REPORT ON CONSULTATION
Draft Safety Order: Combustible Dust Hazards in Wood Processing
Facilities Containing Electrical and Gas Equipment
EXECUTIVE SUMMARY
A consultation on BC Safety Authority’s draft Safety Order on combustible dust hazards in wood
processing facilities was held from January 23, 2013 to March 15, 2013. Out of the 261 individual
invitations were sent industry-wide, 32 responses were received, for a participation rate of 12%.
Consultation responses revealed the following:
 A very wide range of facilities were defined as applicable for the Safety Order;
 Financial burden, time, resources (personnel/work) and classification of “hazardous location”
were cited as key impacts of the Safety Order;
 The definition of what constituted a “qualified professional” to identify combustible dust hazardous
locations was varied and described through citing specific types of knowledge, education or
training, and professions. Stakeholders also suggested additional ideas, such as opportunities for
industry and regulators to work together to create a standardized training program for these
“qualified individuals”.
 The qualified individual was required to have the knowledge of the following areas:
 Applicable codes (fire code, electrical code and gas code)
 Operating process and related hazards
 Wood/Sawmill industry
 Dust classification standards.
 Possible internal expertise, such as someone who has worked in the wood industry, an
owner/operator or company safety officers were identified as possible qualified individuals
 Possible external expertise, such as the fire department, WorkSafeBC and electrical safety
officers were identified as possible qualified individuals.
 The most frequently mentioned standards to guide hazardous location assessment were: BC Fire
Code, NFPA 664, Canadian Electrical Code, and all four standards cited in the
Recommendations Report.
 Respondents were equally divided about documenting identified combustible dust hazardous
locations in the Fire Safety Plan with 46% responding negatively and 43% responding
affirmatively. The most frequently mentioned alternative location was the Combustible Dust
Mitigation and Control Plan as ordered by WorkSafeBC.
 A significant majority (75%) indicated that there was an overlap between terms in the draft Safety
Order and existing regulatory processes for the Office of the Fire Commissioner or WorkSafeBC.
The most frequently specific areas of overlap and the issuing regulatory agency were:
 WorkSafeBC: Ensure alignment with Combustible Dust Mitigation and Control Plan (10
responses)
 Office of the Fire Commissioner: Ensure alignment with content amendments to Fire Safety
Plan
 Fire Inspection & Prevention Initiative (FIPI): Ensure alignment with qualification of individuals
to conduct hazardous location assessments


The timeline of June15, 2013 was considered by 52% of respondents as being non-achievable.
The most often cited reasons for the timeline to be not achievable were:
 BC Safety Authority needs to finalize Safety Order first, with the following areas requiring
finalization: recommended hazardous location identifier, recommended qualifications of
assessor and standard to determine hazardous locations
 Simply an impractical timeframe for completing all requirements
 Potential changes to hazardous location criteria: major infrastructure changes for all of
industry and large number of variances will need to be identified, then approved by BC Safety
Authority
The notion of collaboration with the wood processing industry and alignment with other regulators
was frequently cited as important for consideration.
INTRODUCTION
After the BC Safety Authority’s investigation of the January 2012 catastrophic incident at Babine Forest
Products, a report was released by BC Safety Authority with recommendations to the wood processing
industry and other organizations to minimize the risk of such an incident occurring ever again.
To support the recommendations, BC Safety Authority drafted a Safety Order regarding identifying
combustible dust hazards to be issued to wood processing facilities. BC Safety Authority considered the
impact of the proposed order on the wood processing industry, and endeavoured to consult with the
industry prior to issuing the order. This report summarizes the written responses gathered from the
consultation.
SCOPE OF CONSULTATION AND RESPONSE RATE
The consultation ran from January 23, 2013 to March 15, 2013 and invited stakeholders to give feedback
on the draft Safety Order through a feedback form that asked questions about specific aspects of the
Safety Order.
The consultation was targeted at the following stakeholders:
 Wood processing facilities with electrical or gas equipment under BC Safety Authority jurisdiction
 Associations of wood processing facilities
 Fire Chiefs’ Association of BC
 Electrical Technology Advisory Committee and Gas Technology Advisory Committee
 Other regulators with similar jurisdiction (WorkSafeBC, Office of the Fire Commissioner, local
governments with administrative responsibility for the electrical or gas areas of the Safety
Standards Act)
Stakeholders were sent the following documents:
 Draft Safety Order SO-ASA 2013-01: Combustible Dust Hazard to Regulated Electrical and Gas
Equipment Located in Wood Processing Facilities (Appendix A)
 Draft Information Bulletin IB-ASA 2013-01: Guidance Material on Hazardous Locations and the
Application to Regulated Electrical and Gas Equipment
 Explanatory covering letter or email
 Feedback form (Appendix B)
 Link to the related electrical Safety Orders (SO-EL 2012-01, SO-EL 2012-02)
 Link to the Recommendations Report
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
2
The below table shows the response rate for this consultation, measured by the number of responses
received, divided by the number of direct messages that were successfully sent, separated by the
different types of stakeholders consulted.
Messages
Successfully
sent
Feedback
received
194
31
18
1
1
0
Electrical Technology Advisory
Committee and Gas Technology
Advisory Committee
22
0
Regulators
26
1*
Wood processing facilities
Associations of wood processing
facilities
Fire Chiefs (via Fire Chiefs’
Association of BC)
Response rate: 12.2%
261
32
*This response was not included in this report as the content was regarding clarification of a site
CONSULTATION FINDINGS
Twenty-eight respondents returned their responses by submitting the completed feedback form. This
section summarizes the most frequent responses given to each of the questions on the feedback form. A
complete listing of summarized tables of responses for each question can be found in Appendix C:
Consultation Tables. Verbatim responses can be found in Appendix D.
Question 1: Wood processing facilities definition
Stakeholders were asked what constitutes a “wood processing facility”, and their responses contained a
wide range of examples, as well as by defining activities that a wood processing facility would consist of.
Some of the most frequently mentioned descriptors were:
 Sawmills
 Planers or planer mills
 Pulp mills
 Wood pellet plants
 Oriented strand board mills
 Reman plants
 Veneer/plywood plants
 Medium density fibreboard facilities
 Shake & shingle mills
In addition to the examples and activities cited, the following definitions and parameters were given for a
“wood processing facility”:
 A business that uses wood fiber to produce a finished product for sale.
 Any business that takes wood and wood based materials that are combustible and alters them
using processes that produce dust and fibres that may become combustible if exposed to a
ignition source.
 Any business that deals with the manufacturing of logs, lumber, or wood residuals.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
3




A facility which has machinery and equipment capable of altering or reconfiguring the shape, size
and / or quality of wood fibre.
Any facility that reworks or manufactures a product from wood. This would be from Logging to
any product after.
Any operation which processes larger wood stock into smaller sizes
Someone that is making wood products.
Question 2: Impact of Draft Safety Order
The core negative impacts of the draft Safety Order cited were money for replacing equipment, time and
resources (personnel/work). The core positive impacts cited were no/little impact or that it increased
safety. A frequently mentioned potential significant change was the “hazardous location” classifications,
which would have major impacts on industry.
Question 3: Definition of “Qualified Professional”
Stakeholders were asked what type of professionals would be qualified to identify combustible dust
hazardous locations. In addition to recommending specific types of knowledge, education or training,
professions, stakeholders also suggested additional ideas, such as opportunities for industry and
regulators to work together to create a standardized training program for these “qualified individuals”.
The qualified individual was required to have the knowledge of the following areas:
 Applicable codes (fire code, electrical code and gas code)
 Operating process and related hazards
 Wood/Sawmill industry
 Dust classification standards.
Stakeholders suggested that the qualified individual would require:
 Standardized training programs
Possible internal expertise, such as someone who has worked in the wood industry, an owner/operator or
company safety officers were identified as possible qualified individuals. External expertise, such as the
fire department, WorkSafeBC and electrical safety officers were identified as possible qualified
individuals.
Other most frequently cited suggestions were:
 Regulator should have more expertise: “If BC Safety Authority staff are ‘not experts in dust
classifications’, it is not certain how, as regulator, BC Safety Authority would be able to determine
the acceptability of the assessment.”
 Requires the knowledge of more than one person to conduct the assessment
 Knowledge and experience is more important than a professional designation
 Opportunity for regulator and industry to create standardized training program together.
Question 4: Standards to guide hazardous location assessment
Within the Recommendations Report, four standards were listed as containing requirements for
classification of hazardous locations, as identified in the draft Information Bulletin:
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
4




British Columbia Fire Code (2006)
Natural Gas and Propane Code Handbook (B149HB-05)
Canadian Electrical Code, Part 1 (C221.1-12)
Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking
Facilities (NFPA 664)
Stakeholders were asked which of the listed standards would be best to guide the assessment of
hazardous locations, or which other standards to would be appropriate.
The following standards were most frequently mentioned for consideration, along with some stipulations:
 BC Fire Code:
 Leaves too much room for interpretation for hazardous location assessment
 Simple and workable; incorporates all necessary wording of Canadian Electrical Code
 NFPA 664:
 Contains important information to consider for the assessment, but not enough to understand
the mechanics of fire and explosions
 Already referenced by WorkSafeBC
 Measurement of 1/8” over 5% of the total surface area is already being used by many
facilities and is easy to measure and follow.
 Canadian Electrical Code:
 As source of ignition
 Reconsider CEC 18-008:
 Consider outcomes of Forest Products Innovations’ Report on Wood Dust in the BC
Forest Industry (March 2013): Wood flour was <1% of wood dust material found in the
wood dust sampling process.
 We recognize the guidance materials make mention of wood flour AND dust but the
wording is too weak to be enforced.
 Should be a non-binding requirement
 All four standards in Recommendations Report:
 Clearly articulate to industry the final standards that will be used for assessment to promote
consistency.
 National Electrical Code Standard (US)
Other frequently mentioned suggestions were:
 Industrial insurers
 Industry needs to be engaged in developing a Recognized Industry Standard to determine
hazardous locations
Question 5: Documenting identified combustible dust hazardous locations in Fire
Safety Plan
The Safety Order, if implemented as drafted, would require industry to “incorporate any identified
combustible dust hazardous locations and the chosen means to manage the combustion hazards into the
facility’s Fire Safety Plan, or where no Fire Safety Plan is required, another suitable facility document”.
Stakeholders were asked whether the Fire Safety Plan would be a suitable location for listing identified
combustible dust hazardous locations and mitigation plans for each. They responded:
Response
Count
Yes
12
No
14
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
5
No response
3
The most frequently mentioned alternative location was the Combustible Dust Mitigation and Control Plan
as ordered by WorkSafeBC.
One frequently mentioned suggestion was to allow for flexibility, citing the example Office of the Fire
Commissioner allowing for elements of the Fire Safety Plan to be contained in various separate
documents as long as all content has been addressed.
Question 6: Overlap with other regulators
Stakeholders were asked whether there was an overlap between terms in the proposed Safety Order and
existing regulatory processes for the Office of the Fire Commissioner or WorkSafeBC.
Response
Count
Yes
22
No
4
No response
3
The most frequently specific areas of overlap and the issuing regulatory agency were:
 WorkSafe BC:
 Ensure alignment with Combustible Dust Mitigation and Control Plan
 Office of the Fire Commissioner:
 Ensure alignment with any content amendments to the Fire Safety Plan
 Fire Inspection & Prevention Initiative (FIPI):
 Ensure alignment with qualification of individuals to conduct hazardous location assessments
As well, a number of respondents commented that undue overlap causes confusion for regulators and
industry.
Question 7: Timelines
Wood processing facilities were asked if the proposed timeline of June 15, 2013 to complete the Safety
Order as it was written would be achievable.
Response
Achievable
Not achievable
No response
Count
8
16
6
The most often cited reasons for the timeline to be not achievable were:
 BC Safety Authority needs to finalize Safety Order first, with the areas requiring finalization were:
 Recommended qualifications of assessor
 Recommended hazardous location identifier
 Standard to determine hazardous locations
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
6


Simply an impractical timeframe for completing all requirements
Potential changes to hazardous location criteria:
 Major infrastructure changes for all of industry
 Large number of variances will need to be identified, then approved by BC Safety Authority
Question 8: Additional comments






Manufacturers’ Advisory Group has developed a Forest Industry Task Force Wood Dust
Mitigation and Control Audit and would like to consider this as a starting point for auditing dust
management processes;
There is a need to develop training/education;
It is important to align with other regulators: Strategy needs to be designed to ensure greater
consistency between BC Safety Authority and other organizations on this initiative
It is important to communicate updates/outcomes: Strategy needs to be designed to
communicate updates and feedback on assessment, area classification, acceptable mitigation
strategies, and other information to all wood processing facilities;
It is important to collaborate with industry: Use current codes and standards as a starting point for
developing standards;
It is important to be clear on hazard classifications.
CONCLUSION
Engaging the wood processing industry in a consultation on the potential impacts and specifications of
the Safety Order on combustible dust hazard locations revealed areas of the draft Safety Order that
required further consideration, and highlighted the willingness of industry to work with BC Safety Authority
on developing training programs for qualified individuals to assess these hazardous locations.
A wide range of facilities were defined as applicable for the Safety Order, for whom the implementation of
the Safety Order as written would create impacts on time, personnel, and overall financial burden,
particularly if the classification of “hazardous location” were to change.
Stakeholders had various expectations for a “qualified professional” who would be able to identify
combustible dust hazardous locations. The individual would need to be knowledgeable in various
applicable codes (fire code, electrical code and gas code), the operating process and related hazards, the
wood processing/sawmill industry, and dust classification standards. Stakeholders preferred that BC
Safety Authority not use the term “qualified professional” as it inferred that the individual would have to
have a professional designation, and they felt that a combination of knowledge, training and experience
would be more important. Possible examples of in-house expertise and external expertise were identified.
Stakeholders also suggested additional ideas, such as opportunities for industry and regulators to work
together to create a standardized training program for these “qualified individuals”.
The most frequently mentioned standards to guide hazardous location assessment were the BC Fire
Code, NFPA 664, the Canadian Electrical Code, and all four standards cited in the Recommendations
Report. Stakeholders were divided on where to document the identified combustible dust hazardous
locations, with nearly 50% of the stakeholders agreeing that the best location would be the Fire Safety
Plan, and 50% feeling this was not appropriate, with the most frequently mentioned alternative location
being the Combustible Dust Mitigation and Control Plan that had been ordered by WorkSafeBC.
