In this podcast, ORFA’s Technical Director shares what he didn’t know was legally required, some of the historical gaps and the roles and responsibilities of refrigeration plant stakeholders as it relates to plantroom logbook information. Read ORFA Technical Corner on this topic.
In this podcast, ORFA’s Technical Director shares what he didn’t know was legally required, some of the historical gaps and the roles and responsibilities of refrigeration plant stakeholders as it relates to plantroom logbook information. Read ORFA Technical Corner on this topic.
Hey, hello and welcome to another ORFA have a podcast. This time, I'm going to look at everything I didn't know about refrigeration logbook readings and my responsibilities under the operating engineer regulation. It almost seems not that long ago that I actually took my first readings as a young operator back in the late 1970s. And the mentor, the individual who took me around the plant room and pointed out all the things that I needed to collect and put into the logbook every two hours, as expected by my employer. And I will be quite honest with you, I always thought that this was a legal obligation to meet this two hour threshold. And if in fact, I failed to do that, then there would be some potential accountability. So we're going down the road of discussions with TSSA Technical Standards and Safety Authority on some of the things that we believe could be improved upon for our industry in regards to better communication from them. And, you know, we are excited that in fact, they are listening to us, and they are having open dialogue with us. And stay tuned in regards to where in fact, this would come into play. So part of the conversation started to talk about the logbook. And if you are invested into the operating engineers regulation, and in fact, you're taking the time to read it, you can you know that it's kind of convoluted when you try to figure out responsibilities, because you have to kind of move around the whole regulation and figure out how I how you're going to comply to this regulation. Now, it's not much different than any other regulation that we are responsible for. Some of them are more direct, I take a look at the swimming pool. It's got some gaps in regards to their regulation. But it does give clear direction in regards to data that the Ministry of Health expects every swimming pool to collect. Now when it comes to our mechanical rooms, both aquatics or refrigeration, there is a little bit of flexibility that the owner actually has. So let me focus in on the refrigeration plant room. And I'll give you a little bit of like I said, my historical understanding. And then I'll give you what I believe is really the flexibility that every owner, user and chief has in regards to collecting this information. Now, first, let's be clear, we are not collecting any of this information for a governing authority. There is an expectation that we are going to invest in inspection. But they don't set out any details in regards to what it is that we need to be collecting in respect to hard data on a regular basis. I melted down to this. And again, you'll have to interpret the regulations specifically for yourself. But if you've attended any of our training courses we'll talk about the logbook must contain incidents, accidents, repairs, and adjustments. Now it's a little bit more detailed than the operating engineer regulation. But it kind of melts down to what the expectations are. Nowhere in that conversation. Did we talk about suction pressures or discharged pressures or temperatures or oil levels or all that kind of good stuff, that this is a data that I'm collecting, or I'm having my staff collect in the logbook, as a health check to the plant. And this is information that gets passed along from operator operator as we switch shifts. So if I'm doing a very detailed dive into collecting all of this information in the plant room, it's not going to work if the next shift operator doesn't come in and take a look at it. So that's the first point of contact. So we've got governing authorities that are expecting us to do an inspection, how detailed is going to be based on the plant design, if there are any issues with the plant. So now as the user of the plant, and we're talking about an unattended plant, I'm the user of the plant, then I need to direct all the other people that are going into the plant room, how often I want them to inspect so if I decide that I've got a really good robust maintenance plan, I've got good technology that will report to my my cell phone if the plant shuts off or if there's any type of shift in in change of operating parameters. Then you know what, maybe one inspection shift as an often I can have them focus on other responsibilities, cleaning disinfection and sanitization. sanitization. So I get that flexibility. But if I got a plant that for whatever reason seems to be kicking off or we have had leaks that have been detected several times over the last couple of months, I might want to up the up the ante and and have staff do more inspections to make sure that in fact, the plant is running as designed. So it's a basically it comes down to the owner in the user of the plant on how the plant is going to be inspected. Now, that will only be really, truly analyzed if there's a problem. And what they may do is take a look at what's the industry best practices and say, Well, okay, how come you weren't following what the industry was suggesting. So currently, we suggest that an unattended registered ice sheet refrigeration plant should be inspected no less than three times per shift. So one at the start of the shift, somewhere around the halfway point, then obviously, before you wrap things up, now again, recommendations, the owner and the user of the plant actually get to dictate how often that is. Now, if you've taken your any of our training, you would have heard me say along the lines is that I would rather that a person that was improperly trained or not adequately trained or didn't know what they were looking at, not go in the room. Rather than have them go in and take a bunch of readings and