CSS -continuous safety services is a "open permit" program where you document any electrical work done in your building and then an inspector comes along once a month and looks over your documented work. He then picks a few jobs and inspects them.
My problem with this is acording to the ministry of labour only registered electricians or apprentices can work on electicity yet our inspectors are inspecting work done by untrained maintenance workers.
By doing this, maintenance workers are gaining false confidence and doing more and more electrical work. What happens if one of them gets hurt while working on electrical? Acording to the ministry they're screwed and so is their boss but when you talk to ESA they say "It's a grey area?"
Why is ESA doing this?
For money. They know maintenance workers are out there changing ballasts, replacing broken outlets, etc without a permit. With this program they can now make money off of those situations.
I am tottaly against this, it goes against everything I was taught. I've spoken with the ministry and they agree with me but do nothing. They say they have to catch it while it's happening.
I guess we'll just have to wait untill some one dies before something is done?
Rant over
The inspector only shows in our office building every 3-4 months.
I guess I should have posted this in the safety forum, sorry. I posted in the canadian code forum because it only pertains to Ontario, I think.
I wonder if this sort of program exists in other provinces or in the US?
In some establishments a competent employee can do electrical work Refer to page 547 of the pocket Ontario OH&S regulations for an example.
It's not the electrical inspectors job to police who does the work just that its up to code they can only alert the ministry of unqualified and incompetent employees as you have already done.
Also many ministry personnel can't articulate there own regulations you need to talk to a ministry workplace inspector
CSS was instituted to target workplaces who use competent yet unqualified employees to do electrical work and rocking the boat by being heavy handed causes the hide and seek reflex with there customers.Employee safety is the ministrys job not the electrical inspectors.they just want to see the work is up to code.
Bill C 45 is very specific towards worker safety and carries stiff penalties even jail time if someone gets hurt.
the ess contractor program is a joke. yes if you own a business you can designate anybody to be competent to do the work. as long as esa makes money they don't care but hire an electrician under the table and it's heavy fines. get the business owner to say your a casual employee. as for the min. of labour it's just a small fine, again a joke. i know of a contractor who employ's unqualified people and has been caught. got a small fine keep's doing it because mol does nothing to ensure it does'nt happen again.
In Ontario, Industrial Electrician is NOT a regulated trade.
A company can therefore designate anybody to perform electrical work at their facility and it's legal.
The only time that I'm aware of that a compnay would get severe punishment from the MOL is if the person was hurt or killed and the company couldn't show that they (the worker) had received appropriate training.
You should also be aware that if a company has the CSS program, that a licensed electrical comtractor (that's not an employee) can go into that facility and not need to pull a permit for any maintenance work performed. The work just needs to be logged.
My biggest complaint with the CSS program is that it's not available to a licensed electrical contractor such as myself. I mean why shouldn't I be able to pay a flat fee per year that covers all maintenance work performed by my company? As long as the work is logged, the ESA can still go every 3 months and pick a random job to inspect, just like they do for a factory.
It's not right that I'm supposed to pull a permit just to go to a commercial building and change one ballast, or one light switch.
BC appears to be similar and given that they used Ontario's rules as a guide I am not surprised to hear this.
In BC, If a facility has an operating permit and the FSR is a direct employee of the company owning a facility then the electrician can instruct the Anybody to do specific maintenance tasks like changing ballasts. The Anybody must be instructed on the techniques and safety requirements like turned off and locked out etc.
If the facility uses a contractor to take the operating permit then only qualified persons may do electrical maintenance.
My biggest complaint with the CSS program is that it's not available to a licensed electrical contractor such as myself. I mean why shouldn't I be able to pay a flat fee per year that covers all maintenance work performed by my company? As long as the work is logged, the ESA can still go every 3 months and pick a random job to inspect, just like they do for a factory.
It's not right that I'm supposed to pull a permit just to go to a commercial building and change one ballast, or one light switch.
Hi, I work in a plant as an industrial electrician. Our inspector comes twice a year. As far as a contractors point of view and having a blanket permit for maintenance, could you not use the ACP program somehow.
As well you do not need to pull a permit to change a ballast or a switch. In fact I am sure no permit is required when replacing like for like for items up to 30amps. You are required to pull a permit when you add to, or alter exsisting electrical wiring, on so on.
