORFA ALERT

Refrigeration Plant Room Eyewash, Deluge Shower and Sensing Equipment Installation and Maintenance Compliance

January 26, 2026

In a continued effort to raise regulatory compliance requirement awareness and reduce operational risk, the ORFA, in partnership with Technical Standards and Safety Authority (TSSA) and the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) are advising of a frontline inspector focus on deluge shower, eyewash, and toxic gas sensor management responsibilities in all ice arena registered refrigeration industrial plants. As much of Ontario's industrial refrigeration inventory is aging, the risks of a significant release of refrigerant increases, requiring plant owner's, users, and operators to be more diligent in preparing for such an event.

TSSA and MLITSD frontline inspectors are committed to plant safety through limited inspection.  However, the real responsibility to inspect for safe operation and plant management rests with the Internal Responsibly System (IRS) through the various stakeholders identified and defined in the Occupational Health & Safety Act (OHSA), Operating Engineers Regulation (OE). Refer to: ORFA Review of TSSA Unattended Refrigeration Plant Advisory

Both MLITSD and TSSA have advised ORFA that they have identified deluge shower, eyewash, and toxic gas sensor inspection as key focus areas for their frontline inspectors in the coming months.

What does this mean?

Inspectors will continue to perform their usual reviews however, a strategic focus on these safety items will be heightened during upcoming inspection cycles.

What will inspectors focus on?

Facility managers would be adequately prepared by having the following information current and up to date:

  1. Plant users are encouraged to review these devices to determine if they meet current standards or if capital investment would improve plant, operator, and public safety.
  2. Proof of regular testing and proper operation of each of these safety devices that meet regulatory responsibility and/or industry best practice.
  3. Confirmation that these items are included in the plant's asset management plan.
  4. A written training plan that is used to inform operators on the safe operation and use of each device if use is required or if an emergency alarm is activated.

What should be expected for non/compliance?

Both TSSA and MLITSD are focused on improved safety through education however, inspectors will use all tools available based on individual operational and site conditions. Both governing agencies believe that financial or other penalties are the last tools in their toolbox to assist in changing attitudes or commitment to safer operations.

ORFA: Historically, these compliance directives given to the ice sheet refrigeration industry has focused on ammonia plants. It is noted that the refrigerant landscape continues to expand beyond ammonia which will require plant owners and users of industrial refrigeration plants with alternative refrigerants to be proactive to the same level of ammonia compliance obligations.

What is role of the refrigeration service contractor?

Having a strong working relationship with a refrigeration service contractor is an important part of the plants ongoing maintenance however, the service contractor is not responsible for confirming compliance. Ensuring operator and public safety through proactive operation, maintenance and asset management is the responsibility of the plant’s owner. Selecting and training qualified users that represent the owner in a professional and responsible manner is essential to safe operation and management of the plant.

ORFA Observations

As part of the identified focus, ORFA shared with both TSSA and the MLITSD that many recreational refrigeration ice plants may seem to be compliant however, devices may not have been properly installed due to poor original plant room design. The following are key areas that inspectors may use as part of their inspection:

1. Inspectors will be reminding plant room owners and users that it is their obligation to confirm and maintain these systems to current standards. Frontline inspectors are not experts in every aspect of compliance or safe operations, however, should there be an incident in the plant room it should be expected that appropriate experts on the subject will be utilized as part of the investigation. This is the level that plant owners and users should prepare for.

ORFA: Health and safety protection has significantly evolved over the past 50-years resulting in clearer direction through regulation and/or standards. As these directives are officially adopted, they become mandatory requirements for "new" or retrofit designs. Unless there is a set directive that reaches back to older construction there is no mandatory obligation of "owners" of this infrastructure to update existing plantrooms. However, at times, governing agencies may deem updating existing infrastructure as a reasonable expectation and will at times try to improve worker safety by requiring a design update. This approach was undertaken approximately 20-years ago as MLITSD inspectors aggressively directed our industry to update plant rooms by installing eye wash and deluge showers through a "Compliance Order". Plant owners responded by investing in the installation of these safety devices which satisfied the Ministry's Compliance Order directive. However, this "compliance" sign off should not be mistaken as a confirmation of proper installation. The MLITSD is not confirming that the systems were installed correctly but rather that a system was installed as directed. A quick audit of current installation that may indicate a failure to properly install these systems would include but not limited to:

  • Were the eyewash and deluge shower installed at the time of plant room construction or a post construction installation based on a Ministry of Labour plant room compliance directive?
  • Does the shower area have a drain or does the water accumulate as a potential slip hazard or an electrical shock hazard as water accumulates near plant electrical devices.?
  • Does the eyewash and deluge shower provide adequate tempered water, as required by code?
  • Were the systems installed in the plant room?

Action: Facility management should consider if a review of installation to ensure it meets current standards should be performed by a qualified technician as required. Alternatively, placing the review with the Joint Health and Safety Committee might be considered.

2. Inspectors will focus on confirming that there is an adequate maintenance, testing and operator training program in place.

ORFA: Many of these systems have been installed and forgotten. The ongoing maintenance of these devices are critical to worker safety. In addition, facility operators who may be required to use these safety devices must be properly trained on the use of this extension of these personal protective devices.

Action: Facility management should be prepared to prove to inspectors that there are solid maintenance, life cycle and operator training plans that meet or exceed standards or industry best practices are in place. These obligations should form part of the mandatory plant room training and maintenance manual as required under section 46 of the Operating Engineers Regulation:

Procedure manual 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.

3. Plant refrigerant sensors are another operator and public safety device that requires ongoing inspection, maintenance, testing and replacement. TSSA expects all required plant room sensing devices to hold a "testing tag" that is dated, indicating it is properly functioning and in good repair. Confirming that devices are properly installed should be undertaken. In addition, operators must understand what the device is sensing and how to properly respond should the device be activated.

ORFA: These plant sensing devices have a variety of roles beyond sensing a noxious or toxic chemical release. When activated, an audible and visual warning in an area that warns those in the building is required. In addition, the sensing device may activate the exhaust fan to begin to purge the plant room. It is critical that all auxiliary response systems are also properly maintained, tested and replaced based on life cycle expectancy.

Action: Facility management should be prepared to prove to inspectors that there are solid maintenance, life cycle and operator training plans that meet or exceed standards or industry best practices are in place. These obligations should form part of the mandatory plant room training and maintenance manual as required under section 46 of the Operating Engineers Regulation.

Conclusion

The role of the ORFA is to provide general guidance and direction to its members on critical matters impacting our industry. Working closely with key stakeholders such as TSSA and the MLITSD helps ensure that we are all focused on the same objectives however, it must be stated that each frontline inspection will use the same guiding inspection principles, but each is also unique requiring the inspector to evaluate based on current conditions and on-site observations. At times, members may not agree with an inspector’s observation and as such a reminder that there is an appeal processes should such issues occur. As a benefit of membership, the ORFA is prepared to assist members should they require support in navigating inspector compliance directives.

Recommended ORFA Resources - Pre-Inspector Plant Visit

Being well informed is always a critical step in being prepared. The following ORFA resources are available as a benefit of membership to better understand the topics outlined in this Alert:

Recommended Plant Owner, User, and Operator Training Pathways

ORFA offers a variety of industry leading training and educational opportunities to support safe and efficient ice sheet refrigeration plant operations. Refer to:

Training and accreditation pathway: Ontario Recreation Facilities Association Inc. - Certified Arena Refrigeration Plant Technician (CARPT)

Other industry leading refrigeration resources: https://www.orfa.com/Refrigeration-Plant-Operations



     
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