A significant majority indicated that there was an overlap between terms in the draft Safety Order and
existing orders by other regulatory agencies. Most stakeholders urged BC Safety Authority to align their
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
7
order with WorkSafeBC’s Combustible Dust Mitigation and Control Plan, the Office of the Fire
Commissioner content amendments to the Fire Safety Plan, and Fire Inspection & Prevention Initiative
(FIPI)’s determination of qualification of individuals to conduct hazardous location assessments.
The proposed timeline of June15, 2013 for completing the Safety Order was considered by 52% of
respondents as being unachievable. Many of the respondents who considered this timeline to be
unachievable found this to be an impracticable timeframe for completing all the necessary requirements.
Others cited the need for BC Safety Authority to identify the recommended hazardous location identifier,
recommended qualifications of assessor and standard to determine hazardous locations. The potential
changes to hazardous location criteria would also create major infrastructure changes for the wood
processing industry and large number of variances will need to be identified, then approved by BC Safety
Authority.
Collaboration with wood processing industry and alignment with other regulators was frequently cited as
important for consideration in the finalization of this Safety Order.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
8
APPENDIX A: DRAFT SAFETY ORDER
SAFETY ORD
DER
COMBU
USTIBLE DU
UST HAZAR
RD TO REGULATED EL
LECTRICAL
L AND GAS EQUIPMEN
NT
LOCATED
D IN WOOD PROCESSING FACILIT
TIES
Date of Issue:
I
xxxx
xxx, 2013
NO: SO-ASA
A-2013-01
This safety order
o
is issued pursuant to sectio
on 31 of the Safe
ety Standards Acct. A person affeccted by this safety order may app
peal
this order in writing to the Sa
afety Standards Appeal
A
Board witthin 30 days. Th
he appeal processs is set out on th
he Safety Standa
ards
Appeal Boarrd's website at htttp://www.housin
ng.gov.bc.ca/ssab
b/. This order may
m not be stayed
d during an appe
eal.
omply with a safe
ety order is an offfence under secttion 72 of the Sa
afety Standards Act.
A
Failure to co
Introduc
ction
As a resu
ult of investig
gation findin
ngs collected
d from a 2012 explosion and fire at a BC sawmill the
BC Safetty Authority is issuing this Safety Orrder to help prevent,
p
avo
oid or reduce
e the risk of
personal injury or damage to pro
operty.
The pressence of com
mbustible dust or fibre may
m create a hazardous location for the
t operation
n of
electricall or gas equiipment. Botth electrical equipment
e
a gas equipment are regulated
and
r
un
nder
the Safetty Standards
s Act. The BC
B Electrical Code and th
he BC Naturral Gas and Propane Co
ode
contain requirements
r
s for the insttallation and operation of
o regulated equipment
e
lo
ocated in
hazardou
us locations.. The BC Sa
afety Authorrity has issue
ed an Inform
mation Bulletiin (under
developm
ment) that prrovides furth
her guidance
e on hazardo
ous locationss and the ap
pplication to
regulated
d electrical and
a gas equiipment.
This safe
ety order app
plies to all wood
w
processsing facilitiess utilizing reg
gulated elecctrical or gas
equipment. Some off the require
ements of this safety order only applyy to wood prrocessing
facilities that have ele
ectrical or ga
as installatio
ons of sufficient size to require
r
an op
perating permit.
Details on
o requireme
ents for operrating permitts can be fou
und in BC Sa
afety Authorrity directive DE3 07080
01 7 Electric
cal Operating
g Permit Requirements or in bulletin
n B-G5-0411
1084 Gas
Operating Permit Re
equirements.
d Actions
Required
I.
o
or op
perator of a wood proc
cessing facility that utiilizes regula
ated electric
cal
Any owner
or ga
as equipment will take the
t following
g actions at any
a facility under
u
its dire
ection or con
ntrol
as so
oon as feasib
ble:
1. C
Conduct an assessment
a
of your wood processing
g facility to id
dentify comb
bustible dust
hazardous loc
cations in re
elation to reg
gulated electtrical and ga
as equipment located in that
t
fa
acility:
a. This asse
essment sha
all be conduccted by a pro
ofessional th
hat is qualifie
ed to identifyy
combustib
ble dust hazzardous locations;
Safety Ord
der No: SO-AS
SA-2013-01
Page 1 of 3
50
05 SIXTH STREET, SUITE 20
00, NEW WES
STMINSTER, BRITISH
B
COLU
UMBIA, CANAD
DA V3L 0E1
Toll Free: 1-866-566-723
33 Fax: 778-39
96-2064 Web Site: www.saffetyauthority.ca
a E-mail: info@
@safetyauthority.ca
FRM
M-1128-05 (2011
1-10-18)
SAFETY ORD
DER
b. The assessment shalll be carried out in accorrdance with a recognized
d industry
standard for combusttible dust hazzardous loca
ations; and,
c. The proce
esses used in these asssessments and the results of the asssessments shall
s
be docum
mented in the
e records loccated at the wood processing facilityy.
2. W
Where combu
ustible dust hazardous locations are
e identified and
a contain electrical
e
or gas
equipment, develop and document a plan to either:
a. Employ auditable woo
od dust man
nagement prractices for these locatio
ons that are
accepted by a qualifie
ed person ass an effective means to manage the
e combustion
n
hazard, or
b. Configure
e the equipm
ment for safe operation given
g
the pre
esence of the
e combustible
dust haza
ard. Any ope
eration of the
e equipment prior to the reconfigurattion must be
e
done under wood dusst managem
ment practice
es required in
n item 2a of this safety order.
o
3. In
ncorporate any
a identified
d combustiblle dust haza
ardous locations and the chosen means
to
o manage the combustio
on hazards into the faciliity’s Fire Saffety Plan, orr where no Fire
F
S
Safety
Plan is
s required, another
a
suita
able facility document.
d
II. Any owner
o
or op
perator of a wood proc
cessing facility that utiilizes regula
ated electric
cal
or ga
as equipment that requ
uires a perm
mit to opera
ate that equiipment will no later than
n
June 15th, 2013, take the follo
owing action
ns at any faccility under itts direction or
o control:
4. C
Complete the
e attached Safety Order Response Form
F
and su
ubmit it to the
e BC Safety
A
Authority;
5. A
Apply to the BC
B Safety Authority
A
for a variance to
o operate eq
quipment in a hazardouss
lo
ocation when
n dust mana
agement pracctices referred to in item
m 2 of this sa
afety order are
utilized to con
ntrol the hazzardous loca
ation;
6. H
Have the Fire
e Safety Plan
n or other su
uitable docum
ment referre
ed to in item 3 of this saffety
order available at the facility for auditt by the BC Safety
S
Autho
ority.
If you have any ques
stions regard
ding this safe
ety order, ple
ease contacct your local electrical sa
afety
afety officer through
t
the BC Safety Authority
A
call centre by phone
p
at 1.866.566.7233
3 or
or gas sa
by email at [email protected] .
Stephen Hinde, P.En
ng
Provincia
al Safety Ma
anager
Safety Ord
der No: SO-AS
SA-2013-01
Page 2 of 3
50
05 SIXTH STREET, SUITE 20
00, NEW WES
STMINSTER, BRITISH
B
COLU
UMBIA, CANAD
DA V3L 0E1
Toll Free: 1-866-566-723
33 Fax: 778-39
96-2064 Web Site: www.saffetyauthority.ca
a E-mail: info@
@safetyauthority.ca
FRM
M-1128-05 (2011
1-10-18)
SAFETY ORD
DER
ces:
Referenc
SBC 20
003, c. 39
B.C. Re
eg. 105/2004
B.C. Re
eg. 100/2004
D-E3 07
70801 7
B-G5-04
411084
IB-xxxxxxxx
Safety Stan
ndards Act
Safety Stan
ndards Generral Regulation
n
Electrical Safety
S
Regulation
Electrical Operating
O
Perm
mit Requirements
Gas Operating Permit Requirements
R
Information
n bulletin unde
er developme
ent
Safety Ord
der No: SO-AS
SA-2013-01
Page 3 of 3
50
05 SIXTH STREET, SUITE 20
00, NEW WES
STMINSTER, BRITISH
B
COLU
UMBIA, CANAD
DA V3L 0E1
Toll Free: 1-866-566-723
33 Fax: 778-39
96-2064 Web Site: www.saffetyauthority.ca
a E-mail: info@
@safetyauthority.ca
FRM
M-1128-05 (2011
1-10-18)
SAFETY
A
ORD
DER RESPO
ONSE FORM
M
S
Safety
Orderr No: SO-AS
SA-2013-01
e information on this form is collected to administe
er the provisionss of the BC Safetyy Standards Act,, and is subject to
o section 26 of th
he Freedom of
The
Info
ormation and Pro
otection of Privac
cy Act. If you havve any questions about the collecction, use, or discclosure of this infformation, contacct the Records,
Info
ormation and Privvacy Analyst for the BC Safety Au
uthority at 1-866
6-566-7233.
The
e company, or
o designated representativve, in receipt of a safety orrder must fill out
o and subm
mit a complete
ed copy of thiss
Safety Order Re
esponse Form
m (pages 1 & 2) to the BC Safety Authority before Ju
une 15th, 2013
Verify that
t
the follow
wing items have
h
been co
ompleted as required in the
t above sa
afety order:
Ye
es
No
Required Action:
R
1 Verify that an assessme
1.
ent to identifyy combustible wood dust ha
azardous loca
ations has be
een completed
d
for your wo
ood processin
ng facility.
2 Verify that the assessm
2.
ment, to identiffy combustible wood dust hazardous
h
loccations, has been
b
carried
out by a prrofessional who is qualified
d as described in the Inform
mation Bulletiin (under devvelopment)
3 Verify that the process used, in the assessment
3.
a
to
o identify com
mbustible woo
od dust hazard
dous
locations, and
a the results of the asse
essment have
e been docum
mented in reco
ords located at
a your wood
processing
g facility.
4 Verify that you have devveloped audittable wood du
4.
ust managem
ment practicess for all combu
ustible wood
dust hazarrdous location
ns.
5 Verify that the auditable
5.
e wood dust management
m
plan has been accepted by
b a qualified person as an
effective means
m
to man
nage the haza
ard.
6 Verify that you have con
6.
nfigured the equipment
e
forr safe operatio
on given the presence
p
of the
combustible dust hazarrd.
7 Verify that your wood processing faccility Fire Safe
7.
ety Plan has been
b
updated
d to include identification off
combustible dust hazarrdous location
ns and the cho
osen means to
t manage the combustion
n hazards in
those locations.
8 Verify that you have a valid
8.
v
Electrica
al Operating permit
p
in place
e for the operration and ma
aintenance of
electrical equipment
e
loccated at your wood processing facility. (Directive D- E3
E 070801 7 Electrical
Operating Permit Requiirements provvides further details
d
on req
quirements forr electrical op
perating
permits.)
9 If your woo
9.
od processing
g facility requiires an Electrrical Operating
g permit and you do not cu
urrently hold
an Electric
cal Operating permit for thiss facility, veriffy that you ha
ave completed
d and submittted an
application
n for an Electrrical Operatin
ng permit to th
he BC Safety Authority.
1 If your wo
10.
ood processin
ng facility requ
uires an Gas Operating pe
ermit and you do not curren
ntly hold an
Gas Operrating permit for this facilityy, verify that you
y have com
mpleted and submitted an application
a
for
an Gas Operating
O
perm
mit to the BC Safety Autho
ority. Information Bulletin
http://www
w.safetyauthoritty.ca/sites/defa
ault/files/B-G5041108_4_
_Gas_Operatin
ng_Permits_Rq
qmnts_obtain_instl_permit.pd
df provides further details on
o
requireme
ents for Gas Operating
O
perrmits.
11. Verify that you have applied for and obtained a va
ariance to ope
erate electrica
al equipment within a
ocation.
wood dustt hazardous lo
SO
O-ASA-2013-01 Response Fo
orm
5 SIXTH STR
505
REET, SUITE 200, NEW WE
ESTMINSTER, BRITISH COLUMBIA, CANA
ADA V3L 0E1
ority.ca E-mail: info@safetya
Toll Free: 1-866-5
566-7233 Fax: 778-396-2064
4 Web Site: www.safetyauth
w
authority.ca
P
Page
1 of 3
SAFETY
A
ORD
DER RESPO
ONSE FORM
M
S
Safety
Orderr No: SO-AS
SA-2013-01
Re
esponse Form
m Completio
on Date:
M
Month
/ Da
ay / Year
Op
perating Com
mpany Name:
Wo
ood Processing Facility
Ad
ddress:
Co
ompany repre
esentative siignifying
completion of Safety
S
Orderr requiremen
nts:
(Pllease print nam
me)
osition Title:
Po
Sig
gnature:
E-m
mail:
Phone num
mber:
Qu
ualified Comp
pany represe
entative or consulting prrofessional
wh
ho conducted
d the Hazard
dous Location assessmen
nt:
(Please print name)
n
Po
osition Title:
Sig
gnature:
Em
mail:
Phone num
mber:
Valid Electricall Operating Permit
P
Numb
ber:
Valid Electricall Field Safety
y Representa
ative (FSR)
named on Elec
ctrical Operatting Permit. Name:
Valid Electricall Field Safety
y Representa
ative (FSR)
named on Elec
ctrical Operatting Permit. Registration
n Number:
If applicable
a
- Valid
V
Gas Op
perating Perm
mit Number:
SO
O-ASA-2013-01 Response Fo
orm
5 SIXTH STR
505
REET, SUITE 200, NEW WE
ESTMINSTER, BRITISH COLUMBIA, CANA
ADA V3L 0E1
ority.ca E-mail: info@safetya
Toll Free: 1-866-5
566-7233 Fax: 778-396-2064
4 Web Site: www.safetyauth
w
authority.ca
P
Page
2 of 3
SAFETY
A
ORD
DER RESPO
ONSE FORM
M
S
Safety
Orderr No: SO-AS
SA-2013-01
t
Re
eturn this form
f
beforre June 15th
, 2013 to:
by
b mail
BC Safety
S
Auth
hority
505 Sixth St.
New
w Westminsster, BC
V3L 0E1
Attn: Safety Orrder – Haza
ardous Loca
ations
by
b fax
778--396-2064
Attn: Safety Orrder - Haza
ardous Loca
ations
by
b email
info@
@safetyautthority.ca
Subjject: Safetyy Order-Hazzardous Locations
SO
O-ASA-2013-01 Response Fo
orm
5 SIXTH STR
505
REET, SUITE 200, NEW WE
ESTMINSTER, BRITISH COLUMBIA, CANA
ADA V3L 0E1
ority.ca E-mail: info@safetya
Toll Free: 1-866-5
566-7233 Fax: 778-396-2064
4 Web Site: www.safetyauth
w
authority.ca
P
Page
3 of 3
APPENDIX B: CONSULTATION FEEDBACK FORM
Consultation on Safety Order SO-ASA-2013-01: Combustible Dust
Hazard to Regulated Electrical & Gas Equipment Located in Wood
Processing Facilities
The BC Safety Authority’s Technical Programs is soliciting feedback from all interested stakeholders in
regards to Safety Order SO-ASA-2013-01. Stakeholders are invited to review the safety order and
provide feedback.
