canadian electrical code full impact assessment...consistent with the application and compliance...

Canadian Electrical Code Full Impact Assessment

Subject 4064

Update Section 4: Installation of identified conductors at control locations

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Full Impact Assessment Subject 4064 Update Section 4 for the installation of identified conductors at control locations

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CONTENTS

1 INTRODUCTION TO THE FULL IMPACT ASSESSMENT ............................................... 3

2 PURPOSE OF THE FULL IMPACT ASSESSMENT ........................................................ 3

3 BACKGROUND OF THE CHANGE .................................................................................. 4

4 THE NATURE OF THE CHANGE ..................................................................................... 4 4.1 How is it different from the Status Quo? ......................................................................... 4

5 PURPOSE/ REASON FOR THE CHANGE ....................................................................... 4 5.1 What is the issue that the change is intended to address? ............................................ 4 5.2 How does the change accomplish the desired results? ................................................. 4 5.3 What are the implications/consequences if action is not taken? .................................... 5

6 WHY IS ACTION REQUIRED AT THIS TIME? ................................................................. 5

7 (14) PREVALENCE OF RULE USE IF ACCEPTED ......................................................... 5

8 IMPACT ON KEY STAKEHOLDERS ................................................................................ 5 8.1 (16) Largest type of stakeholder who would benefit ....................................................... 5 8.2 (24) Largest type of stakeholder who would be negatively affected ............................... 5 8.3 (15) Other stakeholders affected on frequent basis ....................................................... 6 8.4 Is the proposed change limited to a specific group/geographic area?............................ 6 8.5 What is the affected stakeholders’ readiness to act on the change(s) ........................... 6 8.6 Recommended stakeholder management strategy ........................................................ 6 8.7 Communication and implementation plan ...................................................................... 6

9 ANALYSIS OF ANTICIPATED ECONOMIC IMPACT ...................................................... 7 9.1 (20) The jurisdiction or stakeholder’s ability to compete based on incompatibility with other standards ............................................................................................................................. 7 9.2 (21) Complexity of Implementation (is training required to be able to implement the rule?) ........................................................................................................................................ 7 9.3 (22) Total costs to implement (for example cost to install, educate, to manufacture/or inspect, purchase additional product, and of the increased use of electricity) .............................. 7

10 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE) ................................ 7

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11 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS? ....................... 7 11.1 Are standards consistent with (or lesser/greater than) other jurisdictions? .................... 7 11.2 (23) Conflict with other Ministries or Codes .................................................................... 8 11.3 Consequence on other Departments/Ministries, e.g. apprentice training ....................... 8 11.4 Consequence on other Codes from other jurisdictions (US, European standards) ........ 8

12 CONSULTATION PROCESS ............................................................................................ 8

13 PROPOSED EFFECTIVE DATE OF CHANGES .............................................................. 8

14 APPENDIX 1 CODE RANKING TOOL VALUES ............................................................ 10

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1 INTRODUCTION TO THE FULL IMPACT ASSESSMENT

The Full Impact Assessment follows the rationale of the Canadian Electrical Code Ranking Tool (CRT) and provides supporting information to validate the rankings of the CRT. It includes all the questions of the CRT either verbatim or modified. However, the scope of the Full Impact Assessment extends beyond that of the CRT and therefore the document includes additional questions that may help to further substantiate the rankings.

The CRT is referenced throughout the Full Impact Assessment. Questions contained in the CRT are included in the Full Impact Assessment and identified by numbers in parentheses. Whenever applicable, chapter titles also include references to sections of the CRT discussed in the chapter.

While an effort has been made to follow the sequence of the CRT as closely as possible, risk – related and benefits – related questions have not been separated in the Full Impact Assessment to enhance the analytical function of the document.

2 PURPOSE OF THE FULL IMPACT ASSESSMENT

The purpose of the Full Impact Assessment is to provide the Provinces and Territories with an enhanced rationale and detailed assessment of a particular change to the Canadian Electrical Code (CEC). The following assessment is submitted for review to provincial and territorial regulatory authorities to aid with their adoption process of the Code. Jurisdictions may decide to conduct further analyses and hold additional consultations.