look and things look at things, they have no comprehension on how it works. So there's a risk factor here that ultimately comes into play. So we've got two different animals. And again, if you are in tune with our industry, we've got attended plants and unattended plants attended plants are those that have a chief operator and require certified operators to support the chief, or a risk base plan that is now offered through TSSA as an option. And the chief gets to dictate how the plant is going to be operated. So he or she will set out that inspection maintenance plan and then direct the operators. Now, it's a little bit more complicated when it gets into unattended plants. And that's the majority of our membership, they have what's referred to as an unattended guarded plant, meaning that you do not require a certified staff. And it's being guarded by a series of safety devices. So if they go outside their working parameters, the plant, in fact will shut down. Now the data that I'm collecting throughout each day, or each operating year is information that's going to be used by me, the user. And we'll get into that a little bit of a discussion there to determine what maintenance needs to be done. So I'm going to take a look at the hour meter. And I'm going to take a look at what's been happening inside the plant throughout the operating year. And then I'm going to discuss these issues with the service contractor. And we're going to come up with a plan that is going to hopefully correct anything that is starting to shift out of the normal parameters. And that may require parts to be replaced or equipment to be replaced. So ultimately, that's what that detailed data is required, or by usually the user. Now, the issue that we're trying to work our way through here is that if you take a look at the operating engineer regulation, it basically says that the only people that can make entries in the logbook are certified staff, the chief certified staff, or those that are recognized by the chief. There's no discussion about unattended plants. So in the operating engineer regulation that basically states that the only people that can make entries into a logbook are our people that are certified. So there's a little bit of a tweaking here that we're working with TSSA to get clarification on. And that's not to suggest you shouldn't stop making a logbook entries. We're going to work with TSSA to make sure that we have what are considered to be best practices as we move along here. So the logbook is a records of how the plant, in fact is being operated and maintained. We often get into this mindset with blinders on that we're collecting data for a governing agency, as I said in my opening comments, and we really need to get away from that. And we need to focus on that the reason that we're collecting this information is in fact so that we can have the correct maintenance plans in place. So we did go through and we've made what we consider to be some recommendations for you to basically set out how data will be collected in your refrigeration plant room, we have several documents that are both in the resource library on supplementary logs and, and logbooks. And then we put out a piece of Technical Corner that talks about additional things that you need to take a look at. Now one of the things that we're asking TSSA to assist us with is to reconfirm our understanding of who the primary stakeholders are when it comes to unattended refrigeration plants. So we have a data document from 2015, from a past TSSA chief operator who provided us with some direction on regards to who he thought would be perceived to be the owner of an unattended plant. And that was basically a CAO Sand a mayor. And but we've come up against some questions that we're currently investigating. Because underneath the municipal act, so we understand is that the accountability to elected officials may be limited under this piece of legislation. So we're gonna work our way through the weeds, the one that I am focused in on better understanding, and if you take a look at the operating engineer regulation, specifically for unattended refrigeration plants, the key players are the owner, the user, and the operator. And what we're trying to figure out is who's the user now is the user, hypothetically, a director, for example, because they have control of who gets hired, and that being the finances, they've got control of the finances for the maintenance of the plant? Or is it in fact, a person that has their hand on the suction valve for an example that, in fact, would be in the plant operating on a day to day basis. So we're asking TSA for a little bit better clarification. And then ultimately, we'll have a better understanding of how we can design our training programs to better reflect a common message that is coming both from the ORFA and TSSA, so don't go changing too much of what you're doing. But I would encourage you to take a look at Technical Corner, a history of ice sheet refrigeration plant logbooks, because in there, we've got what I consider to be a blend of information that is currently available in the operating engineer regulation. And then what we've done is we've added in red font items that we have had as industry best practices for many years and had them through our training programs so that you can evaluate how in fact you are running your refrigeration plant. So I think that's a great note to end on is that it is your plant, it is your responsibility. All we tried to do here at the ORFA is give you in North Star of what other members are focused on what we understand what our conversations are with those that are primary governing stakeholders. And then we try and give you all the parts to build your own rocket ship to get to that North Star. So in the end, it comes down to the primary stakeholders of every operation to ensure that they are in fact going to be compliant. So I invite you to stay tuned through E News and other communications that the association is always putting out in respect to our efforts to assist you on your day to day activities. And until then, stay safe, and we'll chat again real soon.