The deadline for feedback is 5:00 pm on Friday, March 15, 2013.
Privacy and Protection: The information gathered on this feedback form is for research purposes only and will be administered
according to the provisions of the Freedom of Information and Protection of Privacy Act.
Introduction
The BC Safety Authority is requesting your feedback on the following three aspects of the required
actions within the Safety Order:
1. qualified professional conducting the hazardous location assessment;
2. recognized industry standards for assessment of hazardous locations; and
3. stated timeline for completion of specified actions and submittal of Safety Order Response Form.
As well, the BC Safety Authority is interested in receiving any general comments and/or questions you
may have with regards to the purpose and content of the Safety Order.
Respondent Information
Name
Company
Association/Organization
Email address
Telephone
Position/Title
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 1 of 6
General Feedback
1.
The BC Safety Authority would like a better understanding of what constitutes wood processing
facilities.
Please identify what businesses you consider as being “wood processing”.
2.
How will this proposed Safety Order impact your business operation?
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 2 of 6
Specific Feedback
3.
Under the first required action, it states: a. this assessment shall be conducted by a professional
that is qualified to identify combustible dust hazardous locations.
What types of persons would you consider to be a "qualified professional"?
4.
Under the first required action, it states: b. the assessment shall be carried out in accordance
with a recognized industry standard for combustible dust hazardous locations.
Which of the stated standards in the Recommendations Report do you consider as
appropriate to guide the assessment of hazardous locations? Are there other standards
that you would consider more appropriate? If so, which standards and why?
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 3 of 6
5.
Part I, section 3 states: incorporate any identified combustible dust hazardous locations and the
chosen means to manage the combustion hazards into the facility’s Fire Safety Plan, or where
no Fire Safety Plan is required, another suitable facility document.
Do you consider the Fire Safety Plan as a suitable location to store this information?
yes
no
If you responded no, where do you think is a more appropriate documentation storage
location?
6.
In your opinion, are there terms within the proposed Safety Order that you think overlap
with existing regulatory process for the Office of the Fire Commissioner or WorkSafe BC?
yes
no
If you responded yes, which agency and what specific terms do you think are an overlap?
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 4 of 6
7.
Part II of the Safety Order states: any owner or operator of a wood processing facility that utilizes
electrical or gas equipment that requires a permit to operate that equipment must take three
actions by June 15, 2013.
Do you consider the timeline of June 15, 2013 as:
achievable
not achievable
If you responded not achievable, please explain.
8.
All opinions, suggestions and/or questions will be reviewed and taken into consideration before
the Safety Order is finalized.
Please provide any opinions, suggestions and/or questions you may have about any
aspect of the Safety Order.
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 5 of 6
9.
Would you like to meet or have a teleconference arranged regarding this Safety Order?
yes
no
If a sufficient number of stakeholders request a meeting/teleconference, a group session can be
organized.
Form submission
The deadline for feedback is 5:00 pm, Friday March 15, 2013.
Please be advised that the Provincial Safety Manager intends to make a final decision on issuance of
this order after the deadline stated whether or not any feedback is received. As a result of considering
any feedback received, please note that the terms of the proposed order may or may not change.
Please submit your feedback form by using any of the following methods:
1.
Mail your completed form to:
BC Safety Authority #200-505 6th Street New Westminster BC V3L 0E1
Attention: Jim Allaway, Leader-Stakeholder Engagement Programs
2.
Fax a copy for your completed form to:
778-396-2064 Attention: Jim Allaway, Leader-Stakeholder Engagement Programs
3.
Download this form or fill out the webform at http://www.safetyauthority.ca/stakeholderengagement/consultation-safety-order-combustible-dust-hazard
Print Form
Consultation on Safety Order: Combustible Dust Hazard to Regulated Electrical and Gas Equipment Located in Wood Processing Facilities
BC Safety Authority
January 2013
p. 6 of 6
APPENDIX C: CONSULTATION REPORT TABLES
Definition of Wood Processing Facilities
The following table shows the list of examples given by stakeholders when asked what constitutes a
“wood processing facility”, as well as the number of times this example was given.
Example
Count
Sawmills
19
Planers or planer mills
17
Pulp mill
 woodroom specified (2 responses)
 sawdust/chip yard specified (1 response)
 Market bleached chemithermomechanical pulp mill (1 response)
16
Wood pellet plants
15
Oriented strand board mills
15
Reman plants
14
Veneer/plywood plants
14
Medium density fibreboard facilities
13
Wood furniture / doors / windows / truss / etc facilities
13
Paper mill
 woodroom specified in one response
12
Shake & shingle mill
11
Energy plants that consume wood biomass
11
Chipping facilities
11
Post and pole manufacturing facilities
10
Wood preserving facilities
9
Stile and rail/fences facilities
9
Wooden moulding facilities
9
Wooden box/crate/pallet facilities
9
Particle board plant
2
Tissue mills
2
Wood products manufacturers
1
Pole/preservative operations
1
Log home builders
1
Cabinet/window/door shop
1
Dry kilns
1
Pole peeling operations
1
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
March 2013
xiii
Example
Count
Co-gen plants
1
Firewood manufacturers
1
Engineered Lumber Products facilities
1
Woodworking shops
1
The following table shows the list of activities that stakeholders felt would constitute “wood processing”:
Activity
Count
Wood drying and sorting
1
Processing of raw logs
1
Wood planing
1
Molding of wood
1
Wood cutting
1
Wood sanding
1
Finger-jointing
1
Pad manufacturing
1
Sawmill cutting hardwood
1
Planer mill doing dry hardwood & green soft wood
1
Carpentry
1
Primary breakdown of logs into lumber, timber, posts
& rails, and other rough sawn wood products.
1
Finish processing of lumber, timbers and other rough
sawn wood products through planers, sanders,
resaws, etc. to create a finished surfaced product
1
Remanufacture of rough sawn and finished or semifinished wood products into finger jointed, laminated
or other value added products including beams,
furniture, etc
1
One response denoted what the definition of “wood processing” would not include.
Activity not included
Does not included processing/cooking of fibre
Count
1
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xiv
Impact of draft Safety Order
When asked what the impact of the draft Safety Order, were it issued as written, would be, some
stakeholders cited negative impacts such as time and money.
Negative impact
Count
Specifications
Money
23
 Purchase and installation of new/replaced equipment if required (13
responses)
 Some facilities may need to discontinue operation due to the cost of
implementing this order (10 responses)
 Inspectors (2 responses)
 Facility/equipment redesigns (1 response)
Time
12
 Reviewing and write fire safety orders and follow up (1 response)
 Hiring and training people (1 response)
Resources
(personnel/work)
8
Downtime of facility
2
 Duplication of work that was already required by other jurisdictions, or
additional requirements (4 responses)
 May need to hire and train people (3 responses)
 Management of order (1 response)
Some stakeholders referenced the positive outcomes of issuing the Safety Order.
Positive/neutral
impact
Count
Quotes
No/little impact
5
 “This safety order would not impact our business to any extent as we
do a major cleanup once a week as well some during the week.”
 “Other than direct costs of implementation of Order, the majority of the
items are part of Permit Compliance.”
Increases safety
2
 “The impact of this safety order is going to improve safety with in
facilities.”
Specific requirements or changes in the Safety Order that would have an impact on the industry were
cited.
Potential change
Classification of
“hazardous location”
Count
10
Quotes
 “A major change to the hazardous location classification proposed by
this order will significantly impact all facilities, requiring time, financial
resources, and regulator/industry collaboration in order to implement a
new standard for the industry”
Classification of
“hazardous dust”
1
 “There will be a significant financial and operational impact if new
hazardous classifications of wood dust are applied to, and enforced
on, existing installations that satisfied the standards of the day”
Increased standards
of regulated
activities
1
 “Changes to regulations in BC that change the standards, carry with
them an associated impact on cost”
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xv
Other comments were:
Comments
Count
Unknown until
regulator finalizes
order
13
Quotes
 “It will take time, money and resources to figure out how to comply with
the order when the organization issuing the order has no clear idea of
what they want produced.”
 “The impact of this order is very difficult to determine without knowing
the final criteria that will be used to define ‘qualified professional’ and ‘a
recognized industry standard’, which are critical drivers for the
assessment of hazardous locations proposed in this order”
 “There is not a clear standard on who will, or who can deem a person to
be a ‘qualified professional’ capable of conducting the audit; [and no]
verification system on how companies will be able to verify that a
‘qualified professional’ is appropriately qualified to conduct audits for an
employer
Regulator and
industry need to
work together
8
 “The industry and BCSA must work together to ensure that these
changes create a meaningful reduction of the risks posed by potential
ignition sources.”
Reputational risk
2
 “It is unclear whether this order is achieving a purpose or simply trying
to shift the blame for any future incidents away from regulatory bodies.”
 “If the process becomes cumbersome, time consuming and an
administrative exercise it will tarnish the reputation and perception of
BCSA.”
Definition of “Qualified Professional”
The qualified individual was required to have the knowledge of the following areas:
Knowledge area
Count
Specifications
Applicable codes
13
Fire code (10 responses)
Electrical code (10 responses)
Gas code (9 responses)
Operating process and
related hazards
14
 Knowledgeable in the process, and in particular, failure
modes that could create a hazard
 Electrical and gas equipment in sawmill environment
Wood/Sawmill industry
14
 This knowledge was emphasized as “critically important”
Dust classification standards
13
 For the purpose of hazardous location identification
Hazardous location
management
5
Dust control
1
Stakeholders suggested that the qualified individual would require the following education, training, or
qualifications:
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xvi
Education, training or
qualifications
Standardized training
program
Count
11
Specifications
See “other” section
Environment/Safety (e.g. IE,
EP, CRSP, CHSC, IH)
1
Electrical trade qualification
1
 With experience in dust control
Gas trade qualification
1
 With experience in dust control
Fire safety
1
Fire protection
1
Fire prevention
1
Fire investigation
1
Accident forensic
assessments
1
Health and safety
1
Some job titles, duties or professions were cited, some of which a facility may already have.
Professions
Count
Specifications
Possible internal expertise
One who has worked in the
wood industry
4
Owner/Operator
2
Company safety officers
2
Electrical technologist
1
Facility maintenance
1
Facility manager
1
Safety professional
1
Fire protection engineer
1
Professional engineer
2
Electrical engineer
1
 With familiarity in wood industry or hazardous locations
Company management
1
 Involved in maintenance or equipment design
Persons with similar training
and experience to
WorkSafeBC representatives
1
 With familiarity in wood industry or hazardous locations
 Trained or knowledgeable about combustible dust hazards
External expertise
Fire department
3
WorkSafeBC
3
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xvii
Electrical inspector/Safety
Officer
2
Gas inspector/Safety Officer
1
Boiler inspector/Safety Officer
1
Industrial hygienist
1
Fire inspector
(regional/municipal)
1
Insurance underwriter
1
Insurance property inspector
1
Other
Consulting group with various
disciplines
1
Whoever BC Safety Authority
decides
1
 A consulting group of various disciplines of engineering
and/or seasoned experienced individuals who work in the
capacity of wood processing, fire investigation, accident
forensic assessments and those agencies that apply
regulatory requirements throughout the industries.
Other suggestions and comments:
Other
Count
Specifications
Regulator should have more
expertise
10
 If BC Safety Authority staff are “not experts in dust
classifications”, it is not certain how, as regulator, BC Safety
Authority would be able to determine the acceptability of the
assessment.
Requires the knowledge of
more than one person to
conduct the assessment
10
 In order to achieve qualification needs in various areas (e.g.
electrical and gas equipment)
 Suggest wording change for flexibility “..as one who is..."
should be changed to "...as one who may have..."
Also see Professions: Other
Does not need to be
professional designation
9
 Knowledge and experience was cited as more important
Opportunity for regulator and
industry to create
standardized training program
together
9
 Regulators and industry both need to undergo this training (2
responses)
 Training should be developed before finalized Safety Order
is issued. (1 response)
 BC Safety Authority should administer the training. (1
response)
Where to find this person?
2
 Respondent did not understand that the draft Safety Order
was under consultation and thought that action was
warranted.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xviii
Enforce existing system
1
 BC Safety Authority should enforce existing regulations for
electrical and gas equipment and use these codes,
guidelines and regulations these to identify hazardous
locations.
Train and qualify FSRs
1
 Consider creating a module for Field Safety Representatives
for assessing combustible dust hazards
Standards to Guide Hazardous Location Assessment
Standard
All four standards mentioned
in the Recommendations
Report
Count
Considerations
12*  Clearly articulate to industry the final standards that will be
used for assessment to promote consistency.
15
 Contains important information to consider for the
assessment, but not enough to understand the mechanics of
fire and explosions
 Already referenced by WorkSafeBC
 Measurement of 1/8” over 5% of the total surface area is
already being used by many facilities and is easy to
measure and follow
NFPA 668
1
 Contains important information to consider for the
assessment, but not enough to understand the mechanics of
fire and explosions
NFPA 499: Recommended
Practice for the Classification
of Combustible Dusts and of
Hazardous (Classified)
Locations for Electrical
Installations in Chemical
Process Areas
1
 Language in this standard supports NFPA 664.
NFPA 77: Recommended
Practice on Static Electricity
1
 Contains important information to consider for the
assessment, but not enough to understand the mechanics of
fire and explosions
Pressure vessel standard
1
 Contains important information to consider for the
assessment, but not enough to understand the mechanics of
fire and explosions
16
 Leaves too much room for interpretation for hazardous
location assessment
 Simple and workable; incorporates all necessary wording of
Canadian Electrical Code
NFPA 664: Standard for the
Prevention of Fires and
Explosions in Wood
Processing and Woodworking
Facilities
BC Fire Code
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xix
Standard
Canadian Electrical Code
Count
15
Considerations
 As source of ignition
Reconsider CEC 18-008 (8 responses):
 Consider outcomes of Forest Products Innovations’ Report
on Wood Dust in the BC Forest Industry (March 2013):
Wood flour was <1% of wood dust material found in the
wood dust sampling process.
 We recognize the guidance materials make mention of wood
flour AND dust but the wording is too weak to be enforced.
