The Ability to Perform Electrical Work in the Province of British

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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
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