Ammonia Safety

Program: Your role in

Safety LeadershipJuly 2020

1. COVID-19 update

2. Clarification on key regulatory requirements

3. Ammonia safety & risk prevention approach

4. Wrap up and Q&A

AGENDA

2

COVID-19 UPDATE

Variance requests during COVID-19Unable to meet regulatory requirements? You may request a variation to a code, standard, regulation. Complete the variance form found on our website.

Starting up your facility

• Carry out maintenance and inspection per CSA B52 and manufacturer’s recommendations• Check and test all safety and operating devices• Review operational parameters• Conduct vibration analysis• Review relevant safety orders

https://www.technicalsafetybc.ca/blog/starting-your-refrigeration-system-what-you-need-know

GUIDANCE DURING COVID-19

4

REGULATORY

CLARIFICATIONS

Staffing Requirements (Continuous Supervision)

“Unless a plant is registered under section 54 or is exempted under section 6, the person in charge of the plant must be present at all timesin the plant boiler room, refrigeration machinery room, engine turbine room or in the immediate vicinity within the plant premises while the plant is in operation.”

• Only a “Refrigeration Operator (RO)” or “Power Engineer (PE) of 4th class or higher” can hold the title of “person in charge” of refrigeration plants.

• An “Ice Facility Operator (IFO)” can operate the plant if the plant is less than 1000 kW and has a “Refrigeration Operator” or “Power Engineer of 4th class or higher” certificate holder as the “person in charge of the plant”

PEBPVR Safety Regulation, Section 45

Staffing Requirements (Risk Assessed Plants)

The “person in charge” of the plant must be present on the plant premises for a minimum 7 hours a day (24 hour) or any greater times as specified by provincial safety manager.

For the remainder of the 24 hours:

• While the plant is occupied by public or building staff / employees, a holder of “IFO” or “RO”, or “PE of 4th class or higher” certificate of qualification must be present on the plant premises

• If person(s) must enter the facility for purposes of maintenance or repair, janitorial service, security or other such requirements, the plant must be monitored by a person holding at least Refrigeration Safety Awareness certificate of qualification or higher.

• When the plant is not occupied, it can be remotely monitored

PEBPVR Safety Regulation, Section 56

Plant in Operation.

“Plant in operation” is defined as:

“A refrigeration plant is deemed to be in operation if any part of the refrigeration system contains refrigerant at a pressure greater than 15 psig, unless the system refrigerant charge is pumped down and contained in a liquid receiver, or parts of

a system designed for that purpose, and isolated to prevent the circulation of refrigerant.”

Safety order SO-BP-2017-02

Maintenance by “Operating Permit” holders

If a person holds an operating permit, the permit holder or an employee of the permit holder may perform routine maintenance or minor repairs to that equipment without holding a refrigeration contractor's licence.

PEBPVR Safety Regulation, Section 62.(3)

An individual must not perform maintenance and repairs on a refrigeration plant unless the individual

(a) holds a fourth class power engineer's certificate of qualification or higher, or

(b) is a refrigeration mechanic.

PEBPVR Safety Regulation, Section 5.(2),

Maintenance by “Operating Permit” holders

An individual may do regulated work for which specific qualifications would be required under the Act if the individual is supervised by a person who:

(a) is specifically authorized under the Act to perform that type of work, and

(b) supervises the individual on site and provides guidance and assistance to the individual as the regulated work is performed.

Safety Standard General Regulation, Section 5.(1)

AMMONIA SAFETY &

RISK PREVENTION

APPROACH

Ammonia Refrigeration Incidents

• Upward incident trend• 40 injuries• 3 fatalities• Two area evacuations• One state of emergency

• 75% of incidents caused by:• Equipment Failure• Inadequate procedure

0 2 0 6 4 4 3

129

4

15

51

39

19

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Nu

mb

er

of

Inci

de

nts

Year

Ammonia Refrigeration Incidents2007 to 2020

Why we all care about safety

Cost of an incidentWell being of your

people

1

• Financial loss

• Productivity loss

• Legal costs

• High internal turnover

• Incidents can cause injuries, or even death

• Complying and following

safety procedures lead

to:

•Employee confidence

•Less downtime

•Happier, healthier

workplace

2

Why we all care about safety

Your legal responsibility

It’s good for your business

3

• Installation Permit

• Licensed contractors & certified individuals

• Asset Owners

• Qualified individuals

• New designs, newly built equipment

• Inform Technical Safety BC

• Positive reputation

• Hiring

• Longevity and reliability of equipment

• Reduces risks of shutdowns

• Reduces legal/regulatory Issues and costs

4

Summary of responsibilities

Maintenance Requirements:

• Act and Regulation

• CSA B52

• owner must maintain the refrigeration system to preserve the operating efficiencies, equipment integrity, personal protection and protection of the building and natural environments

• CSA B51

• in-service inspection must be performed to determine the condition and fitness to continue to operate safely of pressure vessels, piping and fittings in a refrigeration system

• NBIC, Part 2

Maintenance strategies and practice

Strategy Description

Corrective Inspections, repairs, replacements carried out following detection

of anomalies.