 Should be a non-binding requirement
CEC Part I (1 response)
CEC 22.1-2 (1 response)
National Electrical Code
standard (US)
12
Occupational Health and
Safety Regulation (BC)
2
Occupational Health and
Safety Administration
standard (US)
8
Propane and natural gas
code
4
OHS 5.81 (1 response)
 As source of ignition
 Leaves too much room for interpretation for hazardous
location assessment
Propane and natural gas code handbook B149HB-05 (1
response)
IEC 60079-10-2: Explosive
atmospheres - Part 10-2:
Classification of areas Combustible dust
atmospheres
1
CSA Z462-12: Workplace
electrical safety
1
Other safety-related codes
relevant to the specific facility
1
*Note: These numbers are also included in the count of the individual codes listed
Other sources for guidance material or a list of standards were also suggested:
Other areas of reference
Count
Considerations
Industrial insurers
8
 There may be some industrial insurers that have guidance
material that could offer a practical composite of association
standards/codes
Standards referenced by
WorkSafeBC
1
 Facility already meets and exceeds standards that
WorkSafeBC used
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xx
Other recommendations were also made in response to this question.
Other
Industry needs to be engaged
in developing a Recognized
Industry Standard to
determine hazardous
locations
NFPA and CSA are not
regulatory bodies
Count
Considerations
11
 A transparent and objective measurement for wood dust
characteristics (i.e., moisture content, size) must be
established
 BC Safety Authority and WorkSafe BC need to work with
industry
 Most other monitoring would be dependent on these
standards
1
 Therefore some “best practices” may not be practicable.
Documenting identified combustible dust hazardous locations in Fire Safety Plan
One out of the twelve respondents who agreed that the Fire Safety Plan would be a suitable location for
the combustible dust hazardous locations added comments.
Yes: Comments
All facilities should have a fire
safety plan
Count
1
Specifications
 The plan should be posted so all employees can read it. (1
response)
If the Fire Safety Plan were considered not to be an acceptable location, respondents were asked to
suggest a more suitable location. The other documents recommended were:
No: Documents suggested
Count
Specifications
Combustible Dust Mitigation
and Control Plan (as ordered
by WorkSafeBC)
9
 Fire Safety Plan can reference the dust control plan –
redundant if this content is in the Fire Safety Plan (9
responses)
 Fire Safety Plan would be an acceptable location but it
would be better to locate in the formal dust control plan (1
response)
Safety program
2
 Combustible dust hazardous locations could be in fire safety
plan but also be part of other safety related plans and/or
other safe work procedures
Site Safety Order
1
Fire order
1
Hot works program
1
Attach to annual permit
1
 Not all locations have a Fire Safety Plan
Out of the three forms received that did not directly respond to this question, one explanation was given.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxi
N/A: Comments
Unaware of fire safety plan
Count
1
Specifications
 Facility has risk assessment document and tour
documentation detailing dust accumulations
Respondents also suggested adding flexibility to the documentation of combustible dust hazardous
location and mitigation plans.
Additional suggestions
Allow for flexibility
Count
8
Specifications
 Office of the Fire Commissioner has allowed for elements of
the Fire Safety Plan to be contained in various separate
documents as long as all content has been addressed; the
flexibility of this has been appreciated.
Overlap With Other Regulators
Regulator
Count
Specific regulations or requirements overlapping
WorkSafeBC
19
 Ensure alignment with Combustible Dust Mitigation and
Control Plan (11 responses)
 Areas of overlap:
 3.5: General requirement (1 response)
 4.1: Safe workplace (1 response)
 4.41: Waste material (1 response)
 G5.81 Combustible dust – Sawmill facility (1 response)
 Facility risk management (1 response)
 Worker safety code/regulation/guideline interpretation (1
response)
Office of the Fire
Commissioner
14
 Ensure alignment with:
 Content amendments to Fire Safety Plan (11 responses)
 Qualification of individuals to conduct hazardous location
assessments (3 responses)
 Requirements are already in BC Fire Code; process is
redundant (1 response)
 Fire safety code/regulation/guideline interpretation (1
response)
Fire Inspection and
Prevention Initiative (FIPI)
11
 Ensure alignment with qualification of individuals to conduct
hazardous location assessments (11 responses)
 BC Safety Authority is on FIPI steering committee;
collaboration is assumed (1 response)
Fire marshal
2
 NFP 664 (1 response)
BC Safety Authority electrical,
gas and boiler safety
programs
3
 Electrical inspections/BC Electrical Code (3 responses)
Occupational Health & Safety
1
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxii
Regulator
Count
Insurance underwriter
1
Environment Branch BC
1
Specific regulations or requirements overlapping
Other areas of potential overlap were also identified.
Areas of overlap
Count
Education requirements
1
Audits/inspections
1
Specifications
Additional comments were also provided.
Comments
Count
Additional comments
 Particularly if varying criteria
 All organizations should be aligned
Undue overlap causes
confusion for regulators and
industry
10
All organizations have their
own priorities/agenda
1
 Difficult to please all of them at the same time
Unknown which organization
is ultimately responsible
1
 Unknown under whose jurisdiction is the enforcement of the
Safety Order
 Dispute resolution mechanics should be in place
Timelines
Out of the seven wood processing facilities that found the timeline of June 15, 2013 to be achievable, two
added comments.
Achievable: Reasons
Achievable with enough lead
time
Count
Specifications
2
Stakeholders who responded “not achievable” gave the following reasons.
Not achievable: Reasons
BC Safety Authority needs to
finalize Safety Order first
Count
15
Specifications
 Areas that require finalization:
 Recommended qualifications of assessor (13 responses)
 Recommended hazardous location identifier (11
responses)
 Standard to determine hazardous locations (11 responses)
 Training programs (2 responses)
 Finding resources (1 responses)
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Impractical timeframe for
completing all requirements
14
 Impractical even if June 15, 2013 is the deadline to respond
to BC Safety Authority, not complete requirements (1
response)
 Three months is impractical, particularly given that BC
Safety Authority took over one year to establish the order (1
response)
Potential changes to
hazardous location criteria
11
 Major infrastructure changes for all of industry (11
responses)
 Large number of variances will need to be identified, then
approved by BC Safety Authority (10 responses)
Hiring
2
 Cost implications of hiring specifically for assessment (1
response)
 Availability of qualified assessors (1 response)
Four out of the six stakeholders who did not respond to this question deliberately did not respond whether
the timeline was achievable, citing the following reasons:
No response: Reasons
Count
Specifications
Some aspects are
achievable, while some are
not
1
 Dependent on size of wood processing facility and amount
of cleanup required (1 response)
Unknown whether achievable
2
 Completion of Part II depends on the amount of time Part I
of the Safety Order is completed (1 response)
 Unable to respond to this question
Electrical permit is in place,
gas permit is not applicable
1
Additional Comments
Stakeholders were asked for any additional opinions, suggestions and questions on the Safety Order.
Comment
Count
Specifications
Forest Industry Task Force
Wood Dust Mitigation and
Control Audit has been
developed by the
Manufacturers’ Advisory
Group
12
 Consider this as a starting point for auditing dust
management processes (11 responses)
 Consider accepting the audit as a Safety Order response (1
response)
Develop training/education
12
 Use to increase number of qualified individuals (5
responses)
 Use BC Fire Code, Natural Gas and Propane Code
handbook, CDN Electrical Code, NFPA 664, future industry
standards, etc. as guidance material (2 responses)
 Should be maximum three days long (1 response)
 Use developed course as hazard assessment qualification
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(1 response)
Align with other regulators
12
 Strategy needs to be designed to ensure greater
consistency between BC Safety Authority and other
organizations on this initiative (5 responses)
 Reduce redundancy (2 responses)
Communicate
updates/outcomes
11
 Strategy needs to be designed to communicate updates and
feedback on assessment, area classification, acceptable
mitigation strategies, and other information to all wood
processing facilities (5 responses)
Collaborate with industry
11
 Use current codes and standards as a starting point for
developing standards (5 responses)
 Continued engagement will help both compliance and
reputation for all organizations (1 response)
Hazard classifications
6
 BC Safety Authority’s definition of “hazardous” should be
primarily based on the code of the equipment regulated by
BC Safety Authority. (1 response)
 Should be classified as higher hazards:
 Storage silos (1 response)
 Dust collectors (1 response)
 Should be classified as lower hazards:
 Facilities that process green logs, or coast (2 responses)
 Primary break that is not enclosed and does not have heat
or gas (1 response)
Simplify
3
 Safety Order should be easy to follow (1 response)
Consider more flexibility in
application of Safety Order in
different types of facilities
3
 New versus existing facilities (1 response)
 Coast versus interior wood processing industries have
different processes, products and conditions: Conduct a
separate review for coast industry (1 response)
 Enclosed buildings versus open-ended buildings (1
response)
Use existing processes
2
 Inspections conducted by WorkSafeBC, electrical inspector
and insurance underwriter should suffice (1 response)
 Electrical and gas equipment should meet permit conditions
already established, and work processes should be taken
into consideration (1 response)
One-time assessment does
not capture everything
1
 One-time assessment by professional does not take into
consideration enough of the work environment; ongoing
monitoring by the operation should be conducted. (1
response)
 Recognizing hazardous locations is different than assessing
the potential of the dust hazard. (1 response)
Move deadline
1
 Deadline should be moved to December 1st, 2013. (1
response)
 A reasonable amount of time should be given to allow for
equipment or electrical changes. (1 response)
Consider requiring “dust tight”
electrical equipment in these
1
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types of environments
Responsibility seems to be on
owner
1
 What therefore is the role of WorkSafeBC? (1 response)
Increased difficulty in
obtaining insurance for mills
1
 Due to several mill fires in interior (1 response)
 Mills should self-insure (1 response)
Orders should not be given
without investigation
outcomes
1
 Ignition source at the mills where explosion occurred has not
yet been released. (1 response)
Cost is less important than
safety
1
 Low levels of enforcement will cost money and safety over
time. (1 response)
Consider incentive program
for upgrading facilities
1
 Facilities processing pine beetle killed wood, for example,
may need special assistance to achieve compliance with the
Safety Order. (1 response)
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APPENDIX D: VERBATIM RESPONSES RECEIVED
Question 1: Please identify what businesses you consider as being “wood processing”.
Someone that is making wood products.
A business that uses wood fiber to produce a finished product for sale.
1. Sawmill primary breakdown
2. Planer mill
3. Reman plant
4. Wood drying and sorting
Processing of raw logs
Wood planing
Molding of wood
Wood cutting
Wood sanding
1. Sawmills
2. Planer Mills
3. Value-added Operations (Finger-jointing, Pad Manufacturing)
4. Wood Pellet Plants
5. Wood Products Manufacturers
6. Pole/Preservative Operations
8. Log Home Builders
9. Veneer/Plywood Plants
10. OSB/MDF Plants
11. Shake & Shingle Mills
Any business that takes wood and wood based materials that are combustible and alters them using processes that produce dust
and fibres that may become combustible if exposed to a ignition source.
Any business that deals with the manufacturing of logs, lumber, or wood residuals.
• Sawmills
• Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Medium Density Fibreboard Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
• Post & Pole Manufacturing Facilities
• Sawmills
• Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Medium Density Fibreboard Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
• Post & Pole Manufacturing Facilities
• Sawmills & Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer/MDF Mills
• Oriented Strand Board Mills
• Pellet Plants
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• Wood Preserving Facilities
• Stile & Rail Fences
• Wood Moulding Facilities
• Remand (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities
• Chipping Facilities
• Post & Pole Manufacturing Facilities
CANFOR believes that the following businesses should be considered “wood processing”
facilities:
· Sawmills
· Planers
· Pulp Mills & Paper Mills
· Shake & Shingle Mills
· Plywood/Veneer Mills
· Oriented Strand Board Mills
· Pellet Plants
· Wood Preserving Facilities
· Stile & Rail Facilities
· Wooden Moulding Facilities
· Medium Density Fibreboard
Facilities
· Reman (ex. Finger Joint) Facilities
· Wood Furniture/ Doors/ Windows/
Truss/ etc. Facilities
· Energy Plants that consume wood
biomass
· Wooden Box Crate/Pallet Facilities
· Chipping Facilities
· Post & Pole Manufacturing Facilities
Sawmill, Planer Mill, OSB plant, Plywood Plant, Pulp Mill, Reman Plant, Moulding Plant
A facility which has machinery and equipment capable of altering or reconfiguring the shape, size and / or quality of wood fibre.
• Sawmill cutting hardwood
• Planer mill doing dry hardwood & green soft wood
• Paulcan fiber - dry kilns
• Sawmills
• Planers
• Pulp mills & Paper Mills (incl. tissue mills)
• Plywood
• OSB
• Pellet Plants
• MDF Plants
• Reman (ex. Finger joint plants)
• Wood Furniture/ doors/ windows/ truss/ etc. manufacturing facilities
• Energy Plants that consume wood biomass
• Chipping Facilities
• Sawmills
• Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Medium Density Fibreboard Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
• Post & Pole Manufacturing Facilities
• Sawmills
• Planers
• Pulp mills & Paper Mills
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• Shake & Shingle
• Plywood/Veneer
• OSB
• Pellet Plants
• Wood Preserving
• Stile & Rail Mfg
• Wooden Moulding Mfg
• Carpentry
• MDF Plants
• Reman (ex. Finger joint plants)
• Wood Furniture/ doors/ windows/ truss/ etc. manufacturing facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Mfg.
• Chipping Facilities
• Post & Pole Mfg
We believe that the following businesses should be considered “wood
processing” facilities:
• Sawmills
• Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Medium Density Fibreboard Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
• Post & Pole Manufacturing Facilities
Any facility that reworks or manufactures a product from wood. This would be from Logging to any product after.
a) Primary breakdown of logs into lumber, timber, posts & rails, and other rough sawn wood products.
b) Finish processing of lumber, timbers and other rough sawn wood products through planers, sanders, resaws, etc. to create a
finished surfaced product.
c) Remanufacture of rough sawn and finished or semi-finished wood products into finger jointed, laminated or other value added
products including beams, furniture, etc.
Sawmill, OSB, particle board, pellet mill
• Pulp mill woodrooms
• Pellet plants
• Planer mills / Remans
• Cabinet / window / door shops / plants
• Shake / shingle mills
• Post & rail
• Pole peeling operations
• Co-gen plants
• Sawmills
The following businesses are some that could be considered “wood processing” facilities:
• Sawmills
• Planers
• Pulp & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Medium Density Fibreboard Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
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• Post & Pole Manufacturing Facilities
• Sawmills
• Planers
• Pulp Mills & Paper Mills
• Shake & Shingle Mills
• Plywood/Veneer Mills
• Oriented Strand Board Mills
• Pellet Plants
• Wood Preserving Facilities
• Stile & Rail Facilities
• Wooden Moulding Facilities
• Reman (ex. Finger Joint) Facilities
• Wood Furniture/ Doors/ Windows/ Truss/ etc. Facilities
• Energy Plants that consume wood biomass
• Wooden Box Crate/Pallet Facilities.
