On July 16, 2021, HRAI and HVI (Home Ventilating Institute) submitted a joint letter to Minister of Natural Resources Canada Seamus O’Regan regarding NRCan’s interpretation of standard CAN/CSA C439-18 and its impact on the Canadian H/ERV industry.
As members may be aware, CSA C439-18 specifies laboratory methods of testing for rating the performance of heat/energy-recovery ventilators. Procedures for determining air movement capabilities and the leakage of air from one airstream to another are also included. Packaged HRVs/ERVs that use a refrigeration cycle or circulating fluid to transfer heat between two isolated airstreams may be rated using this standard.
Canadian H/ERV manufacturers believe NRCan’s strict interpretation of the standard is unnecessarily restrictive and punitive to industry stakeholders and consumers.
In the letter, HRAI submits that NRCan’s application of the standard will require industry-wide re-testing and re-certification of all existing residential H/ERV models sold in Canada. Members estimate this process will take approximately eight years to complete, at significant cost to industry. This effort will divert industry resources and hinder manufacturers’ ability to develop more efficient H/ERVs, which will in turn result in higher costs for consumers, reduced variety of model options in the market, reduced manufacturing capacity, new housing completion delays and, most importantly, reduced IAQ for Canadian consumers.
The letter discusses in detail the key issues at stake for industry and consumers as well as some possible solutions, which include:
- Allowing manufacturers to submit data that relies on an alternative method to determine “exhaust air transfer ratio” (EATR), and allow publication in the Searchable Product Listings of models that were tested prior to October 2020 and found to have more conservative deviations in performance.
- Allowing publication of third-party certified ratings from a SCC-accredited Certification Body in the SPL, based on test results collected in accord with CSA C439-18 and provided to NRCan per EER clauses 278 and 280.
- Failing those concessions, postponing publication of NRCan’s EER SPL to no sooner than 12 months after approval of our first proposed solution, or January 1, 2026, to give Canadian H/ERV manufacturers adequate time to re-test and re-certify products.
HRAI, HVI, and Canadian H/ERV manufacturers urge Minister O’Regan to take immediate action and to work with industry on the interpretation and application of this standard.
For more information, contact Stephen Chartrand at 1-800-267-2231 ext. 276, or email schartrand@hrai.ca.