ASTTBC Proposed Training Program - Frequently Asked Questions

Published date: 25 September 2013

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GENERAL FAQ

1.    Who is ASTTBC?
2. What is ASTTBC proposing?
3. Why is ASTTBC proposing this new program (i.e. what is the problem to be solved)?
4. What does “limited scope” mean?
5. Why is ASTTBC trying to create a new type of electrical worker that will result in “semi-skilled” workers doing electrical work?
6. Will all technologists and technicians need to take this training?

ISSUES/CONCERNS FAQ

7.    Who has concerns about this proposed new program?
8. What are the issues/concerns that have been identified?
9. What does BCSA think about these concerns?
10. Will this program undermine the safety of workers, working families, businesses, and the public?
11. Who will be providing the training?
12. How does ASTTBC propose to ensure that technologists and technicians have completed the training and that they will be competent to perform electrical work safely?
13. What about those who say that the program is a threat to public health and safety because only electricians should perform all electrical maintenance and installation work?
14. Has BCSA met with and/or communicated this information to the groups that are concerned?
15. What has been the response of these groups?
16. What does BCSA think about claims by people in favour of the proposed program that those who are against the program are claiming it is about safety (i.e. “wrapping themselves in the safety blanket”), but it is actually about protecting themselves from competition?

BCSA APPROVAL FAQ

17.   Has BCSA approved this new program?
18. Why did BCSA grant “conditional” approval?
19. Who is this “Provincial Safety Manager”? I thought BCSA was responsible?
20. But can BCSA approve certification programs run by someone other than BCSA?
21. Does that mean BCSA is giving ASTTBC the ability to authorize individuals to perform work that it regulates on the Safety Standards Act?
22. Then what exactly is BCSA approving or authorizing for ASTTBC?
23. Has BCSA/the Provincial Safety Manager done this before and, if so, when/where?

APPLICATION STATUS FAQ

24.   It has been over two years since BCSA granted conditional approval for this program. Has BCSA subsequently granted formal approval to the training program?
25. Has BCSA made suggestions to ASTTBC in terms of how to address these conditions?
26. What are the next steps in the approval process?
27. What happens if BCSA approves ASTTBC’s training program?
28. What if ASTTBC does not meet all of the conditions imposed by the Provincial Safety Manager? What will BCSA do then?

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I. General

1. Who is ASTTBC?

Technologists, technicians and technical specialists achieve professional recognition through the Applied Science Technologists and Technicians of BC (ASTTBC). The ninth largest self-regulating association in BC, ASTTBC has 10,000 Technology Professionals registered in 17 disciplines for technologists and technicians and 8 technical specialist occupation areas. Electrical, Electronics and Biomedical Engineering technologies are 3 of the 17 disciplines. For more information on ASTTBC, please visit their website at: http://www.asttbc.org/.

2. What is ASTTBC proposing?

ASTTBC is proposing a training program for its member technologists and technicians in Electrical, Electronics and Biomedical Engineering who perform a narrow scope of electrical work as part of their normal job functions and within their specialized fields of training and expertise. ASTTBC has applied for recognition of this training program to allow qualified technologists and technicians, in the 3 above mentioned disciplines only, to do this work in compliance with the Safety Standards Act.

3. Why is ASTTBC proposing this new program (i.e. what is the problem to be solved)?

The normal duties of Electrical, Electronics and Biomedical Engineering technologists and technicians often require them to interact with electrical equipment. Some of their work includes testing and calibrating equipment, and performing normal maintenance on the equipment in order to keep it functioning properly and safely. The equipment often requires specialized knowledge and training that is not covered under other training programs, such as the electrical Red Seal Apprenticeship program. The work requiring interaction with electrical equipment may be regulated electrical work, but technicians’ and technologists’ credentials are not recognized as qualifications to perform electrical work under the Electrical Safety Regulation. ASTTBC’s proposed program will provide additional training and experience in electrical work; recognition of the training program will allow these individuals to perform their work in compliance with existing regulations.