• Chipping Facilities
• Post & Pole Manufacturing Facilities
• Firewood manufacturers
• Medium Density Fibreboard Facilities
Any operation which processes larger wood stock into smaller sizes (sawmills, plywood mills, wood rooms at pulp/paper mills,
particleboard plants, OSB plants, MDF plants, Engineered Lumber Products facilities, furniture manufacturing, woodworking shops,
pellet manufacturing, etc.).
Sawmills, planer mills, pulp mill sawdust/chip yards (note this does not including processing/cooking of fiber)
We are a market BCTMP mill
Any business, in either the primary or secondary wood processing industry that generates fine wood particulate, including, but not
limited to,
1. Sawmill operations
2. Planer operations
3. Plywood operations
4. Pulp mills & Paper Mills, including tissue mills
5. OSB plants
6. Pellet plants
7. MDF plants
8. Remanufacturing facilities (finger joint plants)
9. Wood Furniture/ doors/ windows/ truss/ etc. manufacturing facilities
10. Energy plants that consume wood biomass
11. Chipping facilities
Question 2:
How will this proposed Safety Order impact your business operation?
I do not totally understand all this but I do not make a lot of money now & may not be able to afford the expenses of doing this so
may have to shut down.
It will take time, money and resources to figure out how to comply with the order when the organization issuing the order has no
clear idea of what they want produced. It is unclear whether this order is achieving a purpose or simply trying to shift the blame for
any future incidents away from regulatory bodies.
1. Cost time to review and write fire safety orders and follow up.
2. Cost of inspector
This safety order would not impact our business to any extent as we do a major cleanup once a week as well some during the week.
Other than direct costs of implementation of Order, the majority of the items are part of Permit Compliance.
The impact of this safety order is going to improve safety with in facilities.
The downside to most safety incentives is the management of them and the cost implication.
It takes time to implent [sic] and train people, and added cost to buy and install new and improved equipment.
Allocation of man power in our clean up dept, proper training, electrical maintenance, and proper management of processes.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
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cost. The industry and BCSA must work together to ensure that these changes create a meaningful reduction of the risks posed by
potential ignition sources.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
cost. The industry and BCSA must work together to ensure that these changes create a meaningful reduction of the risks posed by
potential ignition sources.
The impact of this order is difficult to determine without knowing the final criteria that will be used to define "qualified professional"
and "a recognized industry standard", which are critical in the assessment of hazardous locations proposed in this order. Any
change to the current hazardous classification, in whole or in part, could have a significant financial impact on our operation.
Any changes to regulations in BC that increase the standard to which activities are completed, will have additional costs associated
with it. We strongly recommend that if changes are contemplated, costs should be considered, outcomes should create meaningful
risk reductions and the process should be collaborative with industry and BCSA working together.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
cost. Improving workplace safety continues to be a commitment of CANFOR. The industry and BCSA must work together to ensure
that these changes create a meaningful reduction of the risks posed by potential ignition sources.
The degree that our business is impacted depends on how many areas in the Sawmill and Planer Mill get classified as Hazardous
Locations.
We are committed to spending money expanding our dust collection systems to further reduce the risk of fire / explosions. If the
Sawmill becomes a hazardous location the cost of rewiring and replacing components to comply with the regulations will be a large
financial burden on top of the other measures we are taking to minimize risks, all of which cost money.
Many areas in the Sawmill have operator consoles and button stations which will need replacing to meet the hazardous location
requirements.
We are in agreement that combustible dust is a hazard. WorkSafeBC has inspected our facility and have been helpful in pointing out
areas that are of concern to them, to you, and to us, which we have in the last year addressed and each day are trying to keep on
top of. As well, our insurance provider has an interest in us maintaining a clean, safe mill. We as owners and employees also have
probably the greatest interest in keeping our mill safe. So our feeling is that this will be a duplication of what we have done, and are
doing. Thus mostly this will be a cost to our business that will only make us less competitive in a very competitive business.
Lumber remanufacturing is a complex business which operates within highly regulated local, municipal, provincial, federal and
international laws and rules. The addition of any new bureaucratic requirement will add additional administration and operational
costs to our business.
More paperwork
We already have to satisfy WCB and the electrical inspector, boiler inspectors, environment branch! How many people do we want
to get involved? Business is tough enough without more, and more, and more inspectors. Are we creating another dynasty!
Significant increase in costs from external resources.
Significant costs related to replacing/upgrading electrical equipment.
May effect business continuity.
If the process becomes cumbersome, time consuming and an administrative exercise it will tarnish the reputation and perception of
BCSA.
Any changes to equipment MUST make business sense and maintain a safe working environment.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
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• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
cost. The industry and BCSA must work together to ensure that these changes create a meaningful reduction of the risks posed by
potential ignition sources.
• This is difficult to determine without knowing the specific changes to the existing standards and classifications or the results of the
assessment.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of impact for the wood processing industry is from minimal expense, to significant capital cost, up to and including
the closure of facilities due to the cost of replacing gas and electrical equipment.
• All existing facilities in BC were designed and built to the existing standards at the time and have been inspected and audited by
the Electrical and Gas Inspectors for many years. There will be a significant financial and operational impact if new hazardous
classifications of wood dust are applied to, and enforced on, existing installations that satisfied the standards of the day. These
include, but are not limited to, facility and equipment re-designs, or replacements, replacement of electrical equipment and
infrastructure, and prolonged periods of facility downtime and lost production while changes are being implemented.
• Changes to regulations in BC that result in more stringent/onerous standards may place the BC industry in a competitive
disadvantage. Need to ensure that these changes are having a meaningful impact on the risks posed by potential ignition sources.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
cost. The industry and BCSA must work together to ensure that these changes create a meaningful reduction of the risks posed by
potential ignition sources.
This will mean an increased expenditure of money and time to comply. The Safety Order will also result in a safer and cleaner work
place.
a) It is difficult to project possible impacts to our operation. If in the interest of administration efficiency the whole of the "wood
processing" industry is treated as a single entity under one set of rules and therefore a secondary manufacturer such as ourselves in
bundled in with primary dry pine processing, I could see compliance becoming very expensive.
b) If the timeline of June 15 is to be held to it will likely require an additional employee at our operation.
c) Some possible impacts will be subject to the final definition of a "Qualified Professional"
Minimal impact on busienss. Change some of the housekeeping practices within the facility.
• Additional cost to maintain plant to new standards
• Plant is small in comparison to major operators (400 Amp service) building is not totally enclosed, therefore, not a risk
The impact of this order is difficult to determine without knowing the final criteria that will be used to define “qualified professional”
and “a recognized industry standard”, as these are critical drivers for the assessment of hazardous locations proposed in this order.
Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact ranges from minimal expense, up to and including the closure of facilities due to the requirement to
replace all existing gas and electrical equipment.
All facilities in BC were designed and built to the standards in force at the time of construction, and have been inspected and audited
by Electrical and Gas Inspectors over the years since. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
implement a new standard for the industry.
Changes to regulations in BC that change the standards, carry with them an associated impact on cost. The industry and BCSA
must work together to ensure that these changes create a meaningful reduction of the risks posed by potential ignition sources.
• The impact of this order is very difficult to determine without knowing the final criteria that will be used to define “qualified
professional” and “a recognized industry standard”, which are critical drivers for the assessment of hazardous locations proposed in
this order.
• Any change to the current hazardous classification, in whole or in part, will have a significant financial impact on the industry. The
potential range of the impact is from minimal expense, up to and including the closure of facilities due to the requirement to replace
all existing gas and electrical equipment.
• All facilities in BC were designed and built to the standards present at the time of construction, and have been inspected and
audited by Electrical and Gas Inspectors for many years. A major change to the hazardous location classification proposed by this
order will significantly impact all facilities, requiring time, financial resources, and regulator/industry collaboration in order to
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implement a new standard for the industry.
• Changes to regulations in BC that increase the standard to which activities are completed, carry with it an associated impact on
cost. The industry and BCSA must work together to ensure that these changes create a meaningful reduction of the risks posed by
potential ignition sources.
I see little impact assuming the order aligns with common codes.
As identified in the Mag meeting dated Feb. 19, 2013
The cost of implementing engineering remedies: e.g. replacement of equipment, installation of dust controls.
- Difficult to determine without knowing the specific results of the assessment process.
- The potential range of impact is from minimal expense up to and including the closure of facilities due to the enormous cost of
replacing heating and electrical equipment.
- Changes to regulations in BC that result in more stringent/onerous standards may place the BC industry in a competitive
disadvantage. Need to ensure that these changes are having a meaningful impact on the risks posed by these ignition sources.
No impact based on our current level of awareness and regulation
Although it is difficult to assess the impacts on business without knowing all of the specifics of the assessment process; there are a
number of areas that businesses could be impacted, including:
1. Significant costs to install new equipment and/or to modify existing equipment to ensure the equipment complies with this order
2. Utilizing a 3rd party to conduct the audits is concerning because,
a. the standards of a qualified professionals are not yet clearly defined
b. there is not a clear standard on who will, or who can deem a person to be a "qualified
professional" capable of conducting
the audit
b. lack of a verification system on how companies will be able to verify that a "qualified professional" is appropriately qualified
to conduct audits for an employer
c. the number of "qualified professionals" available to perform the audits in a timely fashion when needed by the industry to
meet deadlines imposed by this order
d. the ambiguity on what specific standard will be utilized for these audits and how they will be consistently interpreted by a
"qualified professional."
3. Changes to the regulations in BC may result in more stringent or onerous standards that may place the industry in a competitive
disadvantage to those jurisdictions with less onerous standards.
Question 3:
Under the first required action, it states: a. this assessment shall be conducted by a professional that is qualified to
identify combustible dust hazardous locations. What types of persons would you consider to be a "qualified
professional"?
2. MAG also has a serious concern around defining “qualified and/or professional” as there are many people that are very
experienced in dust mitigation yet do not carry any professional designation. There are not a lot of individuals in the province that
would be qualified AND carry a designation. We would like to see a standard to qualify or certify persons to conduct hazard
assessments specific to dust, perhaps a certification course/program through BCSA? I know as a stakeholder we would be glad to
send people to such course. Perhaps this is a long term plan…so then what would be in place in the interim? Has there been any
thought to adding a module onto the FSR program to include dust so that at a minimum a FSR would be qualified to conduct an
assessment?
A qualified professional needs to be someone that is aware of the codes being applied and the consequences that could result if not
followed. The person also has to have a good knowledge of the operating process and the hazards associated with the process.
The person needs to use a systematic tool for the process to ensure that all potential hazards are identified and mitigated.
The person needs to pass through a standardized training program to ensure that they understand and can apply the codes of
practice.
I am reading the Safety order for combustible dust and would like some more information on the qualified person to conduct the
combustible dust hazardous locations. In short terms where would I find this person.
1. Fire Chief or fire inspector
2. Insurance underwriter
3. WorkSafeBC
Fire department
Electrical inspector
Gas inspector
Ones listed under BC Safety Authority considers a qualified professional
Qualified Professional would be a person with practical knowledge of the operation and professional accreditation in Environmental
and Safety fields. IE: EP, CRSP, CHSC, IH.
A qualified person would be someone who is well versed in the fire code,electrical code and management of hazardous locations ,
but who can use common sense and has actually worked in these types of locations , not some one who is going to quote chapter
and verse with out a working knowledge.
Fire Marshall certificate, fire safety training, people with trade certificates ( gas, electrical) with experieince in dust control.
• The current description in the draft information bulletin is an acceptable starting point, however it is critically important that this
person contains industry and facility-specific knowledge in the application of the appropriate standards for the area that is being
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxiii
assessed. Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience.
Individuals with professional designations may be able to provide these attributes, as could other individuals with an appropriate
background in this field. These latter individuals should not be expressly excluded from the assessment process because they do
not currently hold a professional designation.
• The BC Safety Authority has indicated that they are “not experts in dust classifications.” This will be problematic from the
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
o This education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. Electrical equipment / heating equipment / etc.) considered during the
assessment.
I was sent the attached Safety Order along with some other information.
Page 2 indicates a “Qualified Company Representative or Consulting Professional who conducted the Hazardous Location
assessment”
What qualifications are necessary? What documentation would a “Company Representative” or “Consulting Professional” need to
have to be considered
qualified to do this work? Is there a list of “Consulting Professional” people available?
• The current description in the draft information bulletin is an acceptable starting point, however it is critically important that this
person contains industry and facility-specific knowledge in the application of the appropriate standards for the area that is being
assessed. Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience.
Individuals with professional designations may be able to provide these attributes, as could other individuals with an appropriate
background in this field. These latter individuals should not be expressly excluded from the assessment process because they do
not currently hold a professional designation.
• The BC Safety Authority has indicated that they are “not experts in dust classifications.” This will be problematic from the
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
o This education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. Electrical equipment / heating equipment / etc.) considered during the
assessment.
• The current description in the draft information bulletin is a good starting point, however it is important that this person contains
industry and facility-specific knowledge in the application of the appropriate standards for the area that is being assessed.
Specifically, the individual should be knowledgeable in:
• the process, and in particular, failure modes that could create a hazard
• the appropriate dust classification standards used in the identification of hazardous locations
• the appropriate requirements of the installation code (electrical or gas)
• the appropriate requirements of the BC Fire Code
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. electrical equipment / heating equipment / etc.) considered during the
assessment.
• The BC Safety Authority has indicated that they are "not experts in dust classifications." This may be problematic from the
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxiv
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
• There needs to be consistency between the training delivered to all regulatory agencies and and training that is being delivered to
all regulatory agencies and that which would be considered applicable to these qualified individuals.
This education and training must be developed with input from industry to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
In addition to creating consistency amongst current assessors, the objective of this training process should be to meaningfully
increase i) the number of qualified individuals that are able to complete assessments, and ii) the overall level of hazardous locations
knowledge across BC
Hazardous location assessments may require the involvement of more than one person in order to achieve knowledge and
experience requirements in the various topic areas considered during the assessment.
The current description in the draft information bulletin is an acceptable starting point, however it is critically important that this
person contains industry and facility-specific knowledge in the application of the appropriate standards for the area that is being
assessed. Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
· CANFOR believes that the key attributes for “qualified individuals” involved in hazardous
location assessments are knowledge and experience. Individuals with professional
designations may be able to provide these attributes, as could other individuals with an
appropriate background in this field. These latter individuals should not be expressly
excluded from the assessment process because they do not currently hold a
professional designation.