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3 BACKGROUND OF THE CHANGE

The purpose of Subject 4064 is to address safety concern issues arising from the introduction, on a large scale into our residential and commercial or institutional buildings, of automatic control devices for essentially energy management.

4 THE NATURE OF THE CHANGE

4.1 How is it different from the Status Quo?

Manual electromechanical switching devices are on the decline. This is not anymore a lifestyle choice which can be addressed by design. As an example energy management and monitoring codes mandate usage of occupancy sensors and photocells, remote controlled switches, and dimming circuits to harvest daylight so to proportion artificial light output with the addition of daylight present in a given location. Several of the Canadian Provinces and Territories have policies in place mandating such use and one of the impacts of such policies to manage energy resources is to impose into the CE Code a manner of installing energy control and monitoring devices and systems so that it is safe and simple and integrated into the CE Code and consistent with the application and compliance with other applicable Codes (such as an Energy Code) at the minimum expense in the economical sense of the term.

5 PURPOSE/ REASON FOR THE CHANGE

5.1 What is the issue that the change is intended to address?

Whether these automatic devices combine with energy management functions with home automation, aesthetic functionalities or else, the devices require the identified conductor to be present at the device location to function. Manufacturers can and do manufacture devices which leak to ground within CE Code limits in certain cases, but this scheme is a perversion of bonding philosophies of the CE Code and introduce, by accumulation resulting from large scale use of these devices, leakage to unacceptable levels. 5.2 How does the change accomplish the desired results?

The word “neutral” has been changed to “identified conductor” into the body of Rule 4-028 for strict application of the definition of “identified conductor” which includes “neutral” and which recognizes for the purpose of the existing part of Rule 4-028 that the “neutral” referred into 4-028 is in fact an “identified conductor” in most cases of usage.

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The subject addresses present and future installs. Manual general purpose switching devices do not require the identified conductor, but conversion to energy management devices becoming mandated cannot be effected economically if the branch circuit routing is not set as per proposal.

5.3 What are the implications/consequences if action is not taken?

Routing of the identified conductor to an automatic control device is no longer through specification or by design: it is now part of society’s fabric to manage its energy consumption footprint. The subject introduces changes that will help mitigate the accumulation of leakage currents from large scale use of these devices.

6 WHY IS ACTION REQUIRED AT THIS TIME?

This proposal is important in light of the fact that many municipalities are mandating energy management systems which make use of automatic control devices on a large scale.

7 (14) PREVALENCE OF RULE USE IF ACCEPTED

This rule is expected to be used very frequently as energy management systems are deployed in home/commercial and industrial settings.

8 IMPACT ON KEY STAKEHOLDERS

8.1 (16) Largest type of stakeholder who would benefit

These changes will benefit the general public, industrial and commercial facility owners, utilities, and buyers of new homes.

8.2 (24) Largest type of stakeholder who would be negatively affected

Installers of equipment as well as Repair and Maintenance Personnel, where applicable, will be required to install additional identified conductors. Training programs and literature, including electronic content, will need to be updated to include the change. Engineers/ Designers - The stakeholder group will be directly affected by the current revisions since it is their responsibility to familiarize themselves with the new identified conductor interconnections with automatic control devices.

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8.3 (15) Other stakeholders affected on frequent basis

The revision will affect a broad range of stakeholder groups, namely:

Electrical contractors. This group of stakeholders is responsible for the application of the Code. As such, they need to be informed about the recent amendments to help ensure full compliance with the Code’s requirements. The updates can be delivered through formal training or through industry literature depending on the current practices of a particular jurisdiction. It is the responsibility of individuals to keep informed of recent changes to the Code. Other standard development organizations (SDO). All references to the part of the CEC being modified will need to be updated in the relevant documents published by other SDOs. Provincial /territorial electrical regulatory authorities. This group of stakeholders will be responsible for enforcement of new requirements and will therefore need to be informed of recent amendments. Insurance. Insurance policies contingent on following the CEC will need to be updated. Builders. Need to be informed of the changes since they will have to be incorporated into constructions. Inspectors. This group of stakeholders is accountable for enforcing compliance with the Code, and should therefore stay informed about recent amendments. It is the responsibility of a particular province or territory to make the information on recent Code amendments available to electrical inspectors. Depending on the practice of a particular jurisdiction, the changes can be communicated through training (provided by the jurisdiction or a third party), or through jurisdiction-specific or national industry literature.

