What We Heard Report: Plant Supervision Requirements (Draft Directive)

Introduction

From Wednesday, August 13, through Friday, September 12, 2025, Technical Safety BC (TSBC) engaged with boiler, pressure vessel, and refrigeration (BPVR) chief engineers, owners, and operators on a draft directive intended to clarify requirements for plant supervision. The draft directive asked plant owners and chief engineers to develop procedures describing their plant premises, immediate vicinity, and controls needed to operate and maintain their plant safely.

This report summarizes the feedback we heard during engagement and our response to the comment themes.

Outreach and Participation

We invited over 900 BPVR chief engineers, owners, operators, and representative industry associations to participate in the consultation. We asked participants to read a draft version of the Plant Supervision Requirements directive on TSBC's Engage site.

Participants responded to an online survey asking about the readability of the draft directive, and their facility’s ability to follow the provided clarifications. Some participants chose to provide their feedback through email or phone. In total, 88 participants provided feedback during the consultation period.

Feedback method	Participants
Survey	82
Email	10
Phone call	1

Note: Several of the emails related to an issue with the consultation survey, corrected in the first day of the consultation. This table counts the number of participants in each feedback method, regardless of whether they participated through multiple methods. The table counts as participants submitting multiple submissions in the same feedback method one submission.

Participant Types

The intended participants for this consultation were owners/operators, chief engineers, and persons in charge of boiler and refrigeration systems, as they would be most impacted by this draft directive. In total, 71 chief engineers, operators, and persons in charge participated in this consultation. This table shows how many of each participant type provided feedback during the consultation period.

Participant type	Participants
Power engineer or operator	42
Person in charge	26
Owner	2
Industry association	6
Other*	16
Total	92

Note: “Other includes: Retirees, shift engineers, assistant chief engineers, maintenance or operations managers, technical compliance directors, electrical controls maintenance, etc.

Feedback

In addition to responding to the survey questions, participants provided feedback on the concerns and questions about following the requirements of the directive.

Ability to Meet Requirements

Most survey participants (78%) agreed they could, or somewhat could, meet the requirements of the directive.

Response	Participants	Percentage
Yes	50	61%
Somewhat	14	17%
Not at all	10	12%
I'm not sure	8	10%
Total	82	100%

Question: Do you believe your plant can implement the requirements of the draft directive?

Comment themes:

Current procedures do not meet requirements: Plants do not currently have procedures in place to follow the requirements of the directive. Owners and staff often have different perceptions around immediate vicinity and plant premises.

Our response

The purpose of this directive is to develop an understanding between owners, persons in charge, and operators about how to run their plant safely, taking into consideration their individual plant’s configuration, risks involved, and work requirements.

TSBC safety officers have the discretion to request documented procedures detailing how the plant will be operated safely.

Definition of “Plant Premises”

Most survey participants (87%) agreed the draft directive’s definition of “plant premises” was clear, or somewhat clear, and provided enough guidance for their role and responsibilities.

Response	Participants	Percentage
Yes	49	60%
Somewhat	22	27%
Not at all	9	11%
I'm not sure	2	2%
Total	82	100%

Question: Does the section on “plant premises” provide enough guidance to you in your role?

Comment themes:

Consider different configurations. Some chief engineers are in charge of plants that service multiple buildings, or multiple plants that are separated by a road. The directive could clarify whether the plant premises means the site’s land area, or specifically the equipment area.
Definition is clear. Participants appreciated the clarity on a long-standing issue in their industry.

Our response

The purpose of the directive is to have plant owners and chief engineers develop a procedure for the safe operation and maintenance of their plant for when the chief engineer or operator needs to leave the control room. This way, they can account for their individual plant and site configurations, staffing and reporting structures, remote monitoring capabilities, and other relevant factors.

Definition of “Immediate Vicinity”

Most survey participants (78%) agreed the draft directive’s definition of “plant premises” was clear, or somewhat clear, and provided enough guidance for their roles and responsibilities.

Response	Participants	Percentage
Yes	35	43%
Somewhat	29	35%
Not at all	16	20%
I'm not sure	2	2%
Total	82	100%

Question: Does the section on “immediate vicinity” provide enough guidance to you in your role?

Comment themes:

Specify time or distance. Some plants can span many square kilometers, meaning chief engineers and operators may be away from the control room for several minutes. Specifying the amount of time or distance the chief engineer or operator can be away from the plant would provide clarity and consistency in interpreting TSBC’s expectations and requirements.
The definition is clear. Participants noted that the directive clarifies the requirements for operating staff to safely run the plant.
TSBC involvement. A TSBC safety officer should assess sites to determine an appropriate time or distance.

Our response

The directive cannot prescribe a specific time or distance that would be reasonable for all plant configurations and situations. Plant owners, chief engineers, and operators are responsible for determining plant premises and immediate vicinity in the procedure they develop. TSBC safety officers may review and verify the procedure during site assessments.

Staffing and Responsibilities

Participants were concerned that plant owners and managers might interpret this directive in ways that shift more tasks to chief engineers and operators or reduce the need for shift engineers and relief staff.

Comment themes:

Additional tasks and responsibilities. Chief engineers and operators are often assigned building maintenance tasks that pull them away from their primary duty of overseeing the safety of the plant.
Power engineer staffing levels. Plant owners and managers may see this directive as an opportunity to reduce power engineer staffing levels, which would compromise safety.
Responsibility for plant development. The directive could better clarify who is responsible for the plant’s safety and who is best to develop the plant safety procedures.

Our response

The procedures should be developed jointly by the plant owner, chief engineer, and operators, as they are responsible for the safe operation of the plant under the regulation.

The directive is not intended to reduce the need for power engineers, operators, or staff to run the plant. All plants must still have a chief engineer or person in charge, who is responsible for the operation and maintenance of the plant and ensures that only qualified people perform regulated work in the plant. Additionally, all plants must have required coverage for the chief engineer or person in charge.

Ultimately, the owner is responsible for the safety of the plant. Chief engineers and operators have the expertise to explain risks associated with plant operations to plant owners and educate them to make decisions that make the plant a safer work environment.

We do not have a mandate to oversee and enforce whether an owner can delegate additional responsibilities to a power engineer.

Facility Types and Remote Monitoring

Participants asked how this directive relates to additional facility considerations, such as the type of facility, continuous supervision requirements, and the facility’s remote monitoring capabilities.

Comment themes:

Continuous supervision and special status plants. The directive does not clarify whether plants must be under continuous supervision and does not take special status plants into consideration.
Remote monitoring. The directive sounds like it is allowing for more remote monitoring.
Facility type. Different types of plants would have different needs and expectations for their chief engineers and operators. For example, an operator in a hospital would have more building maintenance duties compared to operators in chemical manufacturing plants and pulp mills.

Our response

This directive applies equally to continuous supervision, special status, and risk assessed plants. To apply for and maintain their status as a special status plant, they already have agreements and plans in place for plant supervision.

The purpose of the directive is to have owners, chief engineers, operators, and persons in charge determine plant premises, immediate vicinity, and operating procedures to keep the plant running safely. This way, they can account for different facility types, plant and site configurations, staff reporting structures, and other relevant factors.

Next Steps

The feedback we received during this consultation helps us to identify where we need to adjust our approach and clarify our language. We will publish the final version of the directive on Plant Supervision Requirements in the coming months.