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Alberta Introduces Bill 22 – the Red Tape Reduction Implementation Act 2020

by Don Purser | Jun 19, 2020
Alberta to become the next target for PSM followers to implement CSA Z767 as a national standard

This new bill proposes 14 legislative changes across six different ministries.  One of them being the Safety Codes Act which covers Alberta Regulation 85/2003 the Power Engineers Regulation.  

This legislation is eerily similar to Bill 66, Restoring Ontario's Competitiveness Act, 2019, which paved the way for the TSSA to introduce it's Alternate Rules and Path 1 and Path 2.  This risk based approach is taken directly from CSA Z767 Process Safety Management which was developed primarily for the chemical industry.  

Now that the TSSA has introduced the option for registered plants in Ontario to self-regulate and control their own staffing, can Alberta be far behind?  In fact in my opinion, it was the plan all along to make CSA Z767 a national standard.

The problem is CSA Z767 is very basic.  Any sort of RSMP would need to be site specific.  The idea is that a Professional Engineer will sign off on the plan and submit it to the TSSA for approval.  If this process seems rigorous for the plant owner, don't worry the TSSA has just introduced their Path 2 Guidelines which includes instructions and tips on how to get your plan approved. 

The risk criteria for CSA Z767 is to get your RSMP, as low as reasonably practical; or (ALARP).  It's a delicate balance, if you're too cautious, the plant doesn't save as much money.  Remember the province's mandate is to "reduce the undue burden on industry".  As far as I can figure it out, their basically talking about the Power Engineer's salaries.  If you go too high a risk than you could have an accident that could potentially harm the operator and the public at large.  Not to mention expensive payouts by insurance companies for the damage to the plant equipment and down time while the plant is being re-built if at all.

The "TSSA has determined that individual worker risk from process safety risk hazards shall not exceed 10-3 per year, and 10-4 per year for individual public risk".

This doesn't give me a warm fuzzy feeling that plant safety will be maintained.  In fact the TSSA admits that you can't have an effective RSMP unless safety is reduced from the present prescriptive regulation.  One question I have is when a plant blows up, who is going to be held responsible?  The Professional Engineer that signed off on the plan, or the TSSA? 

I guess the whole idea of labour mobility across Canada is headed for the garbage pile.  Especially if each plant will argue and implement their own staffing requirements individually.  This is sure to muddy the waters for Power Engineers who wish to move around within Canada.

Good luck Alberta, the PSM cult leaders are gunning for you!  CSA wants to have Z767 become a national standard.  Let's hope and pray no one gets killed in the process.


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