Preventative Inspections, repairs and replacements are scheduled at pre-

determined intervals.

Predictive Regularly assess condition and repair or replace prior to

estimated failure.

Reliability

Centered

Analyze failure modes and customize inspections, repairs and

replacements based upon desired reliability.

Toolkit

Guidelines for Ammonia Refrigeration

Plant Equipment Integrity Programs

Sample Maintenance Manual

Hiring Assistance

Roles and Responsibilities

Communication Aid Tool

Type Intervention

Target group Arena owners & managers, all arena

facilities with ammonia refrigeration

systems

Population size 168 active sites, all regions

Intervention

strategies

Maintainence guideline

Support tools

Training

1:1 Peer coaching & knowledge sharing

Length of

intervention

6 months delivery + follow-up evaluation

Ammonia Safety Supports

PURPOSE OF

MAINTENANCE

GUIDELINE

Provide guidance and basic information to support industry with developing effective maintenance and inspection programs and operational procedures.

Guideline objectives

1. Provide support to industry in response to the report’s recommendations

2. Provide direction and guidance to:

• owners

• contractors

• training providers

• operators

3. Improve the management and oversight of:

• maintenance programs

• inspection

• operational emergency procedures

Ammonia Refrigeration Maintenance Guideline

Equipment Integrity Management Requirements

• Statement of Authority and Responsibility

• Manual Control

• Training and Competency

• Document and Records Administration

• Procedures

• Installation, Repair and Alteration Methods

• Materials

• Etc.

Maintenance Guideline – Risk Assessed Plants

• Technical Safety BC, MAN-4000, requires a comprehensive maintenance program

• The “Maintenance Guideline” could be used for this purpose

• Maintainence Guideline complete

• Training & support tools in development

• Program launch dates TBD – will be decided in consultation with

industry (Re: COVID-19 impacts), expected late fall 2020 or early 2021

Ammonia Safety Supports – what’s next

Sign up for Notifications (bottom of homepage)

• Receive safety orders and directives

• Find out about technical events

• Receive technical newsletters

Login to your online account

• Pull, pay for and view permits

• View your inspection results

• Find out about common non-compliances and

high hazards

*Note: Our new online system replaces MyConnection.

technicalsafetybc.ca

STAY CONNECTED

LEARN WITH US

Access our Learning Centre

(www.learning.technicalsafetybc.ca)

• Register for online courses, webinars and in-

person sessions

• Access online resources

www.learning.technicalsafetybc.ca

technicalsafetybc.ca

INCIDENT & HAZARD REPORTING

To report an incident or

hazard:

• Call 1-866-566-7233

• Go on our website

and complete the

online form

CLICK here to get

to the online form

QUESTIONS?

Who is Technical Safety BC?

Technical Safety BC by way of an Administrative Agreement with the Province of BC is the regulatory body that administers:

The Railway Safety Act

(RSA)

The Safety Standards Act

(SSA)

If you are installing, operating, manufacturing, altering, maintaining or selling equipment in any of the technologies we regulate, you are likely within our jurisdiction*

Our Vision: Safe technical systems. Everywhere.

Products and services Technical Safety BC offers

• Installation Permits

• Operating Permits

• Licensing for Contractors

• Certification of Individuals

• Education (tech talks, events)

• Review & Approval of Product Designs

• Investigate Incidents

• Inspect Based on Risk

• Audit & Enforce

Fernie Memorial Arena – Multiple Areas of Failure

Employee Turnover

FERNIEOCTOBER 17, 2017

3 Fatalities

95 Residents

Knowledge & Expertise

Unclear Roles

Competing Priorities

Maintenance programs

Hazards and Risk

Industry standards and guidelines

• Limited resources (specific to ammonia refrigeration systems)

• standards

• guidance

• information

• Refining and Petrochemical:

• API:

• RP 571 (Damage Mechanisms Affecting Fixed Equipment in the Refining Industry),

• RP 574 (Inspection Practices for Piping System Components)

• Goal of proposed guidelines is to fill this gap

Ammonia Refrigeration Maintenance Guideline

Main Body and General Information:

• Scope,

• Definitions,

• Owners Responsibilities

• Equipment Integrity Management Program Requirements

• Mandatory Code and Regulations

Ammonia Refrigeration Maintenance Guideline

Guidelines for Ammonia Refrigeration Plant Equipment Integrity Programs:• Main Body and general information

➢ Equipment Integrity Management Program

• Appendix A: Sample of an integrity management manual

• Appendix B: Damage mechanisms and inspection approaches

Ammonia Refrigeration Maintenance Guideline

Appendix A: Sample of an integrity management manual

Appendix B: Damage mechanisms and inspection approaches

• Corrosion

• Erosion

• Cavitation

• Damages specific to certain refrigeration equipment:

➢ Piping, Compressors, Condensers, Heat exchangers, …

AMMONIA

REFRIGERATION

PLANTS

REQUIREMENTS

Plant Supervision

Scope

Terminology and references provided in this presentation on

plant supervision are applicable to refrigeration plants in

public occupancies such as ice rinks and curling rinks.