4. What does “limited scope” mean?

Electricians receive a broad scope of training in lay-out, assembly, installation, testing, troubleshooting and repair of electrical wiring, fixtures, control devices and related equipment in buildings and other structures. Electrical and electronics engineering technologists and technicians may work independently or provide technical support and services in the design, development, testing, production and operation of electrical and electronic equipment and systems. They are employed by electrical utilities, communications companies, manufacturers of electrical and electronic equipment, consulting firms, and in governments and a wide range of manufacturing, processing and transportation industries (Human Resources and Skills Development Canada; NOC 2011, pp. 236, 483 & 484). The electrical work done by Electrical, Electronics and Biomedical Engineering technologists and technicians only requires them to operate, test, calibrate or maintain existing equipment; their work does not include installation of electrical wiring or equipment, and it does not include any alterations to building wiring. ASTTBC’s proposed training will cover only those aspects needed to ensure technologists and technicians are capable of safely working on or around electrical equipment. These workers will not be trained as electricians and they will not be able nor authorized to perform the general duties of qualified electrical workers.

5. Why is ASTTBC trying to create a new type of electrical worker that will result in “semi-skilled” workers doing electrical work?

BCSA and ASTTBC have heard concerns from industry that this program will create “semi-skilled” workers, and have actively encouraged concerned industry stakeholders to engage with ASTTBC to assist in developing a comprehensive training program. ASTTBC’s proposed training program aims to promote safety by ensuring that its members have received training that is appropriate for the scope of work they do, and that they are capable of performing the work properly and safely. Those who believe that the training is inadequate are encouraged to contact ASTTBC to ensure that the training addresses those concerns.

ASTTBC is not proposing that technologists or technicians become electrical workers, or to change the normal job duties for technologists and technicians. The proposed program will build on existing skills and competencies to enhance their ability to safely perform their normal job duties, and to allow technologists and technicians to perform their normal job duties in accordance with the Safety Standards Act.

6. Will all technologists and technicians need to take this training?

No, only those technologists and technicians who are ASTTBC members in Electrical, Electronics or Biomedical Engineering and who perform electrical work as part of their normal job duties will require this training. Many technologists and technicians have existing credentials, such as trades qualifications or certification as manufacturer’s technical representatives, and will not need to take this additional training. This training program is not intended to become a substitute for other existing training programs or qualifications. Technologists and technicians who have existing credentials that are recognized under the Act will not be required to take this additional training.

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II. Issues/Concerns

7. Who has concerns about this proposed new program?

A petition was submitted to the Legislative Assembly on July 23, 2013, with 1,824 signatures calling on the provincial government “to reverse the BCSA action to allow other organizations to train and certify Electrical Work Practitioners.” The petition is backed by the Electrical Contractors Association (ECA) of BC, the Electrical Inspectors Association (EIA) of BC, the International Brotherhood of Electrical Workers (IBEW) of BC, and the BC Electrical Articulation Committee (EAC) of electrical apprenticeship instructors from public technical training institutions.

8. What are the issues/concerns that have been identified?

Among the issues and concerns expressed are:

  • That BCSA’s action breaches the Safety Standards Act by ceding provincial authority to grant Certificates of Qualification to a non-independent, third-party organization;
  • That the new certification will result in allowing “semi-skilled” workers the right to perform regulated electrical work in BC without adequate training (480 hours compared to 7,200 of schooling and on-the-job training required by a certified electrician);
  • That, as a result, this will jeopardize public safety, the safety of other workers and potentially impact clients when it comes to manufacturer warranties;
  • That this action fails to recognize the authority of the Industry Training Authority (ITA) as the governing body for trades training and trades qualifications in BC;
  • That a new certification will undermine the one national training standard, called a Red Seal, and lead to a fragmented trade with multiple classifications of electricians; and,
  • That ASTTBC is not a training organization and that the scope of the ASTTBC Act has no provision for training programs.