My biggest complaint with the CSS program is that it's not available to a licensed electrical contractor such as myself. I mean why shouldn't I be able to pay a flat fee per year that covers all maintenance work performed by my company? As long as the work is logged, the ESA can still go every 3 months and pick a random job to inspect, just like they do for a factory.
It's not right that I'm supposed to pull a permit just to go to a commercial building and change one ballast, or one light switch.
Hi, I work in a plant as an industrial electrician. Our inspector comes twice a year. As far as a contractors point of view and having a blanket permit for maintenance, could you not use the ACP program somehow.
The ACP program means that not all of my projects need to be inspected and the permits cost less money. But I still need to pull a permit for all jobs.
As well you do not need to pull a permit to change a ballast or a switch. In fact I am sure no permit is required when replacing like for like for items up to 30amps. You are required to pull a permit when you add to, or alter exsisting electrical wiring, on so on.
Yes you do need to pull a permit to change a ballast or switch as per 2-004. The only exception to this rule is outlined in rule 2-005. (For those of you outside of Ontario, please note that these 2 rules are specific to the OESC.)
My biggest complaint with the CSS program is that it's not available to a licensed electrical contractor such as myself. I mean why shouldn't I be able to pay a flat fee per year that covers all maintenance work performed by my company? As long as the work is logged, the ESA can still go every 3 months and pick a random job to inspect, just like they do for a factory.
It's not right that I'm supposed to pull a permit just to go to a commercial building and change one ballast, or one light switch.
Hi, I work in a plant as an industrial electrician. Our inspector comes twice a year. As far as a contractors point of view and having a blanket permit for maintenance, could you not use the ACP program somehow.
The ACP program means that not all of my projects need to be inspected and the permits cost less money. But I still need to pull a permit for all jobs.
As well you do not need to pull a permit to change a ballast or a switch. In fact I am sure no permit is required when replacing like for like for items up to 30amps. You are required to pull a permit when you add to, or alter exsisting electrical wiring, on so on.
Yes you do need to pull a permit to change a ballast or switch as per 2-004. The only exception to this rule is outlined in rule 2-005. (For those of you outside of Ontario, please note that these 2 rules are specific to the OESC.)
I disagree. I would never pull a permit to change a switch, receptacle, or ballast on any 120volt circuit rated at 30A or less. Why....because 2-005 says I don't have to. Please show me what rule you are refering to in 2-004 to support your answer.
Rule 2-005 has nothing to do with this discussion as it deals only with "owner-occupied single dwellings" and "the equipment being installed is installed by an electrical contractor licensed in accordance with Regulation 570/05".
Rule 2-004 in it's very first sentence states..."A contractor shall file with the inspection department a completed application for inspection of ANY work...".
Ok, after reading it more carefully I can agree with what your saying about 2-004.
I just have a hard time accepting that if I were called to change a ballast (120v) in a commercial building that I would need to have an inspection done.
I agree that it's not fair.
In some establishments a competent employee can do electrical work Refer to page 547 of the pocket Ontario OH&S regulations for an example.
???? Can you give me the rule #. I have a 2007 version and p.547 is on confined spaces.
S.182(1)says no worker shall connect, maintain or modify electrical equipment unless the worker is an electrician or registered under the apprenticeship act. (page 166 in my book)
It's not the electrical inspectors job to police who does the work just that its up to code they can only alert the ministry of unqualified and incompetent employees as you have already done.
And how do they know who is competent and who is not? Do they test these janitors after noticing that they changed a 347volt ballast?
mol does nothing as i said before. i talked to esa they said in reply qoute the contractor is responsible for their workers since they have to have ins. as far as they are concerned its ok.
Eddy Current,
On page 574 of the POCKET ONTARIO OH&S ACT& REGULATIONS Health Care-Reg67/93
Sub-rule (4)If the installation ,equipment or power line is operating at 300 volts or more but less than 750 volts ,a suitably equipped COMPETENT person who is able to perform rescue operations ,including cardiopulmonary resuscitation,shall be readily available and be able to see the worker who is performing the work
Sub-rule (6)Subsections (4),(5) do not apply to troubleshooting ,installing or replacing meters or testing of appliances or instruments by a worker who is an electrician who is certified under the Trades Qualification Act to do electrical work or a person with equivalent qualifications by training or experience
In the definitions section is says,
"competent person"means a person who,
(a)is qualified because of knowledge ,training and experience to organize the work and its performance
(b) is familiar with this Act and the regulations that apply to the work and
(c)has knowledge of any potential or actual danger to health or safety in the workplace
These rules allow competent workers to carry out electrical work as long as a CPR certified worker who is also competent on the performance of the job is present.