Plant in Operation

For the purposes of plant supervision, a plant is deemed to be in

operation if any part of the refrigeration system contains refrigerant

(e.g. ammonia, Freon, etc.) at a pressure greater than 15 psig,

unless:

• the refrigerant charge is pumped down and contained in a liquid

receiver, or parts of a system designed for that purpose,

• provided with over-pressure protection, and

• isolated to prevent the circulation of refrigerant.

Plant Supervision / Common Requirements

The regulation sets out the requirements for the supervision of

refrigeration plants:• that exceed 50 kW total capacity (Group A3, B2 and B3 refrigerants).

Ammonia plants fall under this category.

• that exceed 200 kW total capacity (Group A1, A2, and B1 refrigerants).

Freon plants fall under this category.

Plants can be operated as Continuous Supervision or Risk Assessed

Status.

Classification of Refrigerants

REFRIGERANT CLASSIFICATIONS

LOWER TO TOXICITY HIGHER TOXICITY

HIGHER FLAMMABILITY A3 B3

LOWER FLAMMABILITY A2 B2

NO FLAME PROPAGATION A1 B1

Ethane

Propane

Isobutane

Carbon

Dioxide

Ammonia

Freon

Plant Supervision / Common Requirements

Person in charge of a refrigeration plant

The owner of a refrigeration plant must designate a person to

be in charge of the plant that is responsible for the plant at all

times that it is in operation.

NOTE: add incident reporting requirement – check info bulletin

Plant Supervision / Common Requirements

The person in charge of a plant that is Continuous Supervision or

Risk Assessed Status refrigeration plant is required to hold a:

• 4th Class Power Engineer (PE) (or higher), or

• Refrigeration Operator (RO) certificate

Note – a PE or RO are also qualified to be in charge of a shift

Plant Supervision / Common Requirements

Ice Facility Operator (IFO)

• can be the person in charge of a shift in a Continuous

Supervision or Risk Assessed Status refrigeration plant that does

not exceed 1000 kW total capacity

Note – an IFO is not qualified to be the person in charge of a plant

Plant Supervision / All Plants

• the person in charge of a shift shall be in the immediate

vicinity of the plant premises at all times that the plant is in

operation

• the person in charge of a shift is not intended to be within

the refrigeration machinery room at all times, but must be

on-site, within the plant premises

CONTINUOUS

SUPERVISION

STATUS PLANTS

Plant Supervision / Continuous

Means that the plant is required to be under continuous

supervision at all times that the plant is in operation

Supervision is not required when:

• the plant is not in operation

• the plant does not exceed 50 kW total capacity (Group A3, B2

and B3 refrigerants e.g. ammonia)

• the plant does not exceed 200 kW total capacity (Group A1, A2,

and B1 refrigerants e.g. Freon)

Plant Supervision / Continuous

Person in charge of a shift

A person in charge of a shift in a Continuous Supervision

Status plant is required to hold a:

• 4th Class Power Engineer (or higher),

• Refrigeration Operator, or

• Ice Facility Operator certificate

SUPERVISION / RISK

ASSESSED:

RISK ASSESSED

STATUS PLANTS

Supervision / Risk Assessed

Section 56 of the regulation provides the requirements for a

Risk Assessed Status Plant

• limited to refrigeration plants up to and including 1000

kW capacity

• Plant must meet additional technical specifications

including remote monitoring and alarms

• Provides for reduced supervision when the plant is in

operation and the premises are not occupied

Supervision / Risk Assessed

Supervision of a risk assessed plant is required at all times when:

• The plant is in operation, and

• The premises are occupied (by any person)

Supervision of a risk assessed plant is not required when:

• The plant is not in operation, or

• The plant is in operation and the premises are unoccupied

Supervision / Risk Assessed

Person in charge of a shift

The person in charge of a shift for a minimum of 7 hours in any 24

hour period is required to hold a:

• 4th Class Power Engineering (or higher), or a

Refrigeration Operator certificate,

The person in charge of the remaining shifts in any 24 hour period

is required to hold a:

• PE (4th class or higher), RO, IFO, or

• a Refrigeration Safety Awareness certificate

Supervision / Risk Assessed

Refrigeration Certificate of Awareness Certificate

The regulation was recently amended to remove the requirement

for a RSA certificate to name the plant on the certificate.

However, it is now the responsibility of the owner of the plant to

ensure that the RSA certificate holder is trained in the safety

procedures for that specific plant prior to being assigned to the

shift schedule