Happy New Year Oil and Gas Companies in Alberta! When the clock struck midnight and 2017 was thrust upon us…after all the premature celebration out East…those of you with gas fired equipment may have missed a subtle reminder hidden in all those fireworks. And admittedly, it was easy to miss, given all the attention generated by the Alberta Carbon Tax, a certain election result down south, and of course the persistence of low oil.
Nevertheless, the Alberta Government’s direction and insistence, under Alberta Municipal Affairs, to bring all gas fired equipment to compliance remains. As a reminder, the Alberta Safety Codes Act – Gas Code Regulation Section 3 mandates that all gas fired equipment shall be tested and certified by a certification body or inspected and accepted by a certification body or an inspection body. Of course equipment of this size and scale (line heaters, treaters, heated tanks, etc.) can be a little difficult to squeeze into a lab for testing and so the latter option for field inspection in accordance with the mechanism that is CSA B149.3 has become a familiar process throughout industry.
Though January 1, 2015 was the initial deadline imposed to have all appliances and equipment certified or approved, in recognition of the large inventory of such equipment held by many companies, the Legacy Equipment Management System (LEMS) was announced in October of 2014. Most importantly, the program provided means for an extension until January 1, 2020 to bring all equipment to compliance.
Since that time period, as the Oil and Gas industry has been taking punches with the latest collapse in commodity prices, the LEMS program has been just one of several pressurized realities facing companies. One report indicates the total number of companies submitting via LEMS to be just 100 and accounting for less than 50% of the equipment in the field throughout the Province.
Without registration to LEMS, companies are assumed to have completed upgrades and field approvals for all existing equipment by the initial deadline of January 1, 2015. Moreover, any non-registrants with sizable inventory are likely to receive increased attention from the Alberta Municipal Affairs Chief Plumbing & Gas Administrator who is tasked not only with jurisdiction for LEMS but the Gas Code Regulation as well. Clearly for at least 100 registered companies, this was enough of an incentive to register with the program.
Fast forward to January 2017, and while the latest total figure for compliant equipment is as elusive as Moby Dick to anyone outside of Alberta Municipal Affairs, participating companies under LEMS are likely still behind their initial reported targets for completion thanks to the downturn and associated budget reductions. Now, with just three years of the extension remaining, time is inevitably more of a factor.
So, do you have much to do about LEMS? Chances are that you do, even if you are among the 100 companies who are registered; moreover, the requirement for compliance is not disappearing and January 2015 could be a painful memory if you did not register.
If you find yourself in a role of responsibility for your company’s LEMS program, Alberta Municipal Affairs has likely already reminded you of your key reporting responsibilities. This includes demonstrating your compliance progress as well as updating your inventory of non-certified equipment in annual submissions directly to the Chief Plumbing & Gas Administrator. Even changes to equipment status such as decommissioned, turned off, or shut-in are to be reported and may assist you with reducing your completion targets or over inflate your liability if not properly completed.
Seem overwhelming? Don’t lose hope, keep reading. The reality is that you still can make progress even in a downturn. After all, the way to eat a whale is one bite at a time.
Our experience at Profire, combustion specialists and manufacturers of Burner Management Systems and controls including the PF2100, suggests that some equipment is just steps away from full compliance. We continue to assist many companies with compliance including site evaluations of equipment; providing advisory reports and recommendations; supplying complete valve train components, burners, and of course controls; and coordinating field approvals with accredited inspection bodies.
We’re willing and capable to assist your organization in making 2017 a year of progress and compliance. Contact us today and ask us for further information on any of our available products and solutions or inquire further about your B149.3 compliance requirements.
 Alberta Municipal Affairs, Gas Safety Information Bulletin, G-02-14
Allan Reay is the Regional Sales Manager at Profire Energy Inc.