Esac00.doc The Ability to Perform Electrical Work in the Province of British Columbia A Discussion Paper on the definition and regulation of electrical work, and in respect to technical certification and safety responsibility of those intending to perform electrical work Applied Science Technologists and Technicians of BC (ASTTBC) March 14, 2000 (Revised March 29, 2000) The Issue It is a matter of fact that the electrical industry and related technology is a complex work environment requiring substantial theoretical knowledge and a variety of manual skills and experience. The complexity and scope of the work has grown over the years, and in the last 20 years specifically. So much so, that it is virtually impossible for any one worker to become highly proficient in all respects. As electrical equipment is used: a) as a primary energy conversion means, b) as a source of operating power, and c) as a means of controlling most operating equipment, there is significant potential for crossover in technical disciplines. Adding to this phenomenon is the reality that there is significant difference in technology depending on application, size, and voltage level. The trend, then, has been for individual workers to specialize in only a few aspects of the diverse technical spectrum within the electrical industry sector. Irrespective of the trend, the evolution of work specialty has been more a result of practical business development than ability of individuals to develop technical skills. There are many examples of this in the existing restricted certification provisions offered through the Ministry of Municipal Affairs. Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 1 ASTTBC has observed the limitation of the Electrical Safety Regulation in the past, in not recognizing all workers appropriately trained and certified to perform specific electrical work functions. ASTTBC has made numerous submissions to the Electrical Safety Advisory Committee (ESAC), the Electrical Safety Branch, the Industry Training and Apprenticeship Commission (ITAC), and the Ministry of Municipal Affairs in an effort to both explain the gap (the needs in industry) and to provide solutions. Despite these comprehensive submissions, there has been limited progress. In fact, a few modest enhancements, established in the 1996 Regulation, were eliminated from the document by the Branch later in the year. ESAC and ITAC subsequently recommended that the Branch should restore some of the critical enabling language that was removed from the Regulation. ESAC (by virtue of motion at the last ESAC meeting in 1997) advised the Ministry to re-integrate specific language accordingly. No action has taken place. Although some of the issues of concern to ASTTBC were covered off in the draft language, we do not advocate a simple resurrection of this earlier draft. There have been significant changes in our awareness of the needs of industry and, this earlier proposal was incomplete conceptually. We now recommend that complete, new, enabling language be drafted that will assure all those who are trained and competent to perform various aspects of electrical work can do so. The Regulation, and its direction in safety certification, must be modified to enable the workforce and, in so doing, enhance electrical safety in the province. There are several factors that also need to be considered in relation to this issue: 1. Individuals can receive and develop very narrow electrical training and experience, or it can be much broader. In all likelihood, the broader the experience, the less specific knowledge there will be of any one aspect. 2. Irrespective of the breadth of scope of training or work, there would be reasonable expectation that one who is highly skilled in any aspect, would be able to skill transfer with relative ease, and would have a corresponding ability to understand safety, skills, and limitations so as to know where they can perform work safely and where they cannot. 3. Generally, those with a greater theoretical education level will require less hands on experience for the same level of competency from either physical or safety perspectives. 4. Any work activity that requires an individual to touch or manipulate electrical equipment to any degree may constitute electrical work. 5. Where the electrical work requirement is very distinct and a very small component of the work being performed essentially within the purview of another technical discipline, it is likely that the individuals working in the discipline are best suited to perform the electrical work safely. Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 2 6. Individuals who have both a high level of technical education and significant hands on experience are likely to be most adaptable in functioning competently and safely over the widest band of work activities in the electrical sector. 7. Those who hold professional responsibility for electrical installations must have the ability to conduct whatever electrical work they deem necessary for assurance. The issue facing us is the structuring of safety certification of those performing electrical work in the province of BC, in such a way that the workforce is efficiently and effectively enabled. ASTTBC PROPOSALS ASTTBC makes the following proposals for consideration by appropriate regulatory authorities. Proposal No.1 Preface Technologists (AScT) and Technicians (C. Tech) certified in the electrical discipline with ASTTBC generally are trained to perform a variety of electrical work tasks competently as a result of both their training and their experience. While experience and the amount of electrical work performed relative to design, during the course of normal day to day activity, may vary considerably, the knowledge and safety competencies of these skilled individuals is significant and even transferable throughout a number of sub-disciplines. The versatility is enabled through complete understanding of the design, installation, and operation of electrical systems. Technicians tend to spend a higher percentage of time performing electrical work. Technologists perform less electrical work tasks, but have a more complete knowledge of the systems and safety considerations. In any case, both are well capable of performing electrical work tasks, common to their respective jobs, safely. Further, these Technicians and Technologists are well able to test and assess systems, identify and work safely around hazards, and perform electrical work tasks to install, commission, operate and maintain electrical equipment. Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 3 Proposal 1A Both Technicians and Technologists be recognized to perform electrical work functions for which they are trained (exemption for testing, commissioning, servicing, maintenance and repair of electrical equipment). Proposal 1B A recognized “pathway” be defined between Technician/Technologist and Trades Qualification. Comment: Technicians and Technologists do not normally work in electrical construction installation (Commercial, Industrial or Residential); however, they are generally well trained in respect to most of the component systems. There is a real need to provide a career pathway for the Technician/Technologist to achieve qualification as an electrical TQ. The corresponding road from TQ to Electrical Technician already exists. The Electrical Safety Regulation (and its safety certification provisions) must recognize this relationship and assure that it aligns with ITAC strategies and trades training/ certification provisions. Proposal 1C Acknowledgment of the competence of Technologists and Technicians, certified in the electrical discipline, to perform any electrical power “utilization voltage level” system work up to 300 Volts - 200 Amps Single Phase. (i.e essentially residential or light commercial installations) - without additional technical certification and remaining subject to obtaining necessary permits and work inspection. Comment: This acknowledgment (as opposed to “exemption”) would be based on the skill set of this group, demands of the respective Codes of Ethics, respective certification, evaluation of training, internal regulatory vetting process (pre-qualification) with the sanctioned technical certification association (ASTTBC). Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 4 Proposal 1D All existing and emerging special (restricted) electrical work functions within the scope of restricted certification be recognized in the Electrical Safety Regulation. Comment: This would pick up the present group of restricted categories (e.g. refrigeration, gas, etc.), and add any that are necessary to ensure that industry is mobilized (e.g. - CPA, Fire Protection Technician, etc.). Proposal No. 2 Preamble ASTTBC certifies Fire Protection Technicians to perform work on such protection equipment and systems as fire alarm, special suppression, smoke control, emergency power, and water based extinguishing. Provisions must exist in the Regulation and related safety certification systems to recognize these technical workers and permit them to continue to carry on their business. Certification (with any ASTTBC specified restrictions, or unrestricted) is granted and monitored by ASTTBC. Conformance to the Code of Ethics and work performance is tested against certification requirements and self-regulatory requirements of the association and the membership. There is only the one certification level (Certified Fire Protection Technician) and the restrictions are applied and monitored by ASTTBC. These technicians are certified to a level that is endorsed provincially by the Fire Commissioner to perform regular inspection, testing and maintenance on all fire protection systems, their electrical supply and ancillary equipment. All this work can be done without the need to take out an electrical permit. They have knowledge and experience with Building, Electrical and Fire Code requirements. It is critical that those performing this specialty work fully understand the interrelationships and have regular operational experience. The CFAA (Canadian Fire Alarm Association) notes, in their letter to the Office of the Fire Commissioner from March of 1999, that “neither an electricians license nor status as an employee of an Electrical Contractor implies de-facto qualification to provide competent service, maintenance and repairs of Fire Alarm Systems.” Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 5 The CFAA goes on to say that “should the Safety Act be interpreted to imply that electricians/employees of electrical contractors are by definition qualified, and that others (who may have better Fire Alarm training) are not, a significant threat to Fire Safety may result.”, and “if appropriately trained technicians are barred from testing and working on Fire Alarms, critical service and repair could go undone, with similarly disastrous potential consequences.” As Proposal 2, then, ASTTBC recommends, Special certification be granted to ASTTBC-certified Fire Protection Technicians . Fire Protection disciplines which include an electrical component are: n n n n n fire alarm systems special suppression systems smoke control systems water based fire protection systems emergency lighting and backup power supply systems It should be noted that ASTTBC-certified Fire Protection Technicians n cannot take out permits to perform initial electrical systems installation or relocation. n are trained and certified to perform specific electrical work activities (inspection, testing, maintenance) required to assure the proper readiness of denoted specific fire alarm, suppression, emergency lighting, and other fire or life safety protection systems. n are trained in the operation of all ancillary fire protection and life safety equipment related to the denoted specialties, with ability to test and replace/perform minor repairs to restore complete functionality of the ancillary equipment. n perform (without TQ or manufacturer assistance) all testing, maintenance, and non-construction repairs of all fire protection systems except complex alarm system panels (that require manufacturer specialist operational assurance) Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 6 Proposal No.3 Preface ASTTBC recognizes the complexities, variation, and detail encountered as electrical work is conducted in the province. This Discussion Paper speaks to the need to better reflect the reality of the current workplace, and to allow for continued evolution. Proposal 3 ASTTBC proposes the development of a new safety certification system which considers certification of all workers on the basis of each specialty level (voltage and work complexity based) and competency at that level. It is hoped that such a system will provide a suitable framework for addressing all the issues brought up in the first proposals. n Restricted to High Voltage Power Systems - perhaps OH, UG and Other. (PLT, HV Power Systems Technician/Technologist, Cableman) n Restricted to Residential/Commercial/Industrial systems to 750 Volts (all sizes) n Restricted to Residential/Commercial/Industrial systems to 300Volts/400 Amps n Restricted to Residential Only - 300 Volts/ 200 Amps n Restricted to Low Voltage systems (Security Alarm Installer, CATV Technician, Telephone Technician n Restricted to Electronic Systems (Electronics technician, n Restricted to specific electrical work in any “non-electrical” work classification (e.g. - refrigeration, fire protection systems, gas appliance installation, appliance repair, elevator specialist/technician, industrial instrumentation specialist, winder, sign and light fixture installer, medical equipment specialist, fuel dispensing specialist, entertainment systems specialist, etc. n Unrestricted (all voltage levels and work types). This may end up no longer being the exclusive domain of the electrical trade. Any candidate would have to display a suitable cross section of training and experience to truly demonstrate competency on an unrestricted basis. Discussion Paper Prepared by Keith Switzer, AScT (With assistance from Larry Barker, John Leech AScT CAE, and Martin MacGregor AScT) March 14, 2000 (Revised March 29, 2000) Discussion Paper The Ability to Perform Electrical Work in the Province of British Columbia March 14, 2000 Page 7