Training on Ammonia Systems Keeps Employees and Facilities Safe
“Training is everything. Without a great training program, you’re asking for trouble,” said Aaron Christopherson, EHS manager at E. & J. Gallo Winery.
Christopherson added that in addition to improving safety, providing training can increase retention because it creates a career path for employees and an opportunity to advance. “As they get more education and certifications, they get higher pay as well,” Christopherson said. “Somebody said, ‘What if we train people and they leave?’ There is a risk with that, but what if we don’t train them and they stay?”
The level of training employees need varies based on their work, and there are several resources to ensure all workers get the training they need, including bringing training providers onsite, sending employees to classes, developing in-house programs or tapping into online programs.
ESTABLISHING GOALS
Training aims to improve an employee’s capability, capacity, productivity, safety and performance, explained Jeremy Williams, owner of Ammonia Refrigeration Training Solutions (ARTS), which provides industrial refrigeration training throughout the United States.
To help ensure success, goals and objectives should be tailored to the specific training modules or segments. “Employers should describe the important actions and conditions under which the employee will demonstrate competence or knowledge as well as what is acceptable performance,” Williams said, adding that learning goals and objectives should be measurable before the training begins.
CREATING AWARENESS
Anybody who steps foot in a facility with ammonia should receive awareness training. This includes new hires, all employees and all visitors. “It covers the general characteristics of ammonia, including the hazards, the location(s) where ammonia is handled at that facility, and what to do if there is an emergency, for example, if you smell ammonia,” said Peter Jordan, principal engineer at MBD Risk Management Services.
Because the awareness training is general, Peter Thomas, president of Resource Compliance Inc., said it can be provided onsite or through an online course.
DIGGING DEEPER
Employees who operate or maintain a refrigeration system need more advanced training on system operating and maintenance procedures, such as how to stop and start equipment. Employees need to know how to do their jobs safely, and the amount of training they require can vary depending on their tasks. “There are things more senior operators need that junior operators don’t and that can change over time,” said Stephanie Smith, principal engineer, Risk Management Professionals.
Management decides who receives more advanced training, but Williams said it can be useful for any worker that could affect the refrigeration system. “This can range from roundsman, operators, mechanics, technicians, electricians, contractors, engineers and various management roles,” he said.
E. & J. Gallo Winery has two primary teams working with ammonia—chiller operators who run and monitor chillers when they’re running and refrigeration mechanics who are full operators. Anybody who will be on or near ammonia assets receives the Refrigerating Engineers & Technicians Association’s (RETA’s) Industrial Refrigeration I training. “That is ammonia theory. Once they’ve completed that course successfully, they can start the on-the-job training,” Christopherson said.
The on-the-job training covers E.& J. Gallo Winery’s equipment and how to apply ammonia to the company’s processes. “We have an in-house program that talks about how we do ammonia,” Christopherson said. “Then you can go out and work with your trainer to learn more.” Employees have a list of things they have to check off before they work on their own.
Mechanics go through the same process but already have a maintenance background. “They know how to work on pumps, motors and seals. They need the Book I training. Once they’ve had that, they can start going out with somebody and get into the refrigeration mechanic training program,” Christopherson said.
Operators and mechanics eventually move on to RETA’s Industrial Refrigeration II training. Operators and backup operators also complete Certified Assistant Refrigeration Operator training, and mechanics can compete in Certified Industrial Refrigeration Operator training. “The bottom line is if you touch ammonia once a year or every single day, you carry the same risk. There is no difference,” Christopherson said.
Training requirements apply to contractors as well. If contractors perform the work of an operator mechanic, they need to be trained like an operator mechanic. Training should include information on what they can access and safety practices, including lock-out/ tag-out procedures. “Either you give it to them, or their company gives it to them,” Jordan said.
GETTING SITE SPECIFIC
Every ammonia refrigeration system is a little different, and some of the most essential training is facility-specific training that highlights the company’s procedures and processes. Anyone working with equipment needs training on site-specific operating procedures, such as start-up, shut-down and maintenance.
“All operators and all mechanics don’t have to be trained on all procedures, but they need to be trained on any tasks they would perform,” Jordan said.
PREPARING FOR EMERGENCIES
Emergency response planning needs to be done to comply with the Hazardous Waste Operations & Emergency Response (HAZWOPER) standard, which Jordan said contains different requirements than operator training. Facilities must decide whether to train first responders at the operations and technician levels.
“First responder operations level are individuals who respond defensively to an ammonia release,” Jordan explained. “They go to the system where there could be a release and verify there has been a release but don’t expose themselves to a level of danger. They contain it from a safe distance.”
It requires eight hours of initial training and then refresher training once a year. “It is unspecified how long the refresher has to be,” Jordan said.
HAZWOPER technician-level training allows responders to go in with personal protective equipment. “The training requirements are 24 hours of initial training and eight hours of refresher training after that,” Jordan explained.
Facilities must also train incident commanders, who receive additional training and have the ability to devise and implement company, local and state emergency response procedures and plans.
COMPLYING WITH REGULATORY REQUIREMENTS
Regulatory requirements dictate some training needs. “The tricky thing with regulations is they don’t tell you what you need. They just tell you that you have to have it,” Smith said. “It is an open book because every facility is different, but there are basics.”