9. What does BCSA think about these concerns?

While BCSA acknowledges all of these concerns, our role is to address issues that relate to safety. Those concerns that have identified direct impacts on safety have been addressed as follows:

   a)    BCSA believes that ASTTBC’s ongoing efforts to develop and refine their training program will address those concerns that are related to electrical safety for industry and the public. The Safety Standards Act authorizes the Provincial Safety Manager to:
  • recognize training programs for the purpose of issuing a licence, certificate, permit, or other permission under the Act; and,
  • issue Certificates of Qualifications to perform regulated work.
BCSA will not delegate the authority to issue certificates to ASTTBC. Any certificates issued by ASTTBC will signify completion of the training program and will not be deemed by BCSA to be Certificates of Qualifications to perform regulated work under the Safety Standards Act. While the process for issuing permissions under this program is still under consideration, if the program does receive final recognition, permission to perform electrical work within these limited scopes will be issued by BCSA.
 
  b)   The National Occupational Classification (NOC), published by Human Resources and Skills Development Canada, is the nationally-accepted reference on occupations in Canada. The NOC is a standard that classifies and describes occupations in the Canadian economy, and classifies Red Seal electricians, and technologists and technicians within the same groupings for skill type (skill type 7) and skill level (group B). Semi-skilled workers are generally classified under skill level groups C and D. For more information on the NOC and occupational skill levels, please see the HRSDC website at: http://www5.hrsdc.gc.ca/NOC/English/NOC/2011/Welcome.aspx

ASTTBC technologists and technicians in electrical, electronics and biomedical engineering have a minimum of two years post-secondary technical education and over 4,000 hours work experience in the electrical and electronics field. ASTTBC’s earlier proposal added 480 hours of formal education and on-the-job training and experience. ASTTBC has increased this to a minimum 1,500 hours of on-the-job training and experience. Technologists and technicians will also be required, as part of the new certification program for electrical work, to demonstrate competency.

The Provincial Safety Manager has made clear that ASTTBC members completing ASTTBC’s training program – if approved – will have to apply for and obtain permission from BCSA before they will be permitted to perform regulated work. BCSA will recognize proof of completing a training program to qualify for permission; BCSA will set the terms and conditions on the work that may be performed.

Restrictions will include:

  • For Class EL1 workers, performance of electrical work is limited to equipment that is rated not greater than 250 VAC, 200 A, 3 PH, or 300 VDC, 4500 W.
  • For Class EL2 workers, performance of electrical work is limited to equipment that is rated not greater than 250 VAC, 30 A, 3 PH, or 150 VDC, 2500 W.
  • Electrical work must be supervised by a Field Safety Representative, and only performed under a valid permit;
  • Work may only be performed within the scope of the technologist’s or technician’s certificate or diploma, and in accordance with the level and scope of training completed under the ASTTBC training program;
  • Electrical work on structural wiring systems may only be testing;
  • Electrical work involving commissioning, testing, calibrating, maintaining, troubleshooting, repairing, inspecting, diagnostic evaluation, retrofitting of equipment that is not associated with, or a component of, a structural wiring system is permitted;
  • Work on energized equipment is prohibited unless the only work being done is testing;
  • Installation, removal, replacement, or alteration of electrical equipment or systems is not permitted within the scope of either Class, except as may be necessary for replacement or interconnection of equipment components; and
  • Class EL1 & EL2 permission holders must:
    • maintain records of all electrical work performed under this credential. These records must include permit numbers, under which the work was authorized, and records must be produced upon request by a safety officer, local safety manager, or provincial safety manager;
    • immediately notify the permit holder and Field Safety Representative, upon being given direction to perform electrical work that is not within the scope of their permission;
    • immediately notify the Field Safety Representative about incidents involving electrical equipment or work;
    • maintain their ASTTBC training credential, and maintain current knowledge of the Safety Standards Act, regulations, and other relevant documents, and
    • immediately surrender their credential, upon request by the provincial safety manager.
As is the case for any work performed under a permit, all work must be supervised and monitored for compliance by a Field Safety Representative. Permit holders are responsible for ensuring that workers are competent, properly trained, and suitably qualified to perform tasks involving electrical work – regardless of credentials held by workers; the permit holder must also ensure that a Field Safety Representative (FSR) supervises and confirms compliance of all work performed under a permit. (Note: Responsibilities of an FSR do not require that work be directly supervised on-site; however, the FSR must be capable of providing guidance, and determining that all work performed under a permit is being conducted in a safe and compliant manner.)
 
