Industry co-operation has set a high bar for anhydrous ammonia stewardship.
As anybody involved in agriculture knows, anhydrous ammonia (NH3) is classified as a Dangerous Good – and with good reason.
According to the Canadian Centre for Occupational Health and Safety, exposure to anhydrous ammonia can irritate and burn the throat, lungs and eyes. Very high levels of ammonia exposure can damage the lungs and may even cause death.
The risks of anhydrous ammonia were displayed prominently on April 25 of this year, when a leak in the Chicago suburb of Beach Park, Illinois, sent nearly 40 individuals, some of them first responders, to hospital.
The incident made headlines across numerous U.S. news outlets. According to multiple sources, a plume of ammonia gas began to leak from one of two nurse tanks being towed by a tractor at approximately 4:25 a.m. The Centre for Disease Control issued an air quality warning and residents within a one-mile radius were instructed to stay inside their homes with AC systems off and windows tightly sealed.
The leak was contained by approximately 9 a.m., and around noon on that same day, the local sheriff’s office tweeted that seven of the individuals taken to hospital were in critical (but stable) condition, and that a total of 11 firefighters and three police officers were hospitalized.
Agriculture is a tightly-knit community and when a serious incident like this happens, whether it is here at home or south of the border, it resonates with everybody.
In the wake of this event, some people may be wondering, “Could this happen in Canada?” While no one can answer this question with complete certainty, individual companies, from the manufacturing level down to the retail and farm level, and industry associations like CAAR and Fertilizer Canada, are all actively engaged to ensure the safe handling, transport and application of this important product that Canadian farmers rely on.
Developing a Code of Practice
“In Canada, our regulations are amongst the world’s most stringent,” says Catherine King, vice president of public affairs with Fertilizer Canada. “There are also industry standards for fertilizer safety and security, which include an audited industry code of practice for anhydrous ammonia.”
The code that King is referring to is Fertilizer Canada’s Ammonia Code of Practice. The Code is a living document, updated on a five-year cycle, complementing legal regulations and standards. The Code outlines how ag retailers can meet regulatory requirements and includes industry best practices that go above and beyond minimum regulatory requirements.
The code, which was first released in 2009, was developed with input from stakeholders across the fertilizer supply chain and government regulators, among others with a vested interest.
Tom Hutcheson, safety manager with Koch Fertilizer Canada, was involved in the original drafting of the Ammonia Code of Practice. The draft was put together by a subgroup of the Fertilizer Safety and Security Council, which was operating then through the Canadian Fertilizer Institute, now Fertilizer Canada.
At the time, Hutcheson says the council viewed the idea to adopt and implement an industry code of best practices for handling and storing anhydrous both as an opportunity for their industry and a crucial necessity.
“Quite a number of years ago, our industry was facing an increasing number of negative events that were garnering more and more public attention from our customers, our owners and with regulators,” says Hutcheson.
Hutcheson says that the Council saw the need to intervene on the industry’s behalf to improve anhydrous ammonia stewardship, and they began to work toward what would become the Ammonia Code of Practice as it is known today.
“We looked at the situation as an opportunity for us to get involved in stewardship to the point where we would develop and enforce a compliance framework that would allow us to keep our industry safe,” says Hutcheson. “We wanted a framework that regulators could not only live with for the present, but one that could evolve over time.”
Gaining Regulators’ Confidence
Since 2009, Hutcheson says the code has grown to become the accepted industry practice across Canada, supporting the strong regulations set by government to keep everybody safe. As the first working group had hoped, regulators continue to have confidence in the code’s ability to help the industry meet legal regulatory requirements and keep anhydrous ammonia moving safely to Canadian farmers.
“We’ve earned regulators’ trust to self-manage the safety aspects of our industry internally,” says Hutcheson. “Our solutions have been developed by those of us who truly understand the ammonia business and have a vested interest in its safe operation. That is a real success story.”
We’ve earned regulators’ trust to self-manage the safety aspects of our industry internally.
The Ammonia Code of Practice supports the industry’s ability to meet Transportation of Dangerous Goods (TDG) regulations which govern the sale and transportation of ammonia. TDG regulations include requirements like minimum training standards and up-to-date placards for ammonia tanks, and mandates that companies that transport ammonia must develop an Emergency Response Assistance Plan (ERAP) documenting what actions they will take in the event of an ammonia incident.
TDG regulations also specify that all anhydrous ammonia tanks must meet the Canadian Standards Association’s (CSA) B620/B622 Standards, which outline the design, construction, inspection, testing and maintenance of all ammonia tanks, including nurse tanks, highway tanks and field delivery units.
Today, each level of the industry plays a vital role and is actively engaged with anhydrous ammonia stewardship. Activities include leading emergency response training for staff and first responders, engaging on industry councils, supporting the Ammonia Code of Practice and providing training to keep all nurse tanks and related equipment working properly to keep users safe.
