CSA B149.3 has been a regulatory requirement for many years in Alberta meaning all gas fired process equipment must either be CSA certified or more commonly must be field approved. Industry however has been slow to comply partially due to the vast number of unapproved appliances in the province and the lack of inspectors available to support this. It is estimated that there are still tens of thousands of appliances that require an installation or operating permit in Alberta.
Inspections must be performed by either a Certification Body or an Inspection Body. A temporary variance had been put in place that allowed a suitably competent professional engineer to approve a fired appliance with a proper documentation package. This variance has expired and will not be renewed, removing the ability of professional engineers to approve fired equipment.
Alberta Municipal Affairs (AMA) advised industry that compliance enforcement would begin starting January 1, 2015. Due to the large volume of upgrades and subsequent field inspections required to comply with this, AMA responded to industry concerns by introducing the LEMS program which for those that chose to participate would allow for an extension on the compliance deadline to January 1, 2020.
Legacy Equipment Management System (LEMS) Program
The Legacy Equipment Management System (LEMS) was implemented by the Alberta Government in order to account for this equipment. LEMS became an acceptable alternative to the January 1, 2015 deadline. Companies that participate in the LEMS program are required to be in full compliance under the standard by January 1, 2020.
The LEMS program requires that all participants submit to AMA an inventory of non-certified or field approved fired equipment to be entered into the program. Each participant must submit a plan towards compliance including risk assessment and prioritization. At the end of each year, each participant must report progress towards compliance. For those parties that failed to enter into the LEMS program, the compliance deadline remains at January 1, 2015. Appliances not approved or in the program are subject to enforcement anytime.
Some important points regarding compliance to LEMS:
- The operating company must provide an inventory of all gas-fired equipment for which no standard existed at the time of installation.
- This applied to all process applications in refineries, petrochemical plants and upstream oil and gas sites.
- Equipment must be approved by an agency accredited by the Standards Council of Canada.
- Old variances have expired (VAR-GAS-04-04 or VAR-GAS-05-05)
- All gas fired equipment must be brought up to code
- No grandfathering
- Fines of $100,000 or more exist for non-compliance
- Operating companies are required to create an internal program in order to design, install and monitor all upgrades and ensure compliance.
- The inventory shall be kept current and submitted to Alberta Municipal Affairs Chief Plumbing and Gas Administrator on an annual basis.
- An annual report shall show compliance progress of non-compliant inventory. Producers that sign on to this program are being given until January 1, 2020 to become compliant and must show progress annually.
- Each company shall conduct a risk assessment in order to categorize and prioritize inventory ensuring the equipment posing the greatest risk are addressed as early as possible.
- As equipment is upgraded, it shall be inspected for compliance with B149.3
- Equipment must be certified by an agency accredited by the Standards Council of Canada.
All appliances previously field approved under a previous version of CSA B149.3 are considered compliant even if the code has changed. Without proof of field approval by an inspector or engineer under the variance, compliance to the latest version of CSA B149.3 is required. Previously approved appliances must also be brought to the current code requirements if modified or relocated.
Why Choose Compliance?
Those that fail to comply with the CSA B149.3 code are subject to regulatory enforcement in the form of fines and/or imprisonment with penalties rapidly increasing for repeat offenses.
Employers are legally required to report any incident with an injury or property loss greater than $250. Under Bill C-45 employers are responsible for the wellbeing of their employees and the public. Employers potentially face criminal charges if found to be negligent in their duty of care in the event of an accident.
Compliant systems are generally safer to operate, and use current technologies that are easier to operate and are more available. They provide safe, easy light off and remotely accessible alarm capabilities when shutdown.
MicroWatt can deliver a single-source solution to achieving B149.3 Compliance
We offer our comprehensive BMS LifeCycle Compliance Service program which is designed to address CSA B149.3 while eliminating complexity, ensuring safety & compliance, and significantly lowering costs for our clients.
The program begins with scheduling the initial on-site equipment audit – our certified technicians come prepared with all the required field safety and workplace certifications, equipped with the latest tools, and decades of expertise to hit the ground running.
Our team will perform a full inventory of all gas fired appliances on site with associated assessments of each piece of equipment. The data from the initial assessment is used to generate your BMS LifeCycle Compliance Service program outline. This includes a detailed itemized and prioritized assessment of any remediation required; all instrumentation and services necessary to bring your site up to code; and a step-by-step action plan to schedule the work required.
As per the new regulations, your inclusion in the LEMS program can also be streamlined by working with our team. We can assist with inventory, support risk assessment, prioritization and status updates that are ready for submission to the LEMS database.
Author: Shaun Williamson P.L. Eng., CFSE, PMP, TÜV FS Eng ID: 4506/11
Ref: MicroWatt Controls