This does not apply to contractors who go into the field to perform electrical work only full time workers in employer owned buildings including public buildings
My particular workplace has been targeted as a dangerous workplace and we are visited by the MOL often.The inspectors have informed us that that the owner of an establishment may designate competent workers to perform electrical work in there building at there own risk in accordance with BILL C-45
Again the ESA inspectors can only report workplace issues to the MOL and cannot impose fines for worker Health and Safety
I dont agree with it either but should someone get hurt or killed under bill C-45 the supervisors,leadhands and anyone who directs work to be done can get life in jail for the death of a worker and ten years for injury.
Eddy Current,
S.182 refers to general construction not maintenance or alterations
If you talk to a MOL inspector he will tell you bill c-45 is what give OH&S Act teeth and any required training is the employers responsibility.you have to read bill c-45 to understand the rational
If the employer wants to screw around and put workers in positions where they can get injured or killed they will pay the price
It's also the workers responsibility to to refuse unsafe work and if they are stupid or afraid enough for their job to work in an unsafe manor than little can be done to protect them.
I know it sucks but thats the reality of the issue
http://www.cos-mag.com/200805281366/legal/legal-columns/bill-c-45-questions-get-answered.htmlhttp://www.esao.on.ca/
These rules allow competent workers to carry out electrical work as long as a CPR certified worker who is also competent on the performance of the job is present.
This does not apply to contractors who go into the field to perform electrical work only full time workers in employer owned buildings including public buildings
No, those rules are subrules of section 68 and apply
only to when electrical work has to be done while the power is on. Working live (page 561 in my book)
S.182 refers to general construction not maintenance or alterations
???? Read it again.
182(1) No worker shall connect,
maintain or modify electrical equipment or installations unless,
(a) the worker is an electrician certified under the trades qualification and apprentice act.
Regardless of the power being on or not the owner of a building can designate competent workers to do electrical work.This is not new and wether i sighted rule or sub rule is just semantics.What are you saying you don't need an electrician the system is energized but you do if it's de-energize?????I don't need to read it again like i said i have dealings with MOL inspectors regularly and it is what it is.Try calling them for an inspection and ask them
Let me put i to you this way a competent worker means other than qualified. Contractors must hold a Certificate of Qualification while employees just have to be competent.Maybe I don't understand your question but it's always been this way.
What I'm saying is no one is allowed to do any electrical work other than a qualified electrician. You say a competent worker is allowed but that is not true. No where in the OHSA book does it say that. If all you have to be is competent than why do we even have licensed electricians?
A home owner in Ontario can do their own work if they get a permit but at work, no one but a qualified person can do any electrical.
The fact that ESA overlooks this with their CSS program (so they can make money) is the problem.
Call the MOL and tell them your a competent maintenance worker in a commercial building and ask if you can do electrical work. I know the answer because I've made that call already.
I have been a 442a since 1999 and a 309a since 2006.And have argued competency as you are now
ESA has absolutely nothing to do with workplace health and safety only the MOL.
I don't need to call for the rational because iv been there and done that.You just wont listen
If only licensed electricians can do electrical work why are competent workers required to have a CPR trained monitor and and electrician does not????.This is the reasoning for the rules i described in an earlier post
In plain English a person or company (CONTRACTOR)who is hired to come into a building must have a C of Q and a person who works for the building owner must only be competent.
We have stationary engineers,matainence mechanics,plumbers and the other trades who troubleshoot up to and including 600v systems in my workplace and the MOL is fine with it.In fact they have inspected our policy and procedure books.
TSSA has done the same with our powerhouse Im the sole operator of a 1500hp plant as i write this and I'm not a licensed engineer im COMPETENT EMPLOYEE.We get SPECIFIC training we sign off on it and blam were good to go.I can't run any other plant in fact its ilegal for me to enter another plant but im in charge of this one while on shift.
It's all about ECONOMICS if your are on shift you do it all and that what it's all about money.I don't agree with it but thats how it is
I don't need to call for the rational because iv been there and done that.You just wont listen
I called today and I was told only a licenced electrician can do electrical work.
