As another crop drying
season commences, it is crucial to recognize that equipment, controls and federal/provincial
codes have changed significantly since your on-farm dryer was installed. Restrictions
on what you, as the operator of a dryer, can legally do are extremely important
to know should an incident occur and liability and/or insurance claims result.
Changes in training requirements, certification standards and processes affect
all natural gas, propane and fuel oil crop drying installations whether on-farm
or commercial. What you as the operator of an on-farm dryer (including grain dryers,
tobacco kilns, etc.) are accustomed to doing in terms of repairs, maintenance
and even start-up may not be permissible now. An incident resulting from some
action on your part which you were not authorized to perform could void your insurance
protection.
The main change has been the introduction of the Crop Dryer Technician (CDT) certificate
effective May 1, 2002 under changes to regulations (O.Reg.215/01) of the Technical
Standards and Safety Act 2000 (TSSA 2000). The CDT certification must be renewed
every two years. The CDT training program is 2 weeks in duration and costs $1,300
(excluding GST).
Under the TSSA 2000, there are a series of certificates:
• G1 - allows holder to install, service, etc., any natural gas or propane
appliance regardless of input. Work on piping or component containing liquid propane
(LP) requires a LP endorsement.
• G2 - allows holder to install, service, etc., any natural gas or propane
appliance whose input is not in excess of 400,000 BTU. Not permitted to work on
LP without LP endorsement.
• G3 - holder is essentially a “helper” under general or direct
supervision of a G1 or G2.
• DA - domestic appliance certificate allows holder to work on unvented residential
appliances whose input is less than 100,000 BTU (clothes dryer, range, barbeque,
etc.)
• CDT - allows holder to install, inspect, alter, purge, activate, repair,
service or remove a natural gas or propane fired agricultural crop-drying appliance
and the equipment and accessories essential to its operation but the person cannot
activate the appliance for the first time. The holder of a CDT cannot perform
duties related to the installation of piping and tubing systems that do not form
part of the appliance.
The Technical Standards & Safety Authority says that: “The majority of
crop dryers have an input in excess of 400,000 BTU’s. The only two certificates
that are acceptable are a G1 or a CDT. In the unlikely event that the crop dryer
has an input of 400,000 BTU’s or less, there are three acceptable certificates:
G1, CDT, or G2.”
What about consumers who service their own crop dryers? The TSSA says: “An
end user/customer or anyone else, is not permitted to install/service their own
crop dryer unless they are the holder of an appropriate certificate (G1, CDT).
Not only would this be illegal, but it may also void their insurance.”
What about people who choose to continue “working underground” without
proper certification? The TSSA says: “TSSA is currently increasing their
Inspection staff (currently 26 in Ontario) and placing a renewed emphasis on compliance
to the Regulations. A ‘non-conforming hot line’ is being established.
Certificate holders (CDT) will be encouraged to contact ... if they are aware
of any individuals installing/servicing crop dryers who do not have a G1 or CDT
certificate. Every person convicted of an offence is liable for a fine of not
more than $50,000 and/or imprisonment of not more than one year, or both. This
also applies to a director or officer of a corporate body who has a duty to see
that the Act is complied with. A corporate body convicted of an offence is liable
to a fine of not more than $1,000,000.”
Essentially, after initial ignition (which only a G1 can do), you can operate
your dryer, but you cannot legally make adjustments, repairs or replacement to
any component in contact with the fuel, controlling the fuel, or the combustion
of the fuel. Moreover, fuel distributors are under increased regulation and liability
as well for the adequacy and safety of installations to which they deliver product.
Therefore, gas and propane suppliers are very likely to enhance inspections of
installations. They will also be liable for reporting installations that are not
in compliance. It is also possible that insurance providers will increase inspections
of installations and operations.
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