Loss of CSA certification causes headaches for grain dryer users

Saturday, November 3, 2012

With the Canadian Standards Association's decision to stop certifying grain dryers, farmers are facing the possibility of a more costly and complicated process to get new or replacement equipment into service

by SUSAN MANN

CSA. For years the presence of those three letters, an acronym for the Canadian Standards Association, stamped on grain dryers has meant that installation of the equipment is straightforward. The dryer is bought, installed, hooked up to gas or propane and test-fired by a certified installer.

But, next year, those letters are slated to vanish from grain dryers. When this happens, some industry representatives predict farmers will have to spend hundreds of dollars more on dryer installation – provided they can still buy a dryer – and wrestle with paperwork to meet provincial regulations.

The situation erupted a year ago when the CSA announced it would no longer certify gas or oil-fired crop dryers as of April 1. Earlier this year, it extended the deadline to Jan. 1, 2013, to give clients more time to prepare.

Anthony Toderian, spokesman for CSA Group, the Association's parent organization, says by email that increasingly stringent accreditation requirements placed on certification bodies are the reason behind the decision to withdraw certification. These requirements make it impossible to evaluate these products outside a laboratory environment. Yet, he writes, "due to their large size and unique nature, these products are typically assembled on-site and have been historically tested and certified at the final installation."

The loss of CSA certification means farmers and grain elevators buying, upgrading or replacing grain dryers must get their equipment certified by the Technical Standards and Safety Authority (TSSA), the provincial regulatory authority. (Ontario fuel regulations stipulate suppliers of propane or natural gas can't supply fuel to a crop dryer or burner that hasn't obtained either a CSA or TSSA certificate.) No other agency has gained accreditation by the Standards Council of Canada to certify such equipment, says Wilson Lee, a spokesperson for the authority. "In the absence of a standard that we would accept, we would then require a field approval," he explains.

TSSA certification involves two steps: an engineering design review of equipment and subsequently a field approval. It will be required for the installation of new equipment or existing equipment that is moved. The process takes about one month and service fees are $150 per hour. "We also offer a rush service which takes about a week and the costs are generally double," says Lee. Total cost varies depending on equipment, but a rough estimate, including the application fee, would be $1,000, he says.

Anything "that is on a farm and working right now won't need recertification," says Bryan Leblanc, communications director for provincial Consumer Services Minister Margarett Best. Nor has the province brought in new regulations or changed any regulations, he adds.

Mark Brock, Grain Farmers of Ontario (GFO) director for Perth County (District 9), says the withdrawal of CSA certification will be particularly hard for farmers who use portable dryers, because every time it's moved "you have to have it re-inspected."  Farmers who use a burner-fan combination on an in-bin system to dry crops and the burner fails, will have to go through the whole inspection process when installing a new burner.

Beverly Leavitt, president of the Canada East Equipment Dealers' Association, which represents equipment dealers in Ontario and the Maritimes, says federal regulations don't permit retailers to sell or service grain dryers lacking standards certification or "some kind of accreditation approval for the safety of equipment." Anything that was CSA certified prior to Jan. 1 2013 can still be sold; it's equipment arriving after that date and lacking the stamp that will be affected.

Farmers can still buy equipment that's not CSA certified, she adds. But the industry is concerned that the certification withdrawal will "create a black market business, which also creates a health and safety issue." Field inspections by TSSA address some of the problem, but "that doesn't resolve the entire situation for us."

Industry organizations in the United States and Canada are working to get new protocols written so the CSA can continue certifying grain dryers, says Brock. His organization is among 21 interested parties and the $50,000 cost of the new document would be split among them. Having new protocols would enable the grain dryers to get the CSA stamp at the factory again after Jan. 1, 2013 and then farmers wouldn't need TSSA certification, he says.

The fuels section of CSA Group, based in Cleveland, Ohio, would be writing the new protocols. Toderian says preliminary discussions with stakeholders have focused on "a standard that would limit the scope to smaller factory-built products rather than the very large field-erected products."

Writing a new standard takes time and CSA Group can't confirm a new standard will be developed or one will be completed by Jan. 1, 2013, he says.

Leavitt is also skeptical that the CSA would deliver the standards in time. She says of the 21 interested parties, "about half" are members of Canada East and the cost of the standards is "very expensive."

"We're looking at other options," she says. One of those is the possibility of creating a national standard by adapting an existing standard developed by the American Society of Agricultural and Biological Engineers that is used in the United States. "It doesn't exactly align with Canadian needs, but it can be rewritten. And if we could implement that, we would have a national standard. But we have to get permission from the SCC (Standards Council of Canada) in order to do that."

Dave Buttenham, executive director of the Ontario Agri Business Association, says it's premature for them to make comments until they find out exactly what the loss of CSA certification of grain dryers is going to mean. The association, which represents the province's country grain elevators, feed manufacturers and crop input suppliers, along with businesses that provide products and services to them, is in the process of working out options with GFO.

Buttenham says there are about 280 commercial grain dealers in Ontario so "there's probably pretty close to 280 commercial grain dryers." That number doesn't include the ones that farmers have themselves.

Dan Bjerre, whose Kitchener company, Danco Electric Inc., services grain dryers, says TSSA certification is already needed on the installation or conversion of used equipment. In those cases, it can be a tough process because of the detective work involved in tracking down the information needed for the engineering design review.

He's also heard people express concern about the possibility of TSSA inspectors making arbitrary decisions during field inspections.

But that's going to be difficult for inspectors to do, he argues, noting that TSSA requires drawings to be approved ahead of the field inspection. Moreover, the process could be easily streamlined if equipment manufacturers work with TSSA and share their equipment plan drawings. "So this means that when the TSSA inspector comes out, you hand him the drawings, he inspects the machine, looks and make sure it matches the stamped drawing and you should be good to go," he says.

It's unlikely equipment that previously obtained CSA approval would require changes, he adds. "I think that for most people, if they did the paperwork correctly with TSSA and worked with them, it wouldn't be such a big deal," he says. "I don't think that the expense is going to be as horrendous as people think." BF

With files from Mary Baxter