  c) Providing technicians and technologists with additional training in electrical work will enhance their ability to perform the work they normally do, properly and safely. BCSA believes that safety – of the public and of fellow workers – will actually be enhanced because:
  • it will build upon existing skills, training, and knowledge about electrical work and safety by offering additional training and practical experience;
  • it will apply to a limited scope of work that is part of the current job duties for technicians and technologists and will not allow them to perform the general duties of a qualified electrical worker; and,
  • the scope of work under this program will be performed under permits, where it will be supervised by a Field Safety Representative.
  d) Skills training and qualifications for tradespersons are administered by the ITA as the governing body for trades training and trades qualifications in BC. Individuals who wish to become Red Seal electricians must complete nationally recognized benchmarks for skills and training. Skills training and qualifications for technologists and technicians are provided through a variety of accredited institutions and through on-the-job experience. Individuals who wish to become ASTTBC-registered technologists and technicians must meet nationally recognized benchmarks within their specialized disciplines. The proposed ASTTBC training program does not affect the quality of training for Red Seal electricians; it adds to the existing training for technologists and technicians and enhances their ability to perform their normal job duties.
 
  e) BCSA’s main focus is to work with industry stakeholders to find ways of enhancing safety. In terms of potential impacts on the national Red Seal certification standard, this training will enhance the ability for technicians and technologists to perform their current job duties more safely, and will not expand those job duties beyond their current roles. BCSA does not believe that this program will impact the current training model for, or work performed by, Red Seal electricians. Technicians and technologists will not become qualified to do the work of a qualified electrical worker; they will still need certification as electricians if they want to perform the more general duties of a qualified electrical worker.
 
  f) Section 15 (k) of the Safety Standards Act authorizes a Provincial Safety Manager to recognize training programs for the purpose of issuing a licence, certificate, permit or other permission under the Act, but does not require that an applicant must be a training provider. BCSA policy on recognition for training programs requires that applicants must demonstrate the capacity to administer a training program and monitor performance on an ongoing basis. As is the case for many training programs, training may be provided through a variety of formal and informal learning activities, and by a variety of individuals or institutions. Organizations who are able to demonstrate that they are capable of administering a training program that promotes or enhances safety of electrical work are entitled to apply for recognition of their training program.

10. Will this program undermine the safety of workers, working families, businesses, and the public?

No. BCSA’s primary concern is safety. ASTTBC’s training program enhances safety by providing additional training that promotes safe work and safe work practices for technologists and technicians who have already completed a minimum of two years post-secondary technical education, and over 4,000 hours work experience in the electrical and electronics fields. In addition, ASTTBC’s program will require these individuals to maintain and upgrade their training regularly in order to ensure continued development and enhancement of safe work and safe work practices. BCSA and ASTTBC feel that this training program meets industry standards for the limited scopes of work being proposed. However, any industry stakeholders who are concerned about safety of electrical workers, industry, or the public, and feel that this program will not adequately train technologists and technicians to perform the limited scopes of electrical work, are encouraged to contact ASTTBC to assist them in identifying any potential training gaps and ensure that the training addresses their concerns.

11. Who will be providing the training?

Training under the ASTTBC program will be provided through a combination of in-classroom training, and on-the-job training by qualified individuals. Eligible technologists and technicians will be required to maintain a training log that records their training activities and identifies training providers. Training may be self-directed, or managed and directed through their employers or other potential training providers.

12. How does ASTTBC propose to ensure that technologists and technicians have completed the training and that they will be competent to perform electrical work safely?

ASTTBC is creating an Electrical Work Practitioner Certification Board (EWPCB) for the purpose of examining and approving applicants. The EWPCB will consist of a Chairperson, Vice-Chairperson and a minimum of three ASTTBC members from the disciplines affected by the EWP program. ASTTBC is also seeking to include one electrical industry representative as a member of the EWPCB.

EWPCB members will review each application, and assess and examine applicants under a rigorous process to ensure that applicants have achieved an appropriate level of training and experience that meets the highest level of industry standards for safely conducting electrical work within the limited scopes of the ASTTBC training program. The EWPCB may also require further examination or training before granting certification for completion of the training program.

13. What about those who say that the program is a threat to public health and safety because only electricians should perform all electrical maintenance and installation work?