· The BC Safety Authority has indicated that they are “not experts in dust classifications.”
This will be problematic from the perspective of evaluating completed assessments and
granting variances that are requested by industry members. It also identifies a common
opportunity for both the industry and regulators around hazardous location training. For
this opportunity, CANFOR would like to make the following points:
o There needs to be consistency between the training that is being delivered to all
regulatory agencies and that which would be considered applicable to these
qualified individuals.
o This education and training must be developed with input from industry, to
ensure that it appropriately considers the range of operating conditions that are
present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this
training process should be to meaningfully increase the number of qualified
individuals that are able to complete assessments, and the overall level of
hazardous locations knowledge across British Columbia.
· Hazardous location assessments may require the involvement of more than one person,
in order to achieve knowledge and experience requirements in the various topic areas
(ex. Electrical equipment / heating equipment / etc.) considered during the assessment.
An electrical Engineer or Technologist familiar with hazardous location ratings and familiar with the wood industry
Don't know, but would be necessary for the person to be experienced in the sawmill industry.
Owner / Operator
Facility Manager
Facility Maintenance Personnel
Worksafe BC / Occupational Health and Safety Inspector
Insurance Property Inspector
Out safety committee, and owners
• We would support developing a standardized training to qualify individuals for the assessment, this is the only way to ensure
consistent assessment.
• Based on the criteria’s listed in the information bulletin, it would be a struggle to find a single qualified "professional" that is versed
in all the listed competencies. I would suggest some different wording to allow some flexibility in determination of a qualified
persons. I would change "...as one who is"....to "...as one who may have"...
• There are many people that would be “qualified” however do not have a professional designation, therefore years of applicable
experience should be taken into consideration for a qualified individual.
• It is critically important that this person contains industry and facility specific knowledge in the application of the appropriate
standards, including fire protection experience for the area that is being assessed.
• There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
• We would recommend that training be developed specifically for this purpose prior to releasing the order. This will give companies
an opportunity to take a course to conduct the assessment in-house if they chose to since there is no requirement that the
assessment be done by an external party.
- I would suggest removing "professional" from 1.a as this implies an engineer of some sort. By removing "professional" then it
would open up the definition a bit more and allow some flexibility in determining a "qualified" person. Most organizations under due
diligence and a requirement to demonstrate qualification if need be. This is nothing new.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxv
• The current description in the draft information bulletin is an acceptable starting point, however it is critically important that this
person contains industry and facility-specific knowledge in the application of the appropriate standards for the area that is being
assessed. Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience.
Individuals with professional designations may be able to provide these attributes, as could other individuals with an appropriate
background in this field. These latter individuals should not be expressly excluded from the assessment process because they do
not currently hold a professional designation.
• The BC Safety Authority has indicated that they are “not experts in dust classifications.” This will be problematic from the
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
o This education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. Electrical equipment / heating equipment / etc.) considered during the
assessment.
• Current description in the draft information bulletin is acceptable, however it is critically important that this person contains industry
and facility specific knowledge in the application of the appropriate standards for the area that is being assessed:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standard used in the assessment
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The term “professional” is not correct as there may be many individuals, internally and externally, to a company that possess the
above knowledge and skills that do not hold any specific professional designation and may not be “engaged in the business of”.
• In addition without a clear standard/guideline and an education and training package, there is no assurance that if a “professional”
is engaged that he/she has the necessary credential to perform the assessment.
• The BC Safety Authority has stated they are “not experts in dust classifications”? If the regulating body is not experts in dust or
hazardous location upon which the basis for the regulation and oversight exist, then who is?
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
o This education training must be developed with the engagement and input form industry and based on industry
standards/regulatory standards in a formal manner to ensure consistent application.
o Without a clear standard/guideline and a training package what metrics would the BCSA use to determine the acceptability or
unacceptability of the assessment?
• Hazardous location assessments may require the involvement of more than one person, in order to achieve qualification needs in
the various topic areas (ex. Electrical equipment / heating equipment / etc.).
• The current description in the draft information bulletin is an
acceptable starting point, however it is critically important that this person contains industry and facility-specific knowledge in the
application
of the appropriate standards for the area that is being assessed.
Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience.
Individuals with professional designations may be able to provide these attributes, as could other individuals with an appropriate
background in this field. These latter individuals should not be expressly excluded from the assessment process because they do
not currently hold a professional designation.
• The BC Safety Authority has indicated that they are “not experts in dust classifications.” This will be problematic from the
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxvi
o This education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. Electrical equipment / heating equipment / etc.) considered during the
assessment.
The existing Safety Authority already regulates the technologies involved. The various regulations, codes, and guidelines already
contain the necessary info to identify these areas. We do not need an additional layer of bureaucracy or the expense that would
create. Enforce the existing system.
a) Regional and Municipal Fire Inspectors
b) Regional and Municipal Electrical Inspectors
c) Safety Authority Boiler Inspectors
d) Representatives of WorkSafeBC
e) Industrial Hygienist
f) Professional Engineers
g) Company Management employed in maintenance and equipment design
h) Company Safety Officer
i) All of the above having experience and background training in the related systems.
A person who would have extensive knowledge of hazardous areas or a person trained for identifying those areas.
One who is knowledgeable in the operation of the operating process of the business application of various applicable codes and
hazardous conditions.
The current description in the draft information bulletin is a starting point, however it is critically important that this person has
industry and facility-specific knowledge in order to apply appropriate standards for the facilities being assessed.
Specific needs:
o knowledge of the process, and in particular, failure modes that could create a hazard
o knowledge of the appropriate dust classification standards used in the identification of hazardous locations
o knowledge of the appropriate requirements of the Code (electrical or gas)
o knowledge of the appropriate requirements of the BC Fire Code
The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience. Individuals
with professional designations may have these attributes, as could other individuals with an appropriate background in this field.
These latter individuals should not be expressly excluded from the assessment process because they do not currently hold a
professional designation.
The BC Safety Authority has indicated that they are “not experts in dust classification". This will be problematic from the perspective
of evaluating completed assessments and granting variances that are requested by firms. It also identifies a common opportunity
for both the industry and regulators around hazardous location training.
For this training opportunity the following factors should be considered:
- Need for consistency between the training that is being delivered to all regulatory agencies and that which would be considered
applicable to these qualified individuals.
- The education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
- In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
- Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (for example electrical equipment / heating equipment / etc.) considered during
the assessment.
• The current description in the draft information bulletin is an acceptable starting point, however it is critically important that this
person contains industry and facility-specific knowledge in the application of the appropriate standards for the area that is being
assessed. Specifically speaking:
o knowledgeable in the process, and in particular, failure modes that could create a hazard
o knowledgeable in the appropriate dust classification standards used in the identification of hazardous locations
o knowledgeable in the appropriate requirements of the installation code (electrical or gas)
o knowledgeable in the appropriate requirements of the BC Fire Code
• The key attributes for “qualified individuals” involved in hazardous location assessments are knowledge and experience.
Individuals with professional designations may be able to provide these attributes, as could other individuals with an appropriate
background in this field. These latter individuals should not be expressly excluded from the assessment process because they do
not currently hold a professional designation.
• The BC Safety Authority has indicated that they are “not experts in dust classifications.” This will be problematic from the
perspective of evaluating completed assessments and granting variances that are requested by industry members. It also identifies
a common opportunity for both the industry and regulators around hazardous location training. For this opportunity, we would like to
make the following points:
o There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxvii
considered applicable to these qualified individuals.
o This education and training must be developed with input from industry, to ensure that it appropriately considers the range of
operating conditions that are present in wood processing facilities.
o In addition to consistency amongst current assessors, the objective of this training process should be to meaningfully increase the
number of qualified individuals that are able to complete assessments, and the overall level of hazardous locations knowledge
across British Columbia.
• Hazardous location assessments may require the involvement of more than one person, in order to achieve knowledge and
experience requirements in the various topic areas (ex. Electrical equipment / heating equipment / etc.) considered during the
assessment.
Fire Protection Engineer or Safety Professional that is trained in or has knowledge of the hazards of combustible dust.
As identified in the Mag meeting dated Feb. 19, 2013
A consulting group consisting of various disciplines of engineering and/or seasoned experienced individuals who work in the
capacity of wood processing, fire investigation, accident forensic assessments and those agencies that apply regulatory
requirements throughout the industries.
Current description in the draft Information Bulletin is acceptable, however it is critically important that this person contains industry
and facility specific knowledge in the application of the appropriate standards, including fire protection experience for the area that is
being assessed:
- knowledgeable in the process, and in particular, failure modes that could create a hazard
- knowledgeable in the appropriate dust classification standard used in the assessment
- knowledgeable in the appropriate requirements of the installation code (electrical or gas)
- knowledgeable in the appropriate requirements of the BC Fire Code
There needs to be consistency between the training that is being delivered to all regulatory agencies and that which would be
considered applicable to these qualified individuals.
Persons with similar training and experience to our WSBC reps.
Consider whether the "qualified professional" contains a mixture of skills (engineering, fire prevention, operations, health and safety,
electrical and gas equipment in a saw milling environment)that it begs for a skilled trade - a ticked certification.
Question 4:
Under the first required action, it states: b. the assessment shall be carried out in accordance with a recognized industry
standard for combustible dust hazardous locations. Which of the stated standards in the Recommendations Report do you
consider as appropriate to guide the assessment of hazardous locations? Are there other standards that you would
consider more appropriate? If so, which standards and why?
The NFPA standards for combustible dust (664,668) and electrical standard (77) and pressure vessel standard are all important
codes to be aware of for this assessment, but these codes are not enough to understand the mechanisms of fire and explosions.
People are lulled into complacency too easily and accept more hazard than they have to because it has never hurt them before.
All the standards in the recommendations report.
1. BC Fire Code
2. Canadian Electrical Code
3. Propane and Natural Gas Codes
Standard that should be used are the fire code, electrical code ,gas and propane codes and other safety related codes that have
some relevance to each facility that is to be inspected.
ALL, cover different areas of fire safety and prevention.
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process (“Report on Wood Dust in the BC Forest Industry”) was released in early March of 2013. Given this, the
consideration of section 18-008 in the assessment process should reflect this sampling information.
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process (“Report on Wood Dust in the BC Forest Industry”) was released in early March of 2013. Given this, the
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxviii
consideration of section 18-008 in the assessment process should reflect this sampling information.
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
a) Which of the stated standards in the Recommendations Report do you consider as appropriate to guide the assessment of
hazardous locations?
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX 'B':
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process ("Report on Wood Dust in the BC Forest industry") should be available as of mid March of 2013. Given
this, the consideration of section 18-008 in the assessment process should reflect this sampling information.
b) Are there other standards that you would consider more appropriate to guide the assessment of hazardous locations? If so, which
standards and why?
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The US Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be applicable or
appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized
· All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
· Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process (“Report on Wood Dust in the BC Forest Industry”) was released to your organization on March 8, 2013.
Given this, the consideration of section 18-008 in the assessment process should reflect this sampling information.
· There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
· The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
· Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
The Canadian Electrical Code
Worksafe BC / Occupational Health and Safety
BC Fire Code
We already meet & exceed all standards put in front of us by WCB
All would be appropriate guidelines for determination of hazardous locations.
I would highly recommend you stick with the mainstream type standards such as the fire code, electrical code or NFPA. Here is
some feedback on each...
NFPA 664 is already being referenced by worksafe and their description of 1/8" over 5% of the total surface area has already been
adopted by most facilities. It is an easy and relatively objective measurement that is widely accepted in industry already. No special
training or tools required for this. NFPA 499 language supports 664.
CEC part 1 is not descriptive enough. Group G includes wood flour...but the recent tests done by FP Innovations of all the sawmills
indicated there is less than 1% wood flour (<75 microns) in all the samples collected. I would struggle to accept the industry would
be in a group G solely because of this. We recognize the guidance materials make mention of wood flour AND dust but the wording
is too weak to be enforced.
BC Fire Code leaves too much room for interpretation and facilities to manipulate the assessment. It classifies a hazard location
when it has combustible dust present in quantities enough to create a hazard. Based on this most facilities will not be hazardous
because combustible dust according to NFPA is particle size less than 420 microns AND greater than 5% of total area, or has an
airborne concentration of greater than 40g/m3. Worksafe has already inspected all sites and those in compliance will automatically
mean they are not hazardous.
The Natural Gas and Propane code is similar to the fire code.
a) Which of the stated standards in the Recommendations Report do you consider as appropriate to guide the assessment of
hazardous locations?
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xxxix
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust
b) Are there other standards that you would consider more appropriate to guide the assessment of hazardous locations? If so, which
standards and why?
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
Which of the stated standards in the Recommendations Report do you consider as appropriate to guide the assessment of
hazardous locations?
• All four are appropriate as guide to hazardous locations. It is imperative that the portions Standards and Codes that are used to
develop the industry standards are clearly articulated. NFPA/CSA is not a regulatory bodies and as such provide a “best practices”
which may or may not be practicable. Options need to be developed or provided to allow risk control. The Canadian Electrical Code
APPENDIX ‘B’ Rule 18-008 is specific to wood flour and not wood dust. Wood Dust and Wood Flour are two different classifications
of wood dust. Generally Wood Flour is considered to be dust that is less than 75 microns. The FP Innovation Report on Wood Dust
in the BC Forest Industry, which will be released on Feb 27, 2013, indicates that wood flour was a very small percentage of the
wood dust sampled, less than 1%. 18-008 should remain a non-binding requirement
Are there other standards that you would consider more appropriate to guide the assessment of hazardous locations? If so, which
standards and why?
• There may be some industrial insurers that have guidance material that may offer a practical composite of association
standards/codes.
• OSHA and NEC standards may be applicable or appropriate.
• Industry must be engaged and involved in development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process (“Report on Wood Dust in the BC Forest Industry”) was released in early March of 2013. Given this, the
consideration of section 18-008 in the assessment process should reflect this sampling information.
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
NFPA 499,664, IEC 60079-10-2 Explosive atmospheres-Part 10-2: Classification of areas
Natural Gas and Propane Code Handbook (B149HB-05)
Canadian Electrical Code Part 1 (C22.1-2
a) I believe the British Columbia Fire Code is a workable standard. It is simple and workable and incorporates through its wording,
all pertinent rules within the Canadian Electrical Code.
b) There will be overlaps in all standards. More importantly I believe the overlaps must be working with the same and common
standard.
Appropriate standards for assessment would be any source of ignition, i.e., gas, electrical
Hazardous locations due to accumulation of dust that has explosive characteristics.