Central to keeping employees and communities safe is the level of co-operative and shared responsibility the industry has established. One example of this is the Mutual Aid Agreement between manufacturers, created to satisfy ERAP timing requirements, by responding on each other’s behalf if one company can make it to an incident location more quickly. Often, manufacturers also have agreements to support retailers as a part of the retail company’s ERAP.
Nutrien’s senior manager for product stewardship, Jim Jenkins, says that Nutrien’s team of trained emergency response experts have a strong track record of responding to and resolving incidents, whether responding on behalf of their own company or providing assistance to another through mutual aid.
Jenkins says as part of their product stewardship efforts, Nutrien provides a 24/7 product hotline that anyone can call to get an answer from a real person. Sometimes staff can provide instruction to help farmers work through a situation and can gauge if an incident is getting out of hand.
“Maybe it’s a circumstance where a farmer says, ‘I’m applying my ammonia and I haven’t seen this before,’” says Jenkins. “We can give them some technical advice, and everything gets resolved. Or maybe it’s a bigger incident and depending on what it is, that will dictate the level of response that our team provides.”
Jenkins says Nutrien’s response team is made up of 40 to 50 individuals across each of their four NH3 plants who are trained in emergency response on top of their regular roles. The company hosts training for these teams on an annual basis.
“We have a large training simulation approximately once a year with 40 to 50 people,” says Jenkins. “Often, Transport Canada representatives come out to observe that training to get a little more familiar with it, so we see that as a success.”
Along with the extensive actions manufacturers take to ensure the safe handling of product within their plants, they also work to ensure first responders in local communities understand the risks should an incident ever occur.
“At the time we were drafting the original code of practice, one issue that first responders were dealing with was product recognition,” says Hutcheson. “We had ongoing dialogue with the Canadian Association of Fire Chiefs and the Canadian Association of Chiefs of Police, and we agreed that there was a need for emergency responders to have credible information about ammonia.”
Hutcheson says manufacturers developed a program to improve product knowledge among firefighters and police chiefs. To this day, manufacturing companies also provide first responder training. For example, Koch runs an annual session with live product, where multiple municipal fire departments practice a response using the equipment they possess.
Leaving How You Arrived
As anhydrous ammonia moves through its lifecycle, manufacturers continue to support stewardship and, according to Jenkins, the Ammonia Code of Practice provides an additional level of assurance that ag retail sites are meeting their regulatory requirements.
As part of the code, ammonia manufacturers and suppliers will only deliver product to retail facilities that are certified as compliant with the code. Retail facilities must be audited by independent auditors every two years to remain in compliance.
Mark Coppicus, agro regulatory and safety manager with Federated Co-operatives Limited (FCL), has been in the industry for nearly 40 years and is a self-described huge supporter of the ammonia code. Coppicus’s department participates with Fertilizer Canada’s Ammonia Code, The Fertilizer Safety and Security Council and the CAAR Nurse Tank Safety Council.
“Before the Code, I was pushing for change on ammonia safety. I want everyone who handles this product to go home to their families every night the same way they arrived at work that morning,” says Coppicus. “I think anything we can do to support continuous improvement in this area will make sure this product is there for farmers and everybody is safely handling it.”
Coppicus oversees development of the numerous training programs that FCL provides to co-op agro centres. He notes that FCL plays an advisory role, and co-ops are not obligated to take part in their training – but he adds that the vast majority do. One program FCL offers is emergency response training to both retail employees and first responders using live product.
“We have a recommended list of equipment for retails to purchase,” says Coppicus. “It’s a two-day training session and we go through techniques with anhydrous ammonia and all different types of scenarios. Quite frequently, local first responders will come out and work through that with us.”
Coppicus says their training covers how local retailers and responders can handle small to medium incidents themselves and manage larger situations until ERAP partners can arrive. Many co-op staff members who are trained to handle incidents also have ties to community volunteer fire departments. This crossover is one way that the training FCL provides extends beyond co-op retails.
“I am so proud of our retails for their proactive attitude and way of thinking,” says Coppicus. “They’re inviting us to come out and train their people. Our retails wouldn’t have to do anything special and they would still be in compliance, but they choose to go above and beyond.”
They wouldn’t have to do anything special and they would still be in compliance, but they choose to go above and beyond.
Jeff Kisiloski, director of environment, health and safety (EHS) with Richardson International Ltd., has worked with anhydrous ammonia or in an adjacent role for the past 20 years, including seven years with CAAR. During his time with CAAR, Kisiloski worked to develop the original versions of CAAR’s ammonia safety training resources and he has witnessed how regulations have evolved, and become more stringent, in the past two decades. In his current position, Kisiloski and his colleagues work to develop health and safety solutions for employees that complement regulatory requirements.
