Despite offering strong support to the Technical Standards and Safety Authority (TSSA), Claims Relationship Manager at RSA Canada, Ryan Jones, is concerned by proposed changes to the Boilers and Pressure Vessels Regulation in Ontario for two main reasons.
The current regulation requires the periodic inspection of piping and fittings “at such intervals as are set out in the code adoption document.” However, the code adoption document (CAD) does not set out any intervals. As a result, there is a lack of clarity regarding the requirement for periodic inspection of piping and fittings. To address the lack of clarity regarding periodic inspections of piping and fitting, the TSSA and MGCS have proposed the inspection requirements be eliminating from the regulation, but the panel did not reach consensus on this issue. As a result, two options were recommended to the TSSA and MGCS:
- Option A: Replace the current general requirement for the periodic inspection of piping and fittings with a clause that provides TSSA with the authority to take actions required to ensure the safety of piping and fittings. For example, TSSA would have the authority to require the periodic inspection of certain piping and fittings if there was a safety rationale for doing so. In the longer term, TSSA should work with a standards development organization (SDO) to conduct analysis and develop national standards for high-risk piping and fittings. This would include a definition of what constitutes “high-risk” and requirements for periodic inspection, if they are deemed necessary. If the SDO develops requirements and definitions, TSSA should implement them in Ontario’s code adoption document as mandatory requirements and, if necessary, revise the regulation.
- Option B: Leave the existing general requirement for the periodic inspection of piping and fittings in place until TSSA, working with an SDO, develops a definition of “high-risk” piping and fittings. At that point, defer to SDO guidance on periodic inspection of piping and fittings that are not high-risk, while maintaining the current regulatory requirement for periodic inspection of piping and fittings that are high-risk.
Jones believes the existing general requirement for the periodic inspections should be left in place until the TSSA develops a clear definition of “high-risk” piping and fittings. Jones feels it would be more beneficial to public safety to establish standards to address the increased life safety risk associated with the operation of ‘high-energy-piping’. “We further submit that it would require a formal ‘regulatory change’ (similar to this one), in order to re-establish the inspection requirements which could take years to operationalize,” Jones says.
Although Jones supports many of the administrative changes that were added after the ‘round table’ process, he does not support the following proposed changes:
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