Variance applications for non-compliant labs must be submitted by July 1, 2025
TSSA has determined that accredited training providers with laboratories or training areas that do not comply with the Technical Standards and Safety Act, 2000 must submit variance applications to the Technical Standards and Safety Authority (TSSA) by July 1, 2025, and achieve regulatory compliance by the end of their next audit cycle.
TSSA is waiving the fee for the variance application which must provide a list of non-compliances found in the laboratory or training area and the safety mitigations used to comply with the Code.
Background
TSSA’s review of its audit process for accredited training providers found that some equipment and laboratories used to train students may be non-compliant with applicable regulations and adopted Codes.
As there is no exemption in the Technical Standards and Safety Act, 2000 or its associated regulations and Codes that would permit the operation of non-compliant training equipment or laboratory, TSSA proposes to work with accredited training providers to bring these labs or training areas into compliance with the adopted Fuels Codes.
As a first step, accredited training providers should submit an application for a variance under section 36(3)(c) of the Act. To further assist compliance, TSSA is waiving the fee to apply for a variance and giving a six-month window for such applications.
How to Submit a Variance Application
- Complete the Application for a Variance/Deviation (Except Non-Certified Plastic Venting) – FS-004-v4. The variance application must provide the following information:
- A list of non-compliances with applicable Codes found in the laboratory or training area, such as:
- Venting not being compliant (as common venting may be used);
- Burner replacement that is not within the approval scope of the appliance; and
- Any other non-compliances contained within the laboratory or the setting where practical training is provided.
- Safety mitigations used instead of Code compliance, for example:
- Supervised instruction at all times by a TSSA certificate holder;
- A master shut-off valve that is clearly identified and readily accessible within the laboratory;
- Carbon monoxide alarm; and
- Any other safety mitigation incorporated into the laboratory setting (see Appendix A).
2. In the “For Office Use Only” section at the top right corner of the form, indicate “Training Provider Variance — Fee Waived”.
3. Submit the variance application to fssubmissions@tssa.org by July 1, 2025.
4. The variance inspection will be conducted on the applicant’s next TSSA training provider audit. A variance will be issued so long as the Director and/or their delegate are satisfied that the mitigations permit the laboratory or equipment to operate safely.
See Appendix A below additional mitigations in the Gas Technician 3 (G3) Instructional Lab Standard, or visit Accredited Training Providers in the Fuels Industry Professionals webpage.
For questions, please contact TSSA’s Customer Service Centre at customerservices@tssa.org or call 1-877-682-8772.
Appendix A
Additional mitigations may be found in the Gas Technician 3 (G3) Instructional Lab Standard under the section “Training Lab Safety Standards” which specifies the following:
- Written procedures outlining the safe conduct of students (PPE, appropriate and safe attire), the safe operation of all appliances, equipment and components, and the location of all safety features (E-stop, fire extinguishers and exit points) shall be established and approved by the Director.
- Review the “written procedures” with all students before commencing training in the lab. In addition, a sign-off document shall also be established to document the students’ review of the written procedures, including their name and signature indicating they understand the content of written procedures.
- Emergency shut-down (ESD) switches were signed and installed at points of egress [JL1] in the lab. These ESDs shall shut off the electrical supply and supply to the gas and/or oil-fired equipment in the lab.
- Fire extinguishers are readily available and signs are posted.
- Carbon monoxide detectors are installed and operated according to the manufacturer’s certified instructions.
- Smoke detectors and/or sprinklers are installed in the lab.
- The methane detector was installed and operated in accordance with the manufacturer’s certified instructions.
Safe effective venting of operational training appliances:
- Vented in accordance with current B149.1 Code and the manufacturer’s certified installation instructions or;
- Vented under an exhaust canopy in compliance with section 8.30 Venting of appliances into canopies detailed in the B149.1 Code.
- Sufficient make-up air and combustion air supply for all operational appliances. If louvers are used, they shall be interlocked to the gas supply.
- The gas supply shall conform to B149.1 requirements and include an interlocked solenoid valve with ESD switches and manual shut-off valves at each appliance drop.
- A visual indicator (light) that indicates the approved solenoid valve is in the on/open position shall be installed in a conspicuous location.
- Posting of safety shoes and safety eyewear requirements at all training lab access points.