If only licensed electricians can do electrical work why are competent workers required to have a CPR trained monitor and and electrician does not????.
??? Electricians have to follow those rules. We can't work live without the extra guy, CPR etc.
We have stationary engineers,matainence mechanics,plumbers and the other trades who troubleshoot up to and including 600v systems in my workplace and the MOL is fine with it.In fact they have inspected our policy and procedure books.
What happens if one of you get hurt while doing electrical? The MOL ok with that too?
but should someone get hurt or killed under bill C-45 the supervisors,leadhands and anyone who directs work to be done can get life in jail for the death of a worker and ten years for injury.
What are you saying there? Your only allowed to do it until someone gets hurt? Or is it actually legal?
I don't know what to say but the actual inspectors are allowing it where i work Maybe it is different in your situation but is defenatly allowed here.
The MOL just showed up one day and grilled employees on our policies and procedures then threatened our directors about our asbestos training as we had none as well other discrepancies.
The company then hired MOL consultants to help get everything in order the created an employee health and safety rep for each union and then went through the ACT with them page by page (YES THERE ARE FIRMS THAT DEAL WITH THE MOL FOR YOU)
We were also designated a dangerous workplace meaning the MOL will do spot inspections without warning.
The employees sign a book at the end of the training saying weve been trained and accept the hazards.
That being said anyone who has a problem can get retrained and is never forced to do anything they feel uncomftable with.Some guys wont do work in the MCCs but have no problem with ballast plugs and stuff like that other wont touch anything.
The 600v work that they do is checking power,fusing on air handlers,low limits,fire relays ect.If they cant fix it The electricians get called in or it waits until we come in on regular hours.
Basically its legal until someone gets hurt because we have signed the books and agreed that we are competent
If someone does get hurt hen Bill C-45 takes over and people can lose there lively hood or do serious jail time If the MOL can prove A won ten disregard for personal safety occurred.The idea that this threat will keep DUE DILIGENCE at the fore front of safety.
There have been occurrences where supervisors have gone to jail or have been fined hundreds of thousands of dollars.Either its monetary or criminal but cant be both.
The idea is to go after anyone who directs work to be done not nessasarily the CEO who may not know whats dangerous and whats not.
The Master electricians license is an extent ion of this if your registered with a contracting business you repressible for the employees saftey.Thats one of the ways they get the contractors.You don't have to be an electrician to be a master electrician
We don't require one because we work are regular employees of the building owner and don't leave the premises
That being said i would be careful attracting attention from the MOL WHEN THE DO COME DOWN THEY COME DOWN REALLY HARD.
I was one of the target employees the inspector walked in the building right up to me told me to take him to the boss.Asked the boss to get the our policy book opened it up and said "these pages have never been turned i need to talk to your guy please leave"
We both just about fainted.And thats how it all started.
good luck man
To me it doesn't make sense that it's ok until someone gets hurt, then at that point people can go to jail. Either it's legal or it's not.
I guess because your in an industrial situation it's different.
I also can't beleive your co-workers sign "the book" that says they accept the hazards.
I work for a big electrical contractor that does commercial work, 100 plus employees.
We are not allowed to work live period. Only for trouble shooting and we have to jump through hoops to do it. I know it (working live) happens in our company on a weekly mabey even daily basis, mostly by the older generation who have done it for years.
We deal with the MOL and WSIB often as well. When I called them yesterday I pretended that I was a maintenance worker who was asked by my employer to do electrical work. I also told them that I took a night school course on electrical. They told me I am not allowed to do ANY electrical work and if I got caught myself and my boss would be charged.
Cheers
Not to breathe too much life back into this debate...but I think perhaps both of you are right.
I think the difference being maintenance vs construction.
Frank is totally right, anybody who is deemed Competent can do Maintenance work in a commercial or industrial facility unless specified otherwise in the regulations (mines, marine, etc).
Only people qualified in construction (309 series) can do the other types of electrical work (excluding homeowners).
CSS only applies to maintenance work. I cannot go in and install a new machine in a plant under the CSS, I require a "permit". I can go in and change ballasts under CSS however.
The competent person is how this whole 442 series started in the first place. In the "old days" a 442 in auto could move fairly freely from one auto sector to another and be deemed competent. However that same 442 could not move into the food industry. That has changed in practice, but the regulations that set this up are pretty dated.
Cheers