What We Heard Report: 2024 Boiler, Pressure Vessel and Refrigeration Code Adoption Consultation

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Introduction

From Wednesday, February 7 through Friday, March 8, 2024, Technical Safety BC engaged with boiler, pressure vessel, and refrigeration (BPVR) contractors, manufacturers, certificate holders, owners, industry associations, and other interested groups on the following:

• using the latest editions of the boiler and pressure vessel codes in BC, including CSA B51:24; and
• using the latest editions of the refrigeration codes in BC, including CSA B52:23.

This report summarizes the feedback we heard throughout the consultation.

Outreach and Participation

Before the code adoption consultation, we notified BPVR clients when CSA's public review process was open for comments on the codes:

• June 27, 2023: we notified refrigeration clients to provide feedback to CSA during the B52:23 public review process.
• September 14, 2023: we notified BPVR clients to provide feedback to CSA during the B51:24 public review process.

When we launched the code adoption consultation, we notified all BPVR clients by email. Additionally, we posted consultation notices on Facebook, Twitter, and our website. In total, 123 participants provided feedback in this consultation, including some feedback we received after the consultation closing date.

Note: This table counts the number of participants in each feedback method, regardless of whether they participated through multiple feedback methods.

Participant Types

We invited all BPVR contacts to participate in this consultation, primarily targeting BPVR contractors and manufacturers, as they would be most impacted by the code changes. In total, 30 BPVR contractors and manufacturers (representing about 2% of all BPVR contractors and manufacturers) participated in this consultation. This table shows the number of participants who provided feedback during the consultation.

Note: This table counts each participant in one participant type category, regardless of whether they fall into multiple categories or have participated through multiple feedback methods.
“Other” includes equipment suppliers, distributors, manufacturers of related products, consultants, inspectors, engineers and engineer supervisors, retirees, and participants who did not specify their participant type.

Feedback

We invited participants to read about high impact code changes on our Engage site and complete an online survey. The survey asked participants when they could meet the requirements of the applicable codes, and their overall support for adopting the new editions of the codes.

Boiler and pressure vessel codes

72% support for adoption

(based on 90 survey participants)

Participants commented on the code adoption and consultation process:

• more consultation is needed on new code requirements, specifically post-weld heat treatment and carbon steel impact testing; and
• more clarification is needed on whether to follow ASME BPVC codes or CSA B51 code where there are conflicts.

37% could meet code requirements within 6 months

(based on 90 survey participants)

Participants commented on the costs associated with meeting the new code requirements, including:

• manufacturing requirements for post-weld heat treatment, material impact testing, and pneumatic testing;
• purchasing code books;
• requalifying to new procedures; and
• replacing equipment (if applicable for these code changes).

Refrigeration codes

69% support for adoption

(based on 54 survey participants)

Participants made the following comments regarding the code adoption and consultation process:

• TSBC's consultation does not allow for input on the code from industry and code users.
• CSA B52:23 code needs to be adopted promptly to allow manufacturers to use climate-friendly A2L refrigerant and ensure the supply chain of air conditioning equipment in BC.

69% could meet code requirements within 6 months

(based on 55 survey participants)

Participants commented on the costs associated with meeting the code requirements, including:

• manufacturing requirements for post-weld heat treatment and pneumatic testing; and
• replacing equipment (if applicable for these code changes).

Next Steps

After a code adoption consultation, TSBC reviews and considers the feedback we receive. We then recommend to the Province of BC whether to adopt the codes and make the proposed changes to the Power Engineers, Boiler, Pressure Vessel and Refrigeration Safety Regulation. We will provide an update to the boiler, pressure vessel, and refrigeration industry on the outcomes of this consultation and the effective date of any new codes.