What We Heard Report: Secondary Coolant Systems (Draft Directive)

Introduction

From Wednesday, August 13, through Friday, September 12, 2025, Technical Safety BC (TSBC) engaged with boiler, pressure vessel, and refrigeration (BPVR) owners and operators on a draft directive to clarify requirements for secondary coolant systems. This draft directive replaces a previous safety order for ammonia systems by expanding the requirements for periodically testing the secondary coolant in existing refrigeration systems and providing a method for preventing overpressurization in new systems. This report summarizes the feedback we heard about the draft directive on secondary coolant systems, and our response to the major comment themes.

Outreach and Participation

We emailed over 900 BPVR chief engineers, owners, operators, and representative industry associations to invite them to participate in the consultation. We invited participants to read a draft version of the Secondary Coolant Systems directive on TSBC's Engage site.

Participants responded to an online survey asking about the readability of the draft directive, and their facility’s ability to follow the new requirements. In total, 45 participants provided feedback during the consultation period.

Feedback method	Participants
Survey	40
Email	4
Phone call	1

Note: This table counts the number of participants in each method, regardless of whether they participated through multiple feedback methods.

Participant Types

The intended participants for this consultation were operators and chief engineers of refrigeration plants using secondary coolant, as they would be most impacted by this draft directive. In total, 23 operators and chief engineers participated in this consultation. This table shows how many of each participant type provided feedback during the consultation period.

Participant type	Participants
Chief engineer or operator	23
Operations manager or supervisor	8
Owner	2
Industry association representative	6
Other*	7
Total	45

Note: “Other” includes retirees, HVAC building operators, contractors, technical compliance directors

Most participants work at refrigeration plants using B2 or B2L type refrigerants. This table shows the refrigerant types that survey participants reported were used at their plant.

Refrigerant type	Participants
A1	7
A2L	2
A2L	2
A3	0
B1	1
B2L (including ammonia)	24
B2	27
B3	0
Multiple types	3
I'm not sure/I don't know	7
Total	40

Question: Which refrigerant types are in use at your plant? Select all that apply.

Feedback

In addition to responding to the survey questions, participants provided feedback on the concerns and questions they had about following the requirements in the draft directive.

Ability to Meet Requirements

Most survey participants (86%) agreed they could, or somewhat could, meet the requirements in the draft directive.

Response	Participants	Percentage
Yes	29	73%
Somewhat	5	13%
Not at all	0	0%
I'm not sure	6	15%
Total	40	100%

Question: Do you believe your refrigeration plant will be able to meet the requirements in the draft directive? (i.e., testing requirements, procedural and documentation requirements, reporting incidents, etc.)

Comment themes:

Current practices. Most facilities already follow the requirements in the draft directive, especially those using ammonia. Further clarification is needed to specify that these requirements now apply to all refrigerant types.
Industry interest. Refrigeration contractors and mechanics are interested in helping facilities comply with this directive because it generates revenue for them.
Regulatory burden. Some view the regulatory requirements as excessive paperwork and burdensome, especially for businesses and municipalities.

Our response

The requirements in this directive are based on the nationally published CSA B52 standard, which is adopted in BC and many other jurisdictions. We issued Safety Order SO-BP 2021-01: Secondary Coolant, which applied only to ammonia refrigeration systems. The code requirements and this directive apply to secondary coolant systems using all refrigerant types.

Reasonability of Timeframe for Keeping Records

Most survey participants (80%) felt that keeping secondary coolant testing records for 7 years is reasonable.

Response	Participants	Percentage
Yes, 7 years is reasonable.	32	80%
No, 7 years is not long enough.	1	3%
No, 7 years is too long.	7	18%
Total	40	100%

Question: Do you believe the timeframe indicated (7 years) to keep certain records is reasonable?

Comment themes:

Reasonable. A seven-year retention period for certain records is reasonable, especially when key personnel (e.g. Chief Engineer) leave.
Not long enough. Records should be kept until system turnaround.
Photo documentation. Visual and written records can be kept digitally for learning and accountability.

Our response

Owners can still retain the records for periods longer than seven years. The minimum requirement is seven years, according to the Power Engineers, Boiler, Pressure Vessel, and Refrigeration Safety Regulation (PEBPVRSR), section 72(1). Keeping records for this time period can show the maintenance history and operating condition of the secondary coolant system.

Suggestions for Additional Testing and Procedures

Some survey participants suggested other procedures and tests that would lessen the risk of human error more effectively than secondary coolant testing.

Comment themes:

Lockout procedures. Secondary coolant systems can be safely managed with approved lockout procedures, especially during servicing. For example, a standard operating procedure for valve positions and system isolation for expansion tanks.
PH monitoring. Active pH monitoring in ammonia brine systems can detect hazards early and is worth the added cost.
Testing standards. Testing should be conducted and reported by certified third-party companies.

Our response

Facility owners may use lockout procedures (valve management systems) as their overpressurization protection method for their secondary coolant system. Facility owners, chief engineers, and other duty holders must select an overpressurization protection method and submit to TSBC during design registration, according to this directive and CSA B52:23 standard, clause 5.13.

Monitoring the pH level of secondary coolant systems can detect refrigerant leaks early, but it is not reliable enough on its own. Other factors may change the pH level of a secondary coolant, such as water quality, absorption of CO2 from the surrounding air, or corrosion. The addition of corrosion inhibitors such as caustic soda, a pH control additive, can counteract the changes in pH level caused by a leak and mask the presence of ammonia. Therefore, ammonia refrigeration plants with active pH monitoring still must conduct the tests described in this directive to detect presence and/or change of refrigerant ppm level.

Conducting secondary coolant tests is not regulated work and therefore this directive does not specify who can perform the testing. For test results with normal condition outcomes, there is no need for immediate reporting to TSBC, as the system is operating normally. If the testing detects a leak, the directive requires test results to be reported to TSBC as an incident. Regardless of outcome, facility owners must keep the records for seven years, available for safety officers during audits and inspections.

Considerations for Aging Systems

Some survey participants expressed concerns about factors that can prematurely age refrigeration systems and need to replace or retrofit the systems.

Comment themes:

Increased demand. Older systems (e.g., installed in 1990) are under stress due to climate change and increased demand.
Corrosion. Corrosion from secondary refrigerants may compromise relief valve effectiveness.
Refrigerant phase-out. R-22 is no longer obtainable, prompting the need for major retrofits.

Our response

The CSA B52 standard and this directive set the minimum requirements for design and testing. Facility owners, chief engineers, and other duty holders may choose to use multiple methods to address overpressurization in secondary coolant systems. Likewise, the owners of refrigeration plants may decide to test their secondary coolant more frequently. A TSBC safety officer may also require more frequent testing.

Determining an overpressurization prevention method only applies to newly installed refrigeration systems of any refrigerant type. All existing ammonia systems should have already addressed the overpressurization requirements through safety order Safety Order SO-BP 2021-01: Secondary Coolant.

Next Steps

The feedback we received during this consultation helps us to identify where we need to adjust our approach and clarify our language. We will publish the final version of the directive on Secondary Coolant Systems in the coming months.