A VALUE PROPOSITION FROM THE CANADIAN INSTITUTE OF PLUMBING

A VALUE PROPOSITION FROM

THE CANADIAN INSTITUTE OF PLUMBING & HEATING

TO FACILITATE THE HARMONIZATION OF MARKET ENTRY REQUIRED STANDARDS AND CERTIFICATION SCHEMES

COVERING SELECTED PLUMBING & HVACR PRODUCTS

E c o n o m i c I m p a c t A s s e s s m e n t

Submitted to: John Walter, Chief Executive Officer

Standards Council of Canada 270 Albert Street, Suite 200, Ottawa, ON, K1P 6N7

Prepared by:

Kevin Wong & Ken Tomihiro Canadian Institute of Plumbing & Heating 330‐295 The West Mall Toronto, ONM9C 4Z4 416‐695‐0447 [email protected] & [email protected]

Submission Date: August 20, 2012

CIPH proposal to the US/Canada Regulatory Cooperation Council inside cover

Introduction to the Submitter: Canadian Institute of Plumbing & Heating The Canadian Institute of Plumbing & Heating (CIPH) welcomes this opportunity to submit our thoughts on the potential economic impact of greater regulatory cooperation between Canada and the United States of America. The Institute believes that a greater degree of harmonization of product standards would improve cross border trade while allowing all Canadians to continue to enjoy the same high standards of product quality, health and safety that are now in place.

Please consider these comments for Phase II of the Regulatory Cooperation Councils program as a major component for improvement to the infrastructure development/constructed environment under the general heading of Industrial and Commercial equipment for: Waterworks, Pipes, Valves, Fittings, Plumbing, Hydronic Heating, and HVACR.

Canadian Institute of Plumbing & Heating The Canadian Institute of Plumbing & Heating is a not‐for‐profit trade association. Founded in 1933, the Institute is a vibrant organization committed to providing members with the tools for success in today’s competitive environment. More than 260 companies are members of this influential Canadian industry association. They are the manufacturers, wholesaler distributors, master distributors, manufacturers' agents and allied companies who manufacture and distribute plumbing, hydronic heating, industrial, waterworks and other mechanical products. CIPH wholesalers operate more than 700 warehouses and showrooms across Canada. Total member industry specific sales to the trades exceed $6.1 billion annually.

CIPH proposal to the US/Canada Regulatory Cooperation Council page i

i. Executive Summary ‐ Bi‐National Regulatory Cooperation (RCC) and Streamlined Standards System Proposal

Canada and the United States of America each have well‐developed, independent regulatory regimes and agencies for technical standards development, product certification, and codes implementation & enforcement. While the respective regulatory systems are very similar, unnecessary duplicative actions such as duplicative testing impact on consumers, businesses and our economies with higher costs and less‐efficient supply chains. This proposition submitted by the Canadian Institute of Plumbing & Heating outlines some of the implications of unnecessary certifications and possible gains in productivity and prosperity the plumbing and heating industry could achieve through greater regulatory cooperation. The scope of the plumbing and heating sector covers components of the built environment that provide Canadians with products that ensure the safety of their water systems and the comfort of their indoor air environment. The estimated value for 2011 of the industry in the Canadian residential sector is approximately $24 Billion while estimates in the USA were $67 Billion for a total of over $90 Billion in economic activity for the sector. Bi‐lateral trade exceeds $17 Billion with more than 70% of the goods sold in Canada being produced in the USA. These figures are indicative of the continued strength of the Canadian housing market and the low number of housing starts in the USA in 2011. The total cost of product testing and certification compliance for the North American plumbing and heating industry is between $3.2 and $4.5 Billion per year. It is estimated that only about 10% of referenced standards are currently bi‐laterally harmonized which results in many instances of duplicate testing and certification to meet the different federal and provincial standards that govern many of these products. The additional cost to Canadian consumers attributed to duplicate certification and testing is between $120 to $150 Million per year. CIPH supports the efforts of the Regulatory Cooperation Council and through this report provides a qualitative assessment of the potential cost savings, productivity gains, speed to market benefits and implications of the establishment of a joint Canada‐US standards secretariat that may be able to facilitate the true harmonization of standards, testing and certification requirements through the creation of North American consensus standards.