8.4 Is the proposed change limited to a specific group/geographic area?

The change will have a nationwide application. 8.5 What is the affected stakeholders’ readiness to act on the change(s)

Research has not revealed any evidence of market not being ready to implement the changes discussed in the revision. 8.6 Recommended stakeholder management strategy

Not applicable. 8.7 Communication and implementation plan

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Not applicable.

9 ANALYSIS OF ANTICIPATED ECONOMIC IMPACT

9.1 (20) The jurisdiction or stakeholder’s ability to compete based on incompatibility with other standards

The revision should not affect a jurisdiction’s competitive position. 9.2 (21) Complexity of Implementation (is training required to be able to implement the rule?)

Training will be required for all concerned personnel dealing with and installing Energy management systems. 9.3 (22) Total costs to implement (for example cost to install, educate, to manufacture/or inspect, purchase additional product, and of the increased use of electricity)

It was the consensus that this subject will create additional costs initially but will have limited cost impact in great majority of cases; it is an evolution of a long standing wiring practice, but economically neutral in wiring practice and positive in benefits with energy management schemes.

10 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE)

Compliance costs. Initial compliance will increase the anticipated project costs, but there are several options available to optimize costs.

Change of investment. Not applicable.

Job creation / job loss. Not applicable.

Labour mobility. Not applicable.

Impact on import/export of goods. Not applicable.

Certification and licensing. Not applicable.

Insurance. Not applicable.

11 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS?

11.1 Are standards consistent with (or lesser/greater than) other jurisdictions?

Currently there are no deviations from the national CEC on this item in provincial electrical codes.

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11.2 (23) Conflict with other Ministries or Codes

Not applicable.

11.3 Consequence on other Departments/Ministries, e.g. apprentice training

Not applicable. 11.4 Consequence on other Codes from other jurisdictions (US, European standards)

Not applicable.

12 CONSULTATION PROCESS

The following groups of stakeholders were involved in the consensus approval of this change as part of CSA’s standards development process. For details please refer to Appendix C of the Canadian Electrical Code.

Groups that have been involved in accepting this change include:

Regulatory authorities selected from various provincial, territorial and municipal electrical inspection authorities.

Owners/Operators/Producers selected from groups with national stature, representing the viewpoints of electrical equipment manufacturers, electrical installation designers and installers and electrical installation users.

General interest representatives selected from groups with national stature, representing the viewpoints of :

(a) fire chiefs

(b) electric utilities

(c) committees responsible for related electrical codes and standards

(d) fire insurers

(e) labour

(f) issuers of building codes, and

(g) educators

A regulatory/legislative body may want to hold additional consultations with all or some of these

groups within their jurisdiction to clarify issues specific to the jurisdiction.

13 PROPOSED EFFECTIVE DATE OF CHANGES

The change will be included in the CEC 2018 edition published January, 2018.

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5

Subject #4064

5

6

5

8

10

3

9

46

9

10

7

36

2

5

2

0

3

12

Total 94

Purely administrative Community's desire to change - Environment, Health, Safety

Safety consideration (Severity) Safety consideration (Frequency) For clarity

Crucial to harmonize

Technological change/New Rule

Total Score for Extent of Use

Total Score for Reason for Change

Extent of Use & Value AddPrevalence of rule use if accepted Number of stakeholders affected on frequent basis

Complexity of implementation

Largest type of stakeholder who would be negatively affected

Total Score for Risk of Changing Rule/ Staying Status Quo

Reason for Change

Risk for Changing Rule/Staying Status The jurisdiction or stakeholder's ability to compete based onincompatibility with other standards

Total costs to implement, e.g. cost to install, to educate, to manufacture,or inspect, increased product cost, increasedcost of electricity.

Conflict with other Ministries or Code

Largest type of stakeholder who would benefit

Benefit to society

10

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