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HRAI has been meeting with Ontario’s Technical Standards and Safety Authority (TSSA) to discuss the possibility of creating an exemption in existing regulations for certain types of commercial air conditioning equipment that many in the industry believe could be safely exempted with minimal safety consequence to technicians or the public.  Specifically, HRAI proposed to have the following exempted under O.Reg. 220/01:

Single or interconnected refrigeration systems (packaged and split systems), including external piping (e.g. common header connection and etc.) coming out from manufacturer’s packaged unit(s), provided that:

a)     The total of all prime movers’ nameplate ratings (in the system) added together does not exceed 125kW;

b)     The system utilizes a “Class A1” refrigerant and the minimum design pressure for refrigerant is not greater than 500 psig;  and

c)      The manufactured unit(s) in the refrigeration system is (are) covered by the following standards and is tested and certified by an approved testing laboratory:

i)       CSA C22.2 No. 63 Household refrigerators and freezers

ii)     CSA C22.2 No. 92 Dehumidifiers

iii)   CSA C22.2 No. 117 Room air conditioners

iv)    CSA C22.2 No. 120 Refrigeration equipment

v)     CSA C22.2 No. 128 Vending machines

vi)    CSA C22.2 No. 236 Heating and cooling equipment.

HRAI made that case that this would be consistent with B52, Section 5.2 but added a provision that this proposed exemption should be limited only to systems running with Class A1 (non-flammable) refrigerants.  A proposed upper limit on design pressure is 500 psig was included to ensure CO2 systems would not be exempted as there is still too much uncertainty about safety issues for such applications to exempt them. 

An exemption of this type would mean that contracting firms whose scope of business is limited to these applications would be exempt from the regulatory requirements currently faced by the industry or, even if registration might still be required, the inspection protocols might be lightened to reflect the lower safety risk inherent in such systems relative to other refrigeration systems.

In December, TSSA agreed to form a Risk Reduction Group (RRG) to do a risk assessment on this proposed change.  HRAI staff and a small committee of contractors met with TSSA on January 31st to discuss the implications.  While no agreement was reached, there was some movement towards a compromise.  The committee will meet again in about a month.

For more information, contact Martin Luymes at 1-800-267-2231 ext. 235 or email mluymes@hrai.ca.