CIPH proposal to the US/Canada Regulatory Cooperation Council page ii

Table of Contents

Introduction to the Submitter: ................................................................................................................................... i

Canadian Institute of Plumbing & Heating ................................................................................................................. i

i. Executive Summary ‐ Bi‐National Regulatory Cooperation (RCC) and Streamlined Standards System

Proposal .............................................................................................................................................................. i

Table of Contents....................................................................................................................................................... ii

1. VALUE PROPOSITION FROM THE CANADIAN INSTITUTE OF PLUMBING & HEATING AND ELECTRO‐

FEDERATION CANADA SUPPORTING THE ESTABLISHMENT OF A JOINT CANADA‐US STANDARDS

SECRETARIAT TO FACILITATE THE HARMONIZATION OF STANDARDS AND CERTIFICATION

REQUIREMENTS FOR SELECTED ELECTRICAL/ELECTRONIC AND PLUMBING/HEATING PRODUCTS ................. 1

2. Description of the sector: scope, International Classification for Standards (ICS) families, examples

of products, employment (direct, indirect), examples of key players active in the sector in Canada

(design, manufacturing, assembly, sale, wholesale, retail installation and maintenance) Description

of the sector....................................................................................................................................................... 1

3. Approximate value of trade between Canada–US of products covered in the sector, trends in terms

of value, volume. If products are manufactured outside of Canada‐US, but destined for the

Canada‐US market, recent trade numbers and trends ..................................................................................... 2

4. Approximate proportion of products in the sector that can be sold in the Canadian‐US market by

using one set of standards, testing and certification (same or harmonized standards) versus

proportion of products that require distinct Canadian and US standards and certification. This will

help understand whether duplicative standards are systemic throughout the sector or isolated to

specific categories of products; ......................................................................................................................... 3

5. Provide an example of a product that is subject to different Canada/US standards ........................................ 4

a. Determine and list the number of different standards and certification marks that are applicable to

the product in Canada and the US..................................................................................................................... 4

b. Describe the standards and certification activities which are required at each step in the value

added chain and explain how the duplicative requirements are handled........................................................ 4

c. Estimate the current costs of testing and certification requirements to the current different

standards and identify the additional costs associated with the duplicative requirements ............................ 5

d. Provide information on how often is the product tested. Estimating for the period of time between

testing/certification the quantity of the product produced.............................................................................. 5

e. Organizations providing the relevant certification services for each certification............................................ 6

f. Who is paying for the additional cost of testing and certification?................................................................... 6

g. Which regulatory authorizations are required for each of the current standards for the product? ................ 6

CIPH proposal to the US/Canada Regulatory Cooperation Council page iii

h. Barriers to removing the different standards/ duplicative testing/ certification of the product and

allow for effective harmonization ..................................................................................................................... 7

i. Are there existing mechanisms in place to remove the duplicative standards / testing / certification

requirements? ................................................................................................................................................... 8

j. Estimating the approximate savings of eliminating duplicative standards, testing, and certification

requirements per unit of the product ............................................................................................................... 8

6. If a joint secretariat for standards harmonization was to be created to establish a process for

determining whether the Canadian‐US standards applying to existing products were equivalent,

who would support this initiative? Who may have reservations abou this? .................................................... 8

7. Would Canadian and USA SDO/TO/CO be in favour, neutral or opposed to your proposal? Would

Canadian‐US certification bodies be in favor, neutral or opposed?.................................................................. 9

8. What are the risks in determining whether Canadian and US standards applying to the same

product are equivalent? What would be the resources required on the part of industry in order to

identify existing standards that are equivalent? ............................................................................................. 10

9. How should provinces/municipalities be engaged in order to secure support for this initiative? ................. 11

10. What types of new products currently under development would likely get strong industry support

in Canada for the development of harmonized standards between Canada and the US before the

product is commercialized?............................................................................................................................. 11

11. What types of existing products subject to two distinct standards / testing / certification

requirements would likely get strong industry support in Canada to eliminate duplicative

requirements and generate cost savings?....................................................................................................... 12

List of Annexes

Annex 1 ‐ CIPH Member Companies

Annex 2 ‐ General Outline of the Certification Process

Annex 3 ‐ Manufacturer Certification Costs for 2011 & 2012 (estimated)

Annex 4 ‐ National Plumbing Code Adoption for Canada

Annex 5 ‐ ANSI/NSF 61 Adoption within the Canadian Standards for Material Safety

Annex 6 ‐ AHRI Table (CIPH Appended for Plumbing Products)

