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Ensuring safety when there is no standard

January 18, 2017

Adding clarity to regulatory compliance of gas-fired equipment in Canada

Every fall (and spring), as most of us turn our clocks backward (or forward), we do maintenance around our home. We check our smoke detectors, clean our furnace filters and ensure our major appliances, like our water heaters are working. Keeping important equipment serviced and operating safely should always be a priority. But how do you know they are built or installed safely in the first place? Most fuel-related appliances we see at home or at work, such as our furnace and hot water tank are certified to be safe. But for the oil and gas industry, it’s not that straightforward.

Alberta Municipal Affairs is estimating that over 300,000 appliances in Alberta, currently in operation in the Oil and Gas sector, have some sort of non-conformance issue and are not compliant with CSA B149 and the Alberta Gas Code Regulation. So how can we work to solve that and improve safety?

Finding the standard

The term certified is defined as having been investigated and identified by a designated testing organization as conforming to recognized standards, requirements, or accepted test reports. Basically this means that in a controlled environment the appliance, component, accessory or equipment has been tested, often to a point of failure, and proven to meet the requirements set out in a known and accepted standard. The trouble is, much of the specialized equipment used in the oil and gas industry, has no known and accepted standard to test against.

So what do you do if a standard does not exist? Meeting an acceptable minimum set of requirements may still be necessary. In the case of fuel related appliances, like steam generators, heating boilers and even stationary natural gas driven engines (generators and pumps), many of the Authorities Having Jurisdiction (AHJs) across Canada have adopted the B149 series of codes. Specifically, B149.3 (Code for the field approval fuel-related components on appliances and equipment) being important for the approval of any non-certified components or appliances.

In accordance to CSA B149.3, a field approval must be conducted on any new non-certified equipment or when upgrading, modifying, or relocating an existing appliance. Many gas-fired appliances assumed to be certified actually are not based solely on the fact that there is no standard to certify and be listed against. Even though the appliance is constructed using certified components or accessories, the installation is not certified and must be approved in the field.

Oil and gas challenges

In the fields of engineering, design, and operations, owners and designers alike encounter a mountain of specifications and standards on a day to day basis. This can become an overload of information! It is rare to encounter a design, or an installed or operated piece of equipment that is not in compliance with more common codes, such as the Canadian Electrical Code for example. The B149 series of codes are just another set of mandatory guidelines to ensure our designs and installations are safe and efficient. So why are there so many installations that do not meet these minimum requirements?

Specifically, in the Oil and Gas sector, compliance has been a challenge with many of the fuel-related appliances being non-certified, designed to operate with conditions outside the considerations of B149.3 (fuel gas pressures above 0.5 psig, or extreme ambient temperatures for example) and an inventory of existing legacy appliances too large to accommodate immediate compliance. Essentially, the scope of B149.3 is written more so with industrial or commercial applications in mind, and although the designs in the Oil and Gas sector are safe, they are unable to meet compliance due to too prescriptive of an approach.

Help meeting the requirements

By 2020, all non-certified gas-fired appliances must have a current site-specific field approval completed by an approved Certification or Inspection body. This includes all legacy equipment currently without this approval and all new equipment being installed. Without this approval, owners are at risk of strict penalties for any pieces of equipment currently in operation today. There are only five accredited Certification or Inspection bodies approved to operate in the province of Alberta to provide field approval of being compliant to B149.3.

To streamline this process. we’ve joined forces with Underwriters Laboratories of Canada (ULC) to conduct field approvals as per B149.3 and provide the industry with an avenue to make sense of how the extensive list of reference material all ties together. Matching our design, installation, and commissioning of fuel-related appliances expertise with the nearly one hundred years that ULC has been in Canada, developing standards, certifying components and helping clients bring products to market as an accredited Certification Body. Working closely with owners, vendors and installers, this alliance is a solution in taking the confusion out of B149 compliance while keeping safety top of mind.

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