As unbelievable as it seems, the TSSA is using a low weight survey in the midst of a global pandemic to substitute for the public consultation promised for the Alternate Rules, Path 1 and Path 2.
While Power Engineers are busy home schooling their kids and stress levels are heightened due to the Covid-19 pandemic, and while under a State of Emergency in Ontario; the Technical Standards and Safety Authority in concert with the policy writers are still moving forward and under the guise of modernizing the OE Regulation 219/01. TSSA has presented a very light weight survey in efforts to slip it past everyone. This survey amounts to the ‘public consultation’ for the direction of our profession. Every Operating Engineer in Ontario should take this survey in order to have a chance to have their say about these changes. But we're hearing that OE's are expressing concern about replying to a public consultation at these troubling times of crisis, as they don’t have the time to really understand what is being proposed. Many of us in the OE profession are working extra long hours, along with helping to educate our children at home. We believe it is very unprofessional of the Government and TSSA to be bringing forth this low weight survey with limited opportunity for comments currently.
Alternate Rules Survey
The Alternate Rules should have included the 25 recommendations from the Expert Council that were identified by the Operating Engineers Advisory Council (OEAC). Instead the TSSA is only acting on 1 of them, adopting a risk-based approach. One can only assume that the government of the day is driving this. The current Ontario Government (introduced by the policy writers) passed Bill 66, which encourages and promotes reducing the burden on businesses. It should make everyone wonder what the burden is that they are referring to. The Alternate Rules also include changing the practical time requirements for certification from 1st Class to Refrigeration Class B. It seems to us that those who (policy writers) are not in the know, and those at TSSA do not respect the work of the OE profession in contributing to public safety in Ontario. Makes you wonder what the difference between a millwright’s apprenticeship and/or other trades time is is worth when compared to that of an Operating Engineer.
Last year the IPE, TSSA and the Ministry of Government and Consumer Services (MGCS) had somewhat agreed on a framework for Path 1, however the focus now is the release of a Path 2 Guide. This focus on Path 2, despite public feedback showing not in favour. It seems the TSSA, guided by the policy writers, is more determined on having plants develop a Risk Safety Management Plan (RSMP) that basically amounts to self regulation. Paperwork over OE profession.
Change in life is a constant and should be expected. However, this is an example of some industry’s writing their own rules in order to eliminate the prescriptive regulation that they deem to be a burden. A change in a regulation whose sole purpose is to ensure the safe operation of power and pressure vessels in the Province of Ontario is a serious undertaking which is not often done. The current changes being proposed by the Operating Engineer Task Group regarding how plants are to be registered and operated leaves much to the imagination of the jurisdiction.
Lobbyist change for deregulation does not bode well for the future safety of Ontario’s 3000+ plants and all Ontarians who work and live near them. We know that these lobbyists want to reduce costs and increase profitability. In doing this we are putting OE lives and health and safety of the general public at an unnecessary risk. To quote the Path 2 Guide, “The authors have determined that individual worker risk from process safety risk hazards shall not exceed 10-4 per year.” They are of the opinion that plants must lower the bar on safety, as low as reasonably possible to improve the bottom line for some industry in the province of Ontario. Apparently running a safe operation is too costly and is negatively affecting the bottom line.