Annex 7 ‐ PTPACC Letter on Fragmentation

Annex 8 ‐ Plumbing Manufacturers International Position on Harmonization

CIPH proposal to the US/Canada Regulatory Cooperation Council page 1

1. VALUE PROPOSITION FROM THE CANADIAN INSTITUTE OF PLUMBING & HEATING AND ELECTRO‐FEDERATION CANADA SUPPORTING THE ESTABLISHMENT OF A JOINT CANADA‐US STANDARDS SECRETARIAT TO FACILITATE THE HARMONIZATION OF STANDARDS AND CERTIFICATION REQUIREMENTS COVERING SELECTED ELECTRICAL/ELECTRONIC AND PLUMBING/HEATING PRODUCTS

The objective of the value proposition is to provide a qualitative assessment of the implications and potential benefits of the establishment of a joint Canada‐US standards secretariat to facilitate the harmonization of standards, testing and certification requirements covering selected electrical and plumbing products. The secretariat would work to facilitate the: ‐ Development of harmonized Canada‐US standards for selected new and existing products to avoid

different standards that result in duplicative testing and certification requirements; ‐ Harmonization, maintenance and use of a list of existing standards and bi‐national acceptance of

certification marks that jurisdictions in Canada and the US could use to avoid duplicative certification requirements for selected categories of products.

In order to evaluate the merits of the proposed initiative, the Canadian Regulatory Cooperation Secretariat requested the development of value propositions covering electrical/electronic and plumbing/heating products.

2. Description of the sector: scope, International Classification for Standards (ICS) families, examples of products, employment (direct, indirect), examples of key players active in the sector in Canada (design, manufacturing, assembly, sale, wholesale, retail installation and maintenance) Description of the sector

i. Scope

The scope of the plumbing and heating sector covers the components of the built environment that provides Canadian homes with products and components that ensure their indoor water and air environment safety and comfort. The industry is supported by manufacturers, a wholesale distribution systems and retail channels to the general construction and specialty trades persons responsible for designing, building, installing and maintaining these systems. The municipal and provincial building and plumbing inspectors enforce the Building Code for health, safety and engineering of the built environment. Both the manufacturing and trades are supported by the Building and Plumbing Codes enforced by the various inspection authorities. ii. International Classification for Standards (ICS) families

North American Industry Classification System Families that affect the industry are: 2213 Water, sewage and other systems (Waterworks and Infrastructure) 236 Construction of buildings (The Building Environment) 237 Heavy and civil engineering construction (Waterworks and Infrastructure) 238 Specialty trade contractors (the trades) 326 Plastics and rubber products manufacturing 332 Fabricated metal product manufacturing 4161 Electrical, plumbing, heating and air‐conditioning equipment and supplies merchant wholesalers (wholesale distribution)

iii. Examples of products,

Examples of products in this sector range from the large water supply pipes to the plumbing pipe that is common to almost every home in Canada and the USA. Fixtures and fittings such as toilets, faucets and


sinks are among the products requiring certifications that ensure adequate safety and performance capabilities. Maintaining proper levels of comfort and indoor air quality includes products such as boilers and water heaters that range from single‐room units to high‐rise integrated systems and these products require multiple certifications for safety and energy‐efficiency.

The high safety standards of plumbing and heating systems enjoyed in North America are major contributors to the health and well‐being of the consuming public and this has only been possible through the development, maintenance and enforcement of an established national system of technical standards and objective based plumbing and building codes, & policy/regulation. iv. Employment (direct, indirect)

According to Statistics Canada estimated direct employment in the manufacturing and wholesale portions of these ICS families is 39,000 full‐time jobs. More than a million Canadians are employed in the installation, service and repair industries of the built‐environment sector.1 v. Examples of key players active in the sector in Canada.

Annex 1 lists the CIPH members who manufacture, assemble and distribute plumbing and heating components and systems in Canada. These companies are prime representatives of the sector.

3. Approximate value of trade between Canada–US of products covered in the sector, trends in terms of value, volume. If products are manufactured outside of Canada‐US, but destined for the Canada‐US market, recent trade numbers and trends

The value of economic activity for the plumbing and heating industry in the Canadian residential sector was approximately $24 Billion in 2011, while estimates in the USA were $67 Billion2. Total value of the bi‐lateral trade exceeds $17 Billion with more than 70% of the goods sold in Canada being produced in the USA3. These figures are indicative of the continued strength of the Canadian housing market and the low number of housing starts in the USA in 2011.

There is also an increasing trend of product that does not meet applicable standards entering the North American market. In most cases, these low‐cost products such as fixtures, pipe and tubing are sold at the retail level and in many cases the required standards are cannot being upheld because the AHJ does not have the required authority to remove the product from the shelf.