All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
develop hazardous locations criteria need to be clearly articulated in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
• All four of the stated standards are guides to hazardous location assessments. However, the eventual standards that are used to
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xl
develop hazardous locations criteria need to be clearly articulated, in order to achieve consistency across the industry and support
the development of options that allow for appropriate risk control.
• Of specific technical note from the information included in the Draft Information Bulletin (Canadian Electrical Code: APPENDIX ‘B’:
Rule 18-008) is the reference to wood flour. Wood flour, which is material that is less than 75 microns in size, composed less than
1% of the wood dust material that was collected during the Forest Products Innovation wood dust sampling process. The full report
for this sampling process (“Report on Wood Dust in the BC Forest Industry”) was released in early March of 2013. Given this, the
consideration of section 18-008 in the assessment process should reflect this sampling information
• There may be some industrial insurers that have guidance material that could offer a practical composite of association
standards/codes.
• The United States Occupational Safety and Health Administration (OSHA) and National Electrical Code standards may be
applicable or appropriate as additional guidance in this process.
• Industry must be engaged and involved in the development of common/acceptable Recognized Industry Standards (RIS’s) to
determine hazardous locations.
CEC 2012 also consider reviewing CSA Z462-12
- There may be some industrial insurers that have guidance material that may offer a practical composite of association
standards/codes.
- OSHA and NEC standards may be applicable/appropriate.
- Industry must be involved in development of common/acceptable Recognized Industry Standards (RIS's).
OHS 5.81
We do note that regardless of the training of a qualified professional, there remains a need for transparent and objective
measurement for wood dust characteristics (in terms of moisture content and size) and accumulation - ie., quality and quantity, in
order for industry to effectively engage in ongoing monitoring to ensure wood processing facilities are not creating deflagration
hazards in any environment. BC Safety Authority and WorkSafe BC need to work with industry to establish acceptable standards in
this area, around which other monitoring, including the identification of locations, in part depends.
Question 5:
Part I, section 3 states: incorporate any identified combustible dust hazardous locations and the chosen means to manage
the combustion hazards into the facility’s Fire Safety Plan, or where no Fire Safety Plan is required, another suitable
facility document. Do you consider the Fire Safety Plan as a suitable location to store this information?: yes/no
If you responded no, where do you think is a more appropriate documentation storage location?
1. Site Safety Order
2. Safety program < fire orders < hot works program
All facilities should have a fire safety plan. It should be posted so all employees can read.
Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and Control
Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the duplication
of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
• No. Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and
Control Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the
duplication of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and Control
Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the duplication
of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
• No. Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and
Control Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the
duplication of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s
Office has been flexible about the location of this content, provided that the necessary elements have been met. CANFOR would
encourage a similar approach moving forward.
I would like to see it on a separate document. Not all locations will have a a Fire Safety Plan. Attach it to the annual permit.
hazardous locations should be identified in the facilities formal dust control plan. The dust control plan AND hazardous locations is
already a requirement by worksafes first combustible dust order, so it would not be a big project to incorporate or revise the existing
document.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xli
Fire Safety plan is very descriptive under the fire code and by adding hazardous locations it would be redundant of the dust control
plan, then it will become a document management problem. The fire safety plan should identify common hazards in the facility and
reference the dust control plan for specifics.
• No. Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and
Control Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the
duplication of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
• The Fire Safety Plan may be appropriate to house this information, or it may be appropriate to include this information in other
suitable programs or plans up to and including other regulator’s requirements for wood dust hazard mitigation and control plans (ex.
WSBC).
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, Safety Programs,
Emergency Response programs, Wood Dust Mitigation and Control programs. As long as all the necessary elements of a Fire
Safety Program are addressed it has not been an issue with the Fire Commissioners Office what form or format it is contained in!
• The requirement for a Combustible Wood Dust Mitigation and Control Plan is a more likely location for this risk assessment and
mitigation controls.
• Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and Control
Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the duplication
of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a similar
approach moving forward.
Orders issued last spring by WorkSafeBC required industry to develop and implement Combustible Dust Mitigation and Control
Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the duplication
of information, we should strive to connect these two processes.
Many of the elements of a Fire Safety Plan are imbedded in other programs and documents in the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
• Orders issued last spring by WorkSafe BC required industry to develop and implement Combustible Dust Mitigation and Control
Plans, which included a risk assessment process as well as various other content requirements. In order to prevent the duplication
of information, we should strive to connect these two processes together.
• Many of the elements of a Fire Safety Plan are imbedded in other programs and documents on the worksites, including Safety
Programs, Emergency Response programs, Wood Dust Control Programs, etc. Historically, the Fire Commissioner’s Office has
been flexible about the location of this content, provided that the necessary elements have been met. We would encourage a
similar approach moving forward.
I am not aware of a fire safety plan; we have a risk assessment document and tour documentation detailing dust accumulations.
Identified combustible dust hazardous locations could be included in the fire safety plan. However, these combustible dust
hazardous locations may also need to be part of other safety related plans and/or other safe work procedures.
Question 6:
In your opinion, are there terms within the proposed Safety Order that you think overlap with existing regulatory process
for the Office of the Fire Commissioner or WorkSafe BC?: yes/no
If you responded yes, which agency and what specific terms do you think are an overlap?
WorksafeBC has already requested a dust management plan.
1. Fire Commissioner
2. WorkSafeBC
3. Our insurance underwriter
The Office of the Fire Commissioner
WorkSafeBC
BC Safety Authority
- BC Electrical
- BC Gas
- BC Boiler
All need to be on the same page and have the same guidelines for dust control.
WorkSafe BC has Regulation that applies to these circumstances:
3.5 General requirement
Every employer must ensure that regular inspections are made of all workplaces, including buildings, structures, grounds,
excavations, tools, equipment, machinery and work methods and practices, at intervals that will prevent the development of unsafe
working conditions.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xlii
4.1 Safe workplace
A workplace must be planned, constructed, used and maintained to protect from danger any person working at the workplace.
4.41 Waste material
Refuse, spills and waste material must not be allowed to accumulate so as to constitute a hazard.
OHS Guideline G5.81 Combustible dust – Sawmill facility.
All the relevant agencies have own priority agendas and trying to please them all at once is usually very frustrating and difficult.
Worksafe: facility risk management, written dust control program
Fire Marshall: NFP 664
Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both regulators and
industry. The items below highlight some of the potential duplication and overlap that could occur.
o WorkSafe BC
§ Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) – see comment above.
o FIPI (Fire Inspection and Prevention Initiative)
§ This group is working on establishing the qualifications of individuals that will be suitable for identifying hazardous locations. We
need to ensure that the direction taken by the BC Safety Authority is consistent with the direction of the FIPI group.
o Office of the Fire Commissioner
§ This office is responsible for the application of the BC Fire Code, which includes the content requirements of the Fire Safety Plan.
We need to ensure that proposals for Fire Plan content amendments are consistent with the objectives of the responsible agency
and are an efficient way to manage this information for industry.
• Yes. Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both
regulators and industry. The items below highlight some of the potential duplication and overlap that could occur.
* WorkSafe BC: Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) - see comment above.
* FIPI (Fire Inspection and Prevention Initiative): This group is working on establishing the qualifications of individuals that will be
suitable for identifying hazardous locations. We need to ensure that the direction taken by the BC Safety Authority is consistent with
the direction of the FIPI group.
* Office of the Fire Commissioner: This office is responsible for the application of the BC Fire Code, which includes the content
requirements of the Fire Safety Plan. We need to ensure that proposals for Fire Plan content amendments are consistent with the
objectives of the responsible agency and are an efficient way to manage this information for industry.
• Overlapping standards with varying criteria from different regulators create unnecessary confusion for both regulators and industry.
The items below highlight some of the potential duplication and overlap that could occur.
• WorkSafeBC: Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) - see comment above.
• FIPI (Fire Inspection and Prevention Initiative): This group is working on establishing the qualifications of individuals that will be
suitable for identifying hazardous locations. We need to ensure that the direction taken by the BC Safety Authority is consistent with
the direction of the FIPI group.
• Office of the Fire Commissioner: This office is responsible for the application of the BC Fire Code, which includes the content
requirements of the Fire Safety Plan. We need to ensure that proposals for Fire Plan content amendments are consistent with the
objectives of the responsible agency and are an efficient way to manage this information for industry.
· Yes. Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both
regulators and industry. The items below highlight some of the potential duplication and overlap that could occur.
o WorkSafe BC
§ Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) – see comment above.
o FIPI (Fire Inspection and Prevention Initiative)
§ This group is working on establishing the qualifications of individuals that will be suitable for identifying hazardous locations. We
need to ensure that the direction taken by the BC Safety Authority is consistent with the direction of the FIPI group.
o Office of the Fire Commissioner
§ This office is responsible for the application of the BC Fire Code, which includes the content requirements of the Fire Safety Plan.
We need to ensure that proposals for Fire Plan content amendments are consistent with the objectives of the responsible agency
and are an efficient way to manage this information for industry.
It is unclear which agency is ultimately responsible for the enforcement of the proposed order. The jurisdiction seems to fall into a
hazy gray area of Worksafe BC, Occupational Health and Safety, Electrical Inspection, Municipal Fire Inspection, Etc. Who or what
is the business actually accountable to and whom do they reference any dispute resolution mechanics?
• WCB
• BC Electrical Code
• Environment Branch BC
-WorkSafeBC-Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012)
-FIPI (Fire Inspection and Prevention Initiative)-Qualification of individuals to conduct hazardous location assessments
-Office of the Fire Commissioner-Fire Safety Plan, and Qualification of individuals to conduct hazardous location assessments
-there will be overlap in education requirements and audits/inspections.
• Yes. Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both
regulators and industry. The items below highlight some of the potential duplication and overlap that could occur.
WorkSafe BC
Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) – see comment above.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xliii
FIPI (Fire Inspection and Prevention Initiative)
This group is working on establishing the qualifications of individuals that will be suitable for identifying hazardous locations. We
need to ensure that the direction taken by the BC Safety Authority is consistent with the direction of the FIPI group.
Office of the Fire Commissioner
This office is responsible for the application of the BC Fire Code, which includes the content requirements of the Fire Safety Plan.
We need to ensure that proposals for Fire Plan content amendments are consistent with the objectives of the responsible agency
and are an efficient way to manage this information for industry.
WorkSafeBC
Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012)
FIPI (Fire Inspection and Prevention Initiative)
Qualification of individuals to conduct hazardous location assessments
Office of the Fire Commissioner
Fire Safety Plan
Qualification of individuals to conduct hazardous location assessments
Redundant standards with varying criteria from the various regulators will create undue overlap and confusion for the regulators and
industry.
Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both regulators and
industry. The items below highlight some of the potential duplication and overlap that could occur.
o WorkSafe BC
§ Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) – see comment above.
o FIPI (Fire Inspection and Prevention Initiative)
§ This group is working on establishing the qualifications of individuals that will be suitable for identifying hazardous locations. We
need to ensure that the direction taken by the BC Safety Authority is consistent with the direction of the FIPI group.
o Office of the Fire Commissioner
§ This office is responsible for the application of the BC Fire Code, which includes the content requirements of the Fire Safety Plan.
We need to ensure that proposals for Fire Plan content amendments are consistent with the objectives of the responsible agency
and are an efficient way to manage this information for industry.
All areas of Combustible Dust control involve, Regulated Equipment and Fire and Worker Safety.
Any of the individual agencies are expected to interpret Regulations, Codes, and Guidelines. An electrical contractor for example is
required to install regulated equipment according to the Canadian Electrical Code. How they interpret and wire are then accepted or
denied by the Safety Authority.
Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both regulators and
industry. The items below highlight some of the potential duplication and overlap that could occur.
WorkSafe BC: Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) – see comment above.
FIPI (Fire Inspection and Prevention Initiative): This group is working on establishing the qualifications of individuals that will be
suitable for identifying hazardous locations. We need to ensure that the direction taken by the BC Safety Authority is consistent with
the direction of the FIPI group. As BC Safety Authority is on the FIPI Steering Committee we assume the coordination will be
enabled.
Office of the Fire Commissioner: This office is responsible for the application of the BC Fire Code, which includes the content
requirements of the Fire Safety Plan. We need to ensure that proposals for Fire Plan content amendments are consistent with the
objectives of the responsible agency and are an efficient way to manage this information for industry.
• Yes. Overlapping standards with varying criteria from different regulators will create undue overlap and confusion for both
regulators and industry. The items below highlight some of the potential duplication and overlap that could occur.
- WorkSafeBC
- Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012) - see comment above.
- FIPI (Fire Inspection and Prevention Initiative)
- This group is working on establishing the qualifications of individuals that will be suitable for identifying hazardous locations. We
need to ensure that the direction taken by the BC Safety Authority is consistent with the direction of the FIPI group.
- Office of the Fire Commissioner
- This office is responsible for the application of the BC Fire Code, which includes the content requirements of the Fire Safety Plan.
We need to ensure that proposals for Fire Plan content amendments are consistent with the objectives of the responsible agency
and are an efficient way to manage this information for industry.
All AHJs should be following the fire codes (NFPA, etc.) which in effect make this process redundant.
I am unable to answer this question
• WorkSafeBC - Combustible Dust Mitigation & Control Plan (WSBC Order April 4, 2012)
• FIPI (Fire Inspection and Prevention Initiative) - Qualification of individuals to conduct hazardous location assessments
• Office of the Fire Commissioner
- Fire Safety Plan
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xliv
- Qualification of individuals to conduct hazardous location assessments
• Redundant standards with different criteria from different regulators will add unneeded layering
Question 7:
Part II of the Safety Order states: any owner or operator of a wood processing facility that utilizes electrical or gas
equipment that requires a permit to operate that equipment must take three actions by June 15, 2013. Do you consider the
timeline of June 15, 2013 as: achievable/not achievable
If you responded not achievable, please explain.
You still have not decided what you want or what qualifications are required, and you are setting deadlines for someone else. You
have had over a year to come up with this and you want it implemented in 3 months from the time you decide what you want, with
no established training programs or people that meet the qualified standard.
I consider the timeline achievable in some cases and in some cases not achievable.
A - Size of wood processing facility.
B - The amount of cleanup required.
Which would require more follow ups and progress reports in a given timeline.
Achievable, with the condition of enough lead time given from when the Order is issued.
Certainly very unachievable in the time frame given.
At the moment there is no list of recommended inspectors to do the inspections and implement the requirements in a practical time
frame.
Also the cost implications for certain established businesses could be immense and a longer lead time would be needed to
implement a strategy to please all parties.
o There are many significant variables and unknowns included in the proposed order, including:
§ The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
§ There is no clear or concise standard to determine hazardous locations.