Electricians are certainly well trained and most often associated with electrical work. However, in today’s economy and job market, there are a large number of other existing Red Seal and other occupations that include electrical work as part of their normal job duties. For example, gasfitters, power engineers, and homeowners are recognized as being allowed to perform limited scopes of electrical work. Building maintenance workers, appliance repair persons, and refrigeration mechanics are other examples of individuals who normally perform electrical work as part of their occupation. Technologists and technicians are included among those whose occupational duties require them to perform some electrical work. BCSA believes that removing the ability for these workers to perform electrical work will have a negative impact on the ability of businesses and industry to safely maintain electrical equipment. Training that promotes safe work, and safe work practices, enhances safety.

14. Has BCSA met with and/or communicated this information to the groups that are concerned?

BCSA has consulted extensively with industry stakeholders on this issue through the Electrical Technology Advisory Committee (ETAC), which has representation from a broad range of industry stakeholders. A number of meetings were held in which various stakeholders, including the ECA, IBEW, and EAC participated. In addition, BCSA has had frequent contact on this issue with ECA, EIA, IBEW, and EAC. More recently, a Working Group has been formed through ETAC to look into the broader topic on recognition of training programs, and provide feedback on changes or improvements for recognizing training programs.

15. What has been the response of these groups?

ETAC has provided much feedback regarding their concerns about this program. Their concerns have been passed on as feedback to ASTTBC for consideration as they continue to develop, refine, and clarify their program. In more recent feedback, ETAC members stated that they disagreed with BCSA allowing ASTTBC to issue certificates of qualification. Concerns were also expressed by a few representatives from local government regulators who administer their own electrical safety program. These regulators were concerned about challenges in their ability to monitor regulatory compliance, without BCSA-issued credentials. BCSA shares this concern and has confirmed to ASTTBC that BCSA remains responsible for evaluating the qualifications of all applicants to perform regulated work.

ETAC members proposed the formation of a Working Group to explore potential improvements on BCSA policies and procedures for evaluating applications for recognition of training programs. While it was proposed that representation on the Working Group would come from local government regulators, electrical contractors, labour, and electrical apprenticeship instructors, representatives from labour and the electrical apprenticeship instructors have so far declined participation.

16. What does BCSA think about claims by people in favour of the proposed program that those who are against the program are claiming it is about safety (i.e. “wrapping themselves in the safety blanket”), but it is actually about protecting themselves from competition?

As an independent, self-funded organization mandated to oversee the safe installation and operation of technical systems and equipment, BCSA’s first priority is always to promote and enhance the safety of technical systems in BC. We have heard comments from both sides regarding the potential impact on market share for various industry sectors; however, these comments do not demonstrate an impact on safety and therefore BCSA is not able to consider these aspects under its statutory duty.

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III. BCSA Approval

17. Has BCSA approved this new program?

ASTTBC’s application for their proposed training program was conditionally approved in 2011, allowing ASTTBC to proceed with development of their program. On September 18, 2013, ASTTBC’s Electrical Work Certification Board accepted the proposed training program and submitted it to the ASTTBC Council (governing board) for consideration at the September 26, 2013 meeting. ASTTBC plans to make its final submission for recognition to BCSA following ASTTBC Council approval and, with BCSA final approval, will implement in October 2013. The final submission from ASTTBC will need to meet conditions imposed by the Provincial Safety Manager. Final recognition of the program will only be granted once all of the conditions have been met.

18. Why did BCSA grant “conditional” approval?

The ASTTBC application proposed the development of a training program and provided an outline and objectives. It also provided evidence that ASTTBC had the capacity to administer the program and monitor performance on an on-going basis. In approving their proposal and providing conditional approval, the Provincial Safety Manager at BCSA agreed that the program objectives would promote workers having sufficient skills to safely complete electrical work and the program would enhance public safety. The conditional approval acknowledges BCSA’s commitment to enhancing safety and provided assurance to ASTTBC, allowing them to commit resources for development of their program.

19. Who is this “Provincial Safety Manager”? I thought BCSA was responsible?

Employed by BCSA, the Provincial Safety Manager is a person who has been delegated the authority to make statutory decisions under the Safety Standards Act.

