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Logbook request, an unqualified apprentice and an overdue TSSA order

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Logbook request, an unqualified apprentice and an overdue TSSA order

On a Sunday at a cold-storage facility, the shift operator holds a Refrigeration Operator certificate and is the only certificate holder on site; the chief engineer is on vacation for two weeks. The plant serves a -25 °C freezer and a 2 °C cooler. Three things land on the operator in one shift. The facility manager asks them to 'fill in and initial' the plant log for Thursday to Saturday, which are blank, so that 'the inspector doesn't flag us.' A contractor has sent an apprentice, alone, to replace a leaking liquid-line solenoid and then re-insulate; the apprentice has no refrigerant-handling certificate and no supervision on site. On the machine room wall there is a TSSA inspection order dated six weeks ago requiring replacement of a relief valve on the high-pressure receiver by a date that has already passed; the relief valve is still the original, and it is the same valve that is now passing slightly.

1. How do you handle the logbook request, and why?

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Refuse, and say why in one sentence. The operating record is the evidence that the plant was operated and monitored by a certificated person; it is what the inspector, the owner and the insurer rely on. Signing another person's entries, or inventing readings for hours you were not there, is falsification of a record - a regulatory offence and a dismissal-level breach - and it erases the only trace of whatever actually happened on those days.

What is legitimate: make one dated entry in your own name stating that you were not on shift for Thursday to Saturday, that the pages were found blank, and the readings you actually took on your shift. Then tell the chief engineer and the owner in writing that the record has a gap that they must account for.

The regulation requires operating records to be kept and produced to a TSSA inspector. A documented gap is a compliance problem to be fixed; a falsified record is misconduct. The same logic applies to any log entry you are asked to make about a safety-device test you did not perform.

2. How do you handle the apprentice and the solenoid replacement?

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Stop the work until the conditions are right. The certificate holder on shift is responsible for the plant, and work on a live refrigerant circuit cannot be supervised from the office.

Replacing a liquid-line solenoid means pumping down and isolating that section, and recovering or containing the refrigerant rather than venting it - venting a halocarbon is prohibited, and ammonia must be handled as a toxic gas. It requires halocarbon-handling certification under Ontario's ODS/halocarbon regulation, plus a qualified technician, hot-work controls and a fire watch if brazing is involved. An unsupervised apprentice with no certificate satisfies none of those conditions.

So: refuse entry to the plant room, call the contractor and require a certified technician plus a written work procedure, and log the refusal and the reason. If the leak is minor and the plant is stable, defer the repair to a properly staffed call-out; if the leak is significant, it becomes the priority for a qualified crew - but it is still not a job for an unsupervised apprentice.

3. What do you do about the overdue TSSA order and the passing relief valve?

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A TSSA order is not advice. The owner is legally required to comply by the stated date, and the operator's job is to make sure the owner cannot claim ignorance: send written notice that the order is overdue, that the relief valve named in it is the same one now passing, and what the risk is. Escalate - if the owner does nothing, report it to TSSA.

Meanwhile protect the plant. The passing relief valve is a live defect in the high-side overpressure protection: reduce the receiver's liquid level and pressure, watch the machine room detector, keep ventilation running, and do not operate in a way that leans on that valve - no raising cut-out settings to get through the week.

The replacement must be a certified relief valve of the correct capacity and set pressure for the receiver's MAWP, installed by qualified personnel with the section isolated and depressurised, and its completion reported to TSSA and recorded against the order number in the plant records.