Jordan said OSHA’s PSM Standard and EPA’s RMP regulation have specific requirements for operator training. To comply with PSM/RMP requirements, operator training must be conducted once every three years but can be done more frequently. The PSM/RMP regulations require facilities to ask employees how often they want training repeated. “If most say every three years, that is okay. If the majority say they want it more often, for example, once a year, then annual training should be conducted.”
Most ammonia facilities with under 10,000 pounds of refrigerant are not subject to PSM/RPM, you’re under general duty clause, and we have an Ammonia Refrigeration Management program,” Jordan said. Under ARM, training doesn’t have specific time requirements.
Seasonal facilities that shut down or are drastically reduced during the off-season should consider holding refresher training for all employees when the season ramps up. “I work with agricultural clients where some of the labor force is seasonal, and there is a lot of turnover from one year to another. It almost makes sense to do it annually,” Thomas said.
MEETING EMPLOYEES NEEDS
Williams said everyone learns differently, and an effective training program will allow employees to fully participate in the training process and practice their skills or knowledge. “A properly conducted training program will ensure comprehension and understanding. It is not sufficient to either just read material to workers or simply hand them material to read,” he said.
Hands-on training where employees can use their senses beyond listening can enhance learning. “Hands-on can both be in the classroom with cut-aways and in the field,” Williams said.
Differing teaching methods can help engage employees with different learning styles. “It is important that people are sensitive to that and avoid death by PowerPoint or doing video series after video series,” Thomas said. “The online videos have improved efficiency, but the downside is they can become boring, routine, or people are unengaged. The name of the game is engagement.”
Smith noted that some people are visual learners while others are verbal learners. “A presentation can be helpful because you’re combining verbal with visual,” she said, adding that since comprehension is critical, facilities may need to offer training in multiple languages.
If someone is working around a system and doesn’t understand the training, the supervisor must make time to re-do it, re-verify it, or figure out where the gaps are. “Taking the time to do that is better than having an incident,” Smith said, adding that after an incident or near miss, part of the investigation should focus on procedures and whether they’re adequate. “That is an opportunity to look at training.”
The PSM/RMP regulations require facilities to verify that operators understood the training, which can be done through testing. “It could be written testing, which is what many people do because it is easy and defendable, oral or demonstration. You have to document how you tested and how they scored,” Jordan said.
INSOURCING VS. OUTSOURCING
There are several training resources available to facilities. “There are some trainings that are perfectly fine to outsource. Anything facility-specific—operating procedures and emergency drills— should be done by internal staff,” Smith said, adding that the exception would be if the contractor has extensive knowledge of the system or helped write the emergency plan.
Thomas said there are several good hands-on training schools. “You could invest some money, get on a plane, get a hotel and take a week-long course. Those can be helpful, but the downside is they are expensive, and you must travel unless you’re near one,” he explained.
Bringing trainers onsite is more costeffective when multiple employees need training. “If you’re considering sending five people away to become trained, it might be more effective to bring that training to you. Then you can even get hands-on training for your system,” Thomas said.
ARTS has both online options to develop employees’ skills and knowledge in specific useful competencies, and its most popular courses are ammonia refrigeration safety, introduction to ammonia refrigeration, PSM/RMP, ammonia operator 1, and ammonia operator 2.
Christopherson takes a multi-pronged approach, tapping into outside training, industry experts, and the company’s internal resources. EJ Gallo has an inhouse training department that works with subject matter experts to create its onsite training. “You get everything on paper and train everybody to that standard. It comes with operating procedures, work instruction and job instruction.”
The type of training locations used often varies in size and breadth. “The larger, more experienced the facility, the more they can take on internally. Smaller operations rely on outside trainers more,” Jordan said.
No matter what, facilities should be wary of training where the majority of time isn’t spent on the actual training. “That can happen at trade shows or sometimes safety days. I love both of those, but an employer might think they’re sending an employee to a week-long trade show for training, but they need to make sure they’re going to the sessions rather than taking a day off of work,” Thomas said. “That can be validated by making them bring back documentation that they did attend the session.”
FINDING TRAINERS
Locations seeking training resources should get recommendations from someone they trust. “You want someone who specializes in refrigeration, but at some point, you have to bite the bullet and bring them in to try them out,” Jordan said.
Williams said that just because someone is educated, credentialed or experienced doesn’t mean the person is an effective trainer. Instructors must demonstrate competent instructional skills and knowledge of the applicable subject matter.
KEEPING TRACK
Training needs to be documented, and facilities are required to keep records. “If it wasn’t documented, it did not happen,” Thomas said.
Records should include the name of the training or the topic, the duration, the names of all the people who participated in the training, the trainer’s name, and the means used to verify that the training was understood. Facilities could go further and have employees sign paperwork confirming they completed the training. “The law doesn’t prescribe the employees have to sign it, but there is better credibility if that is the case,” Thomas said.
Often, with training, people just miss it. “It has to be every three years, but some should be done more often, and that is when you start losing track of what is needed when,” Smith said. “It has gotten better with databases and software to track training. It makes sure training is consistent.”
Tracking training doesn’t have to be complicated. “The most difficult part is making sure the deadlines are met for each person and keeping the records,” Smith said.
LOOKING AHEAD
Training may also extend beyond ammonia as more and more natural refrigerants are adopted.
“CO2 and hydrocarbons aren’t covered by PSM, but you could make the case that training needs are even greater because there are fewer trained people in the technologies, and the history and institutional knowledge isn’t there,” Thomas said. “I think there will be a huge opportunity to fill that void for other natural refrigerants.”