20. But can BCSA approve certification programs run by someone other than BCSA?

No. BCSA does not approve certification programs. Under Section 15 (k) of the Safety Standards Act the Provincial Safety Manager may recognize training programs, and may evaluate the qualifications of individuals under Section 15 (l).

21. Does that mean BCSA is giving ASTTBC the ability to authorize individuals to perform work that it regulates on the Safety Standards Act?

No. The Provincial Safety Manager has the ability to recognize training programs and allow individuals who complete a training program to perform electrical work. This ability is not included as one of the powers that may be delegated under Section 15 of the Safety Standards Act.

22. Then what exactly is BCSA approving or authorizing for ASTTBC?

ASTTBC has been working on development of a training program. Upon receiving the final submission from ASTTBC, the Provincial Safety Manager will decide whether the program has satisfied the conditions imposed by the 2011 approval. Once all of the conditions have been satisfied, the Provincial Safety Manager will issue formal recognition of the training program. Individuals who are able to demonstrate that they have completed the training program will become eligible to apply for a permission to perform electrical work within a limited scope. Qualifications for individuals who apply for permission will be assessed before a credential is granted.

23. Has BCSA/the Provincial Safety Manager done this before and, if so, when/where?

Recognition of individuals with training for limited scopes of electrical work was first done under the Provincial Government’s Electrical Safety Branch. These individuals have been granted certifications in restricted classes for Field Safety Representatives. BCSA assumed this role in 2004 and has continued to grant certifications for restricted class Field Safety Representatives. Only one other training program has been recognized under the Electrical Program, but recognition of training and granting of qualifications or permissions has also occurred in the gas, boiler, and elevating devices technologies.

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IV. Application Status

24. It has been over two years since BCSA granted conditional approval for this program. Has BCSA subsequently granted formal approval to the training program?

No, it has not. ASTTBC has announced its intention to implement their training program this fall. However, individuals who complete the training program will not be recognized until the Provincial Safety Manager is convinced that the ASTTBC training program has satisfied all conditions.

25. Has BCSA made suggestions to ASTTBC in terms of how to address these conditions?

Yes, in June 2013, BCSA provided the following suggestions to ASTTBC:

  • Scope of training/work – the scope of training will need to be clearly defined and accurately describe the limitations of work that may be subsequently performed;
  • Description of training and work experience – the description of training and work experience, including hours of practical training and experience under this program, will need to be determined; a plan for the delivery of this training will need to detail how the training will be provided;
  • “Challenge” procedures – the proposed training program will need to acknowledge that BCSA will remain responsible for evaluating the qualifications of all applicants to perform regulated work; and,
  • Program implementation and issuance of final recognition documentation – given its legal responsibilities under the Safety Standards Act, BCSA will have to issue its own certificate to those who complete the ASTTBC training program; this will need to be recognized as part of the program materials.

26. What are the next steps in the approval process?

ASTTBC is continuing to work towards achieving its goals and is attempting to address these issues in order to meet its planned implementation date. BCSA’s expectation is that ASTTBC’s amended training program application will address these conditions. The Provincial Safety Manager will review the amended application and make the decision on whether to fully approve the training program.

27. What happens if BCSA approves ASTTBC’s training program?

Once BCSA has granted final recognition of the training program, individuals who have successfully completed the training will be eligible to apply for permission under the Safety Standards Act. Those who receive permission will be authorized to perform tasks that involve electrical work in accordance with Electrical Safety Regulation, Section 4(1)(b), and the terms and conditions for the credential.

The ASTTBC training program will undergo regular review to promote continuous improvement and development of the training program and affected ASTTBC members. Members who are recognized under this program will be required to demonstrate continued upgrading and development in order to maintain their ASTTBC training credential. Individuals who are unable to demonstrate that they have maintained their ASTTBC training credential will have their permission suspended or revoked at the discretion of BCSA.

28. What if ASTTBC does not meet all of the conditions imposed by the Provincial Safety Manager? What will BCSA do then?

ASTTBC is entitled to implement its training program at its own discretion. However, workers who complete the training will not be authorized to perform electrical work unless they have made a successful application to BCSA for permission to perform electrical work within the limited scope of their training. The training program will not be approved until and unless ASTTBC satisfies all of the conditions imposed by the Provincial Safety Manager.

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