“Our internal programs and systems complement the already stringent focus regulators have on product safety,” says Kisiloski. “We take a practical approach to assist our personnel in understanding mandatory and corporate expectations for product safety and stewardship, in an operations setting.”
As part of this practical approach, the EHS department provides various training programs and resources to their Richardson Pioneer retail locations that provide a mix of formal, structured training and more informal, day-to-day solutions.
“We do a lot of what I call ‘job observations’ or ‘behaviour-based safety observations’ with employees,” Kisiloski says. “This might be with new employees entering the industry or checking in with more senior employees. It doesn’t matter if you’ve been doing this for 10, 20 or 30 years, you have to make sure that you can demonstrate these practices on a regular basis.”
Like co-ops, Kisiloski says a large percentage of Richardson’s retail locations host emergency training sessions. Kisiloski says these sessions may vary from year-to-year from full simulations to classroom seminars. Along with covering the actual mechanics of a response, Kisiloski says there is a focus on the psychological component.
“We try to make sure people are confident and comfortable talking about what could happen. That helps them focus on what to do and why we do it,” he says. “It comes down to looking at the worst that could happen, and then what can we do to prevent that from ever happening.”
It comes down to looking at the worst that could happen, and then what can we do to prevent that from ever happening.
On top of retailer training, Richardson’s also encourages retailers to discuss anhydrous ammonia stewardship with their customers and provide their customers with resources that are relevant to them.
Kisiloski says the Anhydrous Ammonia Safety and the Farmer training course developed in partnership between CAAR and Fertilizer Canada is the best course in the industry for anhydrous ammonia safety training for farmers.
“We regularly make farmer training available to Richardson Pioneer customers,” says Kisiloski. “That primarily involves getting access to CAAR materials that are available to help farmers satisfy mandatory requirements that they need to follow and abide by when they’re handling this product, per Transport Canada regulations.”
Inspection and Testing
Much like how The Ammonia Code of Practice bars uncertified retailers from receiving shipments of anhydrous ammonia, Brian Downie, Wawanesa branch manager with independent Manitoba retailer Shur-Gro Farm Services, says that Shur-Gro will not deliver anhydrous ammonia to grower customers unless they have completed the Anhydrous Ammonia Safety and the Farmer training course.
“We’re very proactive in that way,” says Downie. “We’ve been using that course with our customers for years and years now. We’re at a point where if farmers don’t take the training, they don’t get the product.”
Shur-Gro has also shown industry leadership by partnering with CAAR multiple times over the years to deliver the association’s on-site Nurse Tank Safety Program training.
This hands-on course covers hydrostatic testing and visual inspection requirements for nurse tanks under the CSA B620/B622 Standards. Retailers must meet inspection and testing standards to keep their fleet of tanks in compliance.
Shur-Gro’s Brandon, Man. location hosted an on-site training session in April of this year. At the end of the training, successful participants received a certification (or re-certification) valid for three years. Downie says hosting this training with CAAR is well worth it to their company, for several reasons.
“It’s very good hands-on training,” says Downie. “Hosting the training provides great value for us to get our personnel trained – and others in the area as well.”
Downie believes by providing an opportunity for other retails in the area to get their employees certified, Shur-Gro is doing something good for the entire industry beyond their own company.
Shur-Gro isn’t an outlier in this way. Looking beyond their own organizations and thinking about the overall health of the industry is something Downie says ag retailers across Canada have embraced, and something he believes they have a responsibility to continue upholding.
Doing a Good Job
Because of the strong regulatory framework in place, and the industry’s world-class record of pioneering stewardship and safety programs to meet and exceed these requirements, anhydrous ammonia is stored, transported and applied safely and effectively. Thanks to Fertilizer Canada’s Ammonia Code of Practice that ag retailers continue to comply with, this product is available to their customers to grow affordable food for the world to eat.
“I think that everybody needs to be involved, and we need to be proactive because we need to make sure this product is available for farmers who need it and it gets to them safely,” says Downie. “Once farmers have made the commitment to use anhydrous, it’s a critical piece of their operation.”
Downie says because it is one of the most economical sources of nitrogen available to farmers, anhydrous ammonia plays a substantial role in maintaining an affordable food supply for everyone.
“We have to make sure we’re doing a proper job and we have good equipment out there on the highways and in fields, so we don’t have issues,” he says. “And the industry is doing that – we’re doing a good job.”
Training the Industry
Manufacturers, suppliers, retailers and industry associations provide numerous training programs to their employees and local first responders. These organizations provide their own variations on the following training topics:
- Emergency Response Training
- “Train the Trainer”
- Nurse Tank Maintenance
- Nurse Tank Inspection and Testing
- Safety and the Farmer
Between the many training programs offered through all levels of the supply chain, over 500 people take some form of anhydrous ammonia stewardship training in Canada every year.
Click here to see training resources for your retail and your farmer customers.
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