NOTICE TO ONTARIO FARMERS
This is a public service announcement.
The Honourable Minister of Government and Consumer Services has revoked exemption for agricultural purposes the compliance of boilers, pressure vessels and pressure piping to the Ontario Regulation 220/01 (Boilers and Pressure Vessel).
REVOCATION of the AGRICULTURAL PRESSURE EQUIPMENT EXEMPTION means better safety oversight of farmers, but could also be somewhat disruptive to normal routine. This article is intended to help understand the ramifications of this regulatory application to farmers.
Who is impacted?
Owners and operators of agricultural operations that use boilers, pressure vessels or pressure equipment.
What is the impact on farmers and agricultural operations?
The first impact is billable inspections by the TSSA.org which should be minimized. The second impact is that owners of pressure equipment for agricultural purposes need to provide engineering data to the TSSA.org in writing by 1 March 2021 that includes:
– Number of steam boilers operating above 15 psi (atmospheric pressure).
– Number of steam boilers operating at or below atmospheric pressure and water boilers.
– number of refrigeration systems using ammonia, carbon dioxide or other refrigerant than Group A1 refrigerants.
– List of all other types of pressure equipment
Will it cost money?
Yes. The TSSA may use the March 1st, 2021 list as a guide to conduct billable and on-sight audits, and say as much in their notice. Auditors have the powers and potential to temporarily shut down pressure equipment operations (within TSSA defined timeframes and within regulated codes and standards) if certain technical requirements cannot be demonstrated to be met or hazards are deemed present by the inspectors. Of course such situations are few and far between, however, it would pay off to do a bit of house keeping before the inspection day. The hope is auditors will be professional and expedient, and there is little reason to doubt this. However, make no mistake and be prepared…its an audit after all.
Therefore, the impact to farmers of the revocation of exemption from Canadian Registration Number requirements has possible potential consequences to farmer’s and agricultural operation continuity.
Is this really that complicated?
It doesn’t have to be. Depending upon your level of knowledge this could be a proverbial piece of cake. However, not all farmers are versed in, for example, refrigeration pressure equipment falling under ASME B31.5 that operates over 11 KW and may need registrations with a CRN per O.REG.220 because “(i) a refrigeration piping that has a capacity of three tons (11 kW) or less of refrigeration or a capacity of five tons (18 kW) or less of refrigeration in an air conditioning system”. We suggest that you google O.REG.220 and find out for your self the exemptions and requirements for this province for registration of piping systems, pressure vessels, fittings and boilers.
There are many other such exemptions found not only in O.REG.220 but in CSA B51 – 2014, TSSA Director’s Orders, TSSA Code Adoption Documents, TSSA Notices etc. Ask the TSSA, or contact us and we could help.
Should I consult a professional first?
As a professional organization accustomed to pressure equipment design, and as a member of ASME committees, we recommend consultation. But that is a little biased. With some work you too could prepare for the audits and submit your non-exempt equipment list by March 1st to TSSA. It is our opinion however, that reporting is nothing to leave to chance, and it is certainly a good idea to get advice from professionals in pressure equipment design prior to contacting the TSSA while keeping in mind TSSA deadlines. It is therefore recommend that a professional pre-assessment of your pressure equipment be conducted before providing ANY information to the TSSA well before March 1 2021. The way the info is presented to the TSSA and what is included or excluded could mean the difference between an easy experience or a difficult one.
What else should I consider?
What should also be noted is that if there is not a CRN on pressure equipment such as boilers, pressure vessels, pressure piping and its fittings (which include not only pipe fittings but instrumentation, valves heat exchangers, steam traps etc), you may be asked to obtain CRN, which is at present a lengthy and time consuming process due to long back-logs at the TSSA due to Covid restrictions.
Titan Research Group’s quick pre-assessment program aims to reduce your risk to minimize your cost and to maximize the benefit acquired from this process by demonstrating readiness and awareness of Ontario’s pressure equipment regulations. Our company has been helping manufacturers and owners obtain and renew Canadian Registration Numbers for over 14 years. We are here to help. Contact us for a free initial consultation.