List members: Please see the link below which states that the Ontario Regulation 438/07 has been postponed - referencing "concerns raised by manufacturers."
http://www.esasafe.com/product_safety/index.php Is the only method to express concerns e-mail or is there an official forum or committee or government organization (CSA??) that is openly discussing the revisions? Curtis Bender | curtis.ben...@tennantco.com ________________________________________________________________________ _ Opinions expressed here are my own and do not reflect those of my emplyeer From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Doug Nix Sent: Friday, May 15, 2009 8:53 AM To: emc-p...@ieee.org Cc: Jim Eichner; Brian O'Connell; mina.you...@electricalsafety.on.ca; norm.bre...@electricalsafety.on.ca Subject: Re: Ontario Regulation 438/07 (again) All, Here are a few answers to your questions: 1) To my knowledge, there is no 'structural' legislation document that explains where each clause/subsection/sectionsubtends another. I can tell you the way it works here in any case. Legal responsibilities in Canada are split up between the Federal Government and the Provincial and Territorial Governments. The Feds look after the military and National Defence, external affairs, Aboriginal affairs, and activities that cross Provincial and Territorial boundaries. In practice for us, this means that they look after radio spectrum management, radiation emitting devices (both ionizing and non-ionizing), and transportation. The Provinces and Territories look after anything that goes on inside their boundaries, and that includes distribution and use of electrical energy. The ACT (in this case the Ontario Electricity Act) is the 'mother' document. Regulations are made under the Act based on the clause in the Act that says that the Minister may make such regulations as necessary. The Regulation gives the detailed means for the Ministry and it's agencies, in this case ESA, to enforce the Act. The Agencies are given the authority to do this in any way that they decide is acceptable, within the scope of existing law in the Province. In this case, it is the Ministry of Small Business and Consumer Services that is in charge of the electrical system. 2) I think that the assumption made by ESA is that the Manufacturer will always have their name on the product, which is obviously incorrect, since many manufacturers brand-label products for others. In my opinion, it is the name on the nameplate that should be registered, however, since I don't work for ESA and can't speak for them, I would suggest you contact either of these two gentlemen directly: Mr. Mina Yousef P.Eng. Product safety Engineer Electrical Safety Authority 155A Matheson Blvd E., Suite 202, Mississauga, ON Canada, L4Z 1X8 (905) 712-5678 mina.you...@electricalsafety.on.ca OR Mr. Normand Breton P.Eng. General Manager, Operations (905) 712-7813 norm.bre...@electricalsafety.on.ca -- Doug Nix, A.Sc.T. IEEE PSES Toronto Section, Ontario, Canada d...@ieee.org mobile (519) 729-5704 fax (519) 653-1318 Find me LinkedIn at http://www.linkedin.com/in/dougnix On 15-May-09, at 1:48 AM, Jim Eichner wrote: > My understanding is that "manufacturer" is defined as the company in > whose name the product safety certification is registered. > > Jim Eichner, P.Eng. > Compliance Engineering Manager > Xantrex Technology Inc. > e-mail: jim.eich...@xantrex.com > web: www.xantrex.com > > Confidentiality Notice: This email message, including any attachments, > is for the sole use of the intended recipient(s) and may contain > confidential and privileged information. Any unauthorized review, use, > disclosure or distribution is prohibited. If you are not the intended > recipient, please contact the sender by reply e-mail and destroy all > copies of the original message. > > > -----Original Message----- > From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian > O'Connell > Sent: Thursday, May 14, 2009 4:18 PM > To: emc-p...@ieee.org > Subject: Ontario Regulation 438/07 (again) > > Good People, > > The text of the regulation does not specify if the manufacturer must > register, or if the company that is on the safety label and name plate > must register. > > The 'FAQ' published by the ESA states that only the manufacturer can > register - but if the mfr's name is not on the name-plate, there is no > basis for tracibility by the local government - which fails to comply > with the code. > > Also, where is the hierarchical structure statute text defined for > Canadian law ? It is not clear where each clause/subsection/section > subtends another. > > I have sent two emails to the ESA requesting clarification; none were > answered (probably their site problems - at least one seems to have > bounced). > > Thanks much, > Brian > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. To post a message to the list, send your > e-mail to <emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to > that > URL. > > Website: http://www.ieee-pses.org/ > Instructions: http://listserv.ieee.org/request/user-guide.html > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <emcp...@socal.rr.com> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher: <j.bac...@ieee.org> > David Heald: <dhe...@gmail.com> > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society emc- > pstc discussion list. To post a message to the list, send your e- > mail to <emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to > that URL. > > Website: http://www.ieee-pses.org/ > Instructions: http://listserv.ieee.org/request/user-guide.html > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <emcp...@socal.rr.com> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher: <j.bac...@ieee.org> > David Heald: <dhe...@gmail.com> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@socal.rr.com> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@socal.rr.com> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