§ The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to the BCSA. The time lines for identifying if and where a variance is required, as well as the application and approval process
timelines will require significant field and administrative support from the BCSA.
o In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
The timeline of June 15, 2013 is not achievable. There are many significant variables and unknowns included in the proposed
order, including:
* The qualifications criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
* There is no clear or concise standard to determine hazardous locations.
* The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to BCSA. The timelines for identifying if and where a variance is required, as well as the application and approval process timelines,
will require significant field and administrative support from BCSA.
In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long term application of these adjustments will extend well beyond June 15, 2013.
There are many significant variables and unknowns included in the proposed order, including:
• The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
• There is no clear or concise standard to determine hazardous locations.
• The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to the BCSA. The timelines for identifying if and where a variance is required, as well as the application and approval process
timelines will require significant field and administrative support from the BCSA.
• In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
The timeline of June 15, 2013 is not achievable.
o There are many significant variables and unknowns included in the proposed order, including:
§ The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
§ There is no clear or concise standard to determine hazardous locations.
§ The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to the BCSA. The time lines for identifying if and where a variance is required, as well as the application and approval process
timelines will require significant field and administrative support from the BCSA.
o In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
It is not yet determined who is qualified to do the assessment.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xlv
Once it is defined, all the wood facilities will be trying to hire these people at the same time.
This has happened to us with crane safe.
Unknown at this time. The completion of the First part of the order in its varying degrees of complexity will ultimately determine the
timeline for the completion of Part two.
-Too many unknowns still such as which standards to follow, who is "required", what training/qualification is required or where to find
resources.
-Although industry understands that June 15th is a "response" date not necessarily a completion date, there are still issues with
establishing qualified persons and planning for identifying deficient equipment.
The timeline of June 15, 2013 is not achievable.
There are many significant variables and unknowns included in the proposed order, including:
The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not developed
or published a list of qualified suitable individuals to identify/determine hazardous locations.
There is no clear or concise standard to determine hazardous locations.
The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to the BCSA. The time lines for identifying if and where a variance is required, as well as the application and approval process
timelines will require significant field and administrative support from the BCSA.
In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
Too many variables and unknowns
1) The qualification criteria of the assessor have not been determined. The Office of the Fire Commissioner has not even begun to
develop or publish a list of qualified suitable individuals to identify/determine hazardous locations.
2) There is no clear or concise standard/guide to determine hazardous locations.
3) The potential impact of any hazardous classification change on industry may require a large number of variances that will be
submitted to the BCSA. The time lines for identifying, if and where, a variance is required, and the application time and process
approval will require significant field and administrative support from the BCSA.
Any changes to the current hazardous location criteria will require significant R&M, Capital or Closure and in some cases variances.
o There are many significant variables and unknowns included in the proposed order, including:
§ The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
§ There is no clear or concise standard to determine hazardous locations.
§ The potential impact of the hazardous location change for industry will likely require that a large number of variances be submitted
to the BCSA. The time lines for identifying if and where a variance is required, as well as the application and approval process
timelines will require significant field and administrative support from the BCSA.
o In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
a) This order states that the assessment done by a qualified professional yet what a "Qualified Professional" is has yet to be
defined. I believe our company has the professional qualifications within, to conduct this assessment in conjunction with our local
Municipal Fire Inspector and meet all requirements of Safety Order l.1.
We will in fact be proceeding on this matter but I am very uncomfortable in saying it can be accomplished by June 15 2013. I would
support the moving of this timeline out a further 60 days. Meeting June 15 would require hiring specifically for this purpose,
something a small company like ourselves can ill afford after five years of financial losses.
• Electrical permit in place
• Gas permit not applicable
The timeline of June 15, 2013 is not achievable.
There are many significant variables and unknowns included in the proposed order:
-The qualification criteria for the assessor has not been determined. As well, the Office of the Fire Commissioner has not developed
or published a list of qualified individuals to identify/determine hazardous locations.
- There is no clear or concise standard to determine hazardous locations. The potential impact of the hazardous location change for
industry will likely require that a large number of variances be submitted to the BCSA. The time lines for identifying if and where a
variance is required, as well as the application and approval process timelines will require significant field and administrative support
from the BCSA.
- In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
The timeline of June 15, 2013 is not achievable.
- There are many significant variables and unknowns included in the proposed order, including:
- The qualification criterion of the assessor has not been determined. As well, the Office of the Fire Commissioner has not
developed or published a list of qualified suitable individuals to identify/determine hazardous locations.
- There is no clear or concise standard to determine hazardous locations.
- The potential impact of the hazardous location change for industry will likely require that a large number of variances be
submitted to the BCSA. The timelines for identifying if and where a variance is required, as well as the application and approval
process timelines will require significant field and administrative support from the BCSA.
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- In the event of a significant change to the current hazardous location criteria, major infrastructure changes will be required by the
industry. The long-term application of these adjustments will extend well beyond June 15, 2013.
achievable given time.
Based on the information that has been provided to date, the proposed time line of June 15, 2013 is not achievable. There are too
many variables that are unknown at this time, including,
• Uncertainty of what the official qualification criteria of the assessor is
• Lack of official definitions on a hazardous environments
• Potential number of variances that may be submitted across British Columbia which will require very significant administrative
support in order to turn around approvals prior to the proposed deadline
• Changes that may be required to be changed in facilities (variances, capital projects etc) require defined standards, assessor
criteria, and time to complete actions.
Question 8:
All opinions, suggestions and/or questions will be reviewed and taken into consideration before the Safety Order is
finalized. Please provide any opinions, suggestions and/or questions you may have about any aspect of the Safety Order.
1. MAG has been working intensely with Factory Mutual, AON, Marsh, and many of the stakeholders (Canfor, Westfraser, Interfor,
Tolko, etc) and have developed a comprehensive dust mitigation audit. This was an initiative from the CEO’s of the companies in
addition to Worksafe’s increase demand in dust mitigation. The dust audit is finalized and will be presented to the CEO’s next week
and will be available publically. (MAG (Manufacturing Advisory Group) is made up of all the stakeholders to address industry
concerns and provide a single contact for regulators and such). MAG would like to know if this dust mitigation audit can/will be
accepted or recognized as indicated in 2(a) of the draft safety order? We would be glad to share the audit with you for review.
[Point #2 is covered by “qualified professional” question 3]
3. MAG would like to provide some input to identifying “hazardous locations” as it may be captured in the audit already. Both NFPA
and WorksafeBC have wording around “hazardous” or “combustible atmosphere”.
The owner of the facility is responsible for the identification of hazardous locations. It is appropriate that MAG work with those
owners to assist them in that process. Various standards define hazardous locations. As the BCSA is concerned with regulated
equipment, the definition of “hazardous” must begin with the appropriate equipment code, and then move into dust classification
standards. Guidance from other regulations such as WorkSafeBC may be suitable, but need to be evaluated against the equipment
code requirements.
4. We (MAG) have spoken to our respective CEO’s and the consensus is that MAG will provide feedback and support on behalf of
the companies.
5. Can we schedule a meeting with your team and MAG to discuss this in the next week or two?
A training program max 3 days long needs to be developed to cover the key aspects of the codes, fire and explosion mechanics,
and comprehensive hazard assessment. This course then could be used as a qualification for completing the hazard assessment to
a uniform standard.
A primary break only that is not closed in with no heat or g as use should be evaluated with a lower risk factor.
WorkSafeBC, the electrical inspector and our insurance underwriter should be all the inspecting we require, and these inspectors
already inspected and passed our mill.
Keep the Safety Order simple and easy to follow.
There is a concern that an assessment performed by a "professional" is done at a finite time and does not recognize the fluidity of
the environment in some operations. Recognizing hazardous locations is different than assessing the potential of the dust hazard.
All Electrical and Gas permitted operations must meet Permit Conditions. If the work process compromises those Permit
requirements they must be addressed immediately without an assessment. Therefore a one time assessment has little value as the
operation, by WSBC standards must inspect and monitor regularly, the work environment.
To make it more streamline and compliant with all other WorkSafe and Fire Marshall orders. Instead of having 3 different
corporations all saying the same thing regarding dust control.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xlvii
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
CANFOR believes that this requires a specific strategy and actions to address. With the proposed implementation of this order, what
is the strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
· As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
· Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
· CANFOR encourages the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and
Control Audit as a starting point for auditable dust management processes.
· CANFOR wishes to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
Move the deadline for audits to Dec 1st.
Allow a reasonable amount of time to implement any equipment or wiring changes to reduce the financial impact.
Consider a requirement that would make any electrical equipment and wiring in and around the Sawmill dust tight and reserve the
hazardous location rating for storage silos and dust collectors.
We feel there is such a wide range of wood processing plants from totally enclosed buildings working with dry wood fibre to plants
with open sides or ends that are processing green logs, even some coming directly out of water, even in the driest conditions this
sawdust is not an issue.
The Safety Order as it stands seems to put the entire operational responsibility on the business owner / operator which raises
questions about what function or role, if any, that Worksafe BC / Occupational Health and Safety has in implementing or enforcing
this order. They have not been named as "qualified professionals", nor was any other party in the draft.
What role does the insurance industry play in the "required actions" of the Safety Review? Insurers typically conduct their own
facility inspections with inspection professionals whose purpose is to determine the risk worthiness of the facility. Yearly thermoimaging, testing of electrical consolidation areas is also an industry requirement.
The Safety Order has grouped the entire BC Wood processing industry into one unit. In fact, it consists of two specific areas, the
coast and the interior. Grouping them together is like saying all farmers are farmers. A blueberry farmer is completely different than
a chicken farmer. Both are farmers but their products, processes and conditions are completely different. As is the coast and interior
wood industry.
We would like to see a specific separate review done for the coast where we maintain that potential for wood dust combustion is and
remains extremely unlikely.
With all mill fires in interior that happened it is now virtually impossible to get insurance, so it is the best interest not to have any
fires…all mills have to self insure!
• There have been inconsistencies in inspections and the standards that are being enforced by all Worksafe inspectors. Different
expectations and interpretations from inspector to inspector. What is the strategy within the BCSA in order to ensure greater
regulator consistency as we move into the implementation of new standards?
• We need to ensure that there is a communication strategy for feedback and updates to the auditable wood dust standards,
hazardous location assessors/classification, etc. to all stakeholders.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at Wood Processing facilities.
• Consider the use of the industry Wood Dust Audit and Guidance material created by MAG as a starting point for auditable dust
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xlviii
management processes.
• Coordinate with other regulators (FIPI and Worksafe) to reduce redundancy such as training, inspection, documentation, etc.
Reputation of each agency is delicate right now, to ensure continued industry participation continued engagement must be
mandatory. Also consider the concept of "Keeping it simple".
We question how orders can be released when investigations have not been released and have not determined the ignition source
at both mill explosions. It seems agencies are grasping at straws when they don't really know, and are simply putting orders out
based on their respective agencies. Hate to see the everyone barking up the wrong tree. The only thing anyone knows is dust is the
fuel. That’s it.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
• There have been inconsistencies in inspections and the standards that are being enforced by all regulators. What is the strategy
within the BCSA (FIPI) in order to ensure greater regulator consistency as we move into the implementation of new standards?
• We need to ensure that there is a communication strategy for feedback and updates to the auditable wood dust standards,
hazardous location assessors/classification, etc. to all stakeholders.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at Wood Processing facilities.
• Consider the use of the industry Wood Dust Audit and Guidance material as a starting point for auditable dust management
processes.
• Develop training/education based on the determined standards (BC Fire Code, Natural Gas and Propane Code handbook, CDN
Electrical Code, NFPA 664, to be developed industry standards, etc) that are available to increase the availability of qualified
individuals to complete these assessments.
• There should be some flexibility as to how the safety order and standards are applied to new constructions versus existing
installations.
• A subsidy, incentive, or assistance program could provide the means for existing facilities to upgrade their installations to meet
new standards. For example, wood product facilities processing pine beetle killed wood may be facing challenges not present in
other areas. A change in circumstance that is beyond their control may warrant special consideration and assistance in achieving
compliance.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between other regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies,
interpretations of these standards etc. that is available for all wood processing facilities.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
Low levels of enforcement cost lives and money to all facilities and agencies involved over time. Cost saving in this respect are only
temporary.
Suggestion:
assess facilities based on hazard level. i.e.,
severe -> moderate -> minimal
There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this should be addressed with a strategy and action plan.
Would like a strategy from the BC Safety Authority to ensure greater consistency both within its organization and between
regulators.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
xlix
As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for feedback
and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that is
available for all wood processing facilities.
Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC wood processing facilities.
We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified individuals
to complete these assessments.
• There have been inconsistencies in inspections and the standards that are being enforced by regulators across British Columbia.
We believe that this requires a specific strategy and actions to address. With the proposed implementation of this order, what is the
strategy of the BC Safety Authority to ensure greater consistency both within its organization and between regulators?
• As we move through the process of implementing this order, we need to ensure that there is a communication strategy (for
feedback and updates to industry) in regards to hazardous location assessments, area classification, acceptable strategies, etc. that
is available for all wood processing facilities.
• Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at BC Wood Processing facilities.
• We encourage the BC Safety Authority to consider the use of the Forest Industry Task Force Wood Dust Mitigation and Control
Audit as a starting point for auditable dust management processes.
• We wish to re-emphasize the importance of developing training/education in order to increase the availability of qualified
individuals to complete these assessments.
I would suggest you address any further discussions regarding this Safety Order with our Safety Manager [...] in regards to:
- a professional who is qualified as described in the Information Bulletin (under development)
- the assessment to identify combustible wood dust hazardous locations
- wood processing facility Fire Safety Plan
[...]
1. There have been inconsistencies within the industry in inspections and the standards that are being enforced by the various
regulators. What is the strategy within the BCSA (FIPI) in order to ensure greater regulator consistency as we move into the
implementation of new standards?
2. There needs to be a communication strategy developed for feedback and updates to the auditable wood dust standards,
hazardous location assessors/classification, etc. to all stakeholders.
3. Using the relevant sections of the current codes/standards as a starting point, we need to collaboratively (regulators and industry)
develop industry standards that have a specific focus on application at Wood Processing facilities.
4. Consider the use of the industry Wood Dust Audit and Guidance material as a starting point for auditable dust management
processes.
5. Develop training/education based on the determined standards (BC Fire Code, Natural Gas and Propane Code handbook, CDN
Electrical Code, NFPA 664, to be developed industry standards, etc) that are available to increase the availability of qualified
individuals to complete these assessments.
Report on Consultation
Draft Safety Order: Combustible Dust Hazards in Wood Processing Facilities Containing Electrical and Gas Equipment
BC Safety Authority
April 2013
l