1 http://www12.statcan.gc.ca/census‐recensement/2006/dp‐pd/tbt/Rp‐eng.cfm?LANG=E&APATH=3&DETAIL=0&DIM=0&FL=A&FREE=0&GC=0&GID=0&GK=0&GRP=1&PID=92102&PRID=0&PTYPE=88971,97154&S=0&SHOWALL=0&SUB=0&Temporal=2006&THEME=74&VID=0&VNAMEE=&VNAMEF= 2 http://www.statcan.gc.ca/tables‐tableaux/sum‐som/l01/cst01/trad35a‐eng.htm

Electrical, plumbing, heating and air‐conditioning equipment and supplies wholesaler‐distributors

$24,082,499,(thousands) 3 Assumption: 70% of the Canadian wholesale market sourcing materials from US Manufacturers.


4. Approximate proportion of products in the sector that can be sold in the Canadian‐US market by using one set of standards, testing and certification (same or harmonized standards) versus proportion of products that require distinct Canadian and US standards and certification. This will help understand whether duplicative standards are systemic throughout the sector or isolated to specific categories of products;

Some plumbing products such as fixtures (toilets) and fittings (faucets) already enjoy the implementation of some harmonized standards where applicable and industry in favour believes that there is no reason for all plumbing products sold across North America to use a single set of certification standards.

It is important to note that many standards referred to by industry as ‘harmonized’ are not formally harmonized as a singular standard, but remain separate standards that the respective SDO’s have agreed to mirror. Changes to one are not automatically adopted by the other and must go through the approved consensus process. This is demonstrated in the case of plumbing fittings where the CSA B125 and the ASME 112 standards are “harmonized”. While the technical standards are harmonized, industry still has to burden the cost of managing the technical aspects of both standards at the standards development stages. There are still divergent approval processes that increase the time and effort to maintain harmony.

Industry also believes that most heating products such as water heaters and boilers could be regulated by a single set of standards. However different national, state and provincial requirements for energy‐efficiency currently have different performance and reporting standards that often require duplicate testing and certifications. This occurs because at the policy formulation stages, different authorities having jurisdiction (AHJs) may consider different data, information or models used to develop policy.

To illustrate the opportunity for true harmonization a quick review of the National Plumbing, Building and Gas Codes illustrates that only a very small percentage of the referenced standards are harmonized. Table 1: Percentage of Harmonized Standards Referenced in Canadian Codes

Total Standards Referenced

Harmonized Standards Referenced

% Harmonized

National Building Code 2010 266 21 9%

National Plumbing Code 2010 101 11 11%

Gas Code (CSA B149‐1S1‐07) 51 9 18%

As more water‐conservation and energy‐efficiency initiatives are introduced by different jurisdictions and government departments, there is a greater likelihood that more divergent standards will be introduced. Immediate efforts toward harmonizing future standards will produce long‐term gains for North‐American industries in the plumbing and heating sector.


5. Provide an example of a product that is subject to different Canada/US standards

The typical domestic hot water heater is a prime example of a product that is subject to different Canada/US standards. There are nearly 1 million water heaters sold for new construction and replacement applications each year in Canada4. Whether powered by electricity, natural gas or oil, testing and certification to different standards is required depending on the jurisdiction in which the product is sold.

a. Determine and list the number of different standards and certification marks that are applicable to the product in Canada and the US

Table 2‐ Harmonized/Non Harmonized elements of a Water Heater

b. Describe the standards and certification activities which are required at each step in the value added chain and explain how the duplicative requirements are handled.

The general certification process is outlined in the chart in Annex 2. A manufacturer typically engineers and prototypes products with conformance to existing standards and codes as part of the development process. Once a final production model has been completed and passed by internal engineering, it will

4 CIPH’s WSS Report 2011.

Water Heaters

U.S. Federal Standards Canadian Federal Standards State/Province Standards

Energy Efficiency issues

Gas/Electric: energy efficiency standards measured in Energy Factor (EF)

Gas: Same Energy Factor standard as U.S. Has proposed to be more stringent than revised EF adopted by DOE in April 2010. Electric: Efficiency standard only measures standby loss

BC: Established separate energy efficiency standards

Standards ??? in the US Three Possible Standards: (only 2 harmonized) ANSI Z21.10.1‐2004/CSA 4.1‐2004 ANSI Z21.10.3‐2004/CSA 4.3‐2004 CSA B140.12‐2003

Provinces are adopting the 2010 NPC in an uneven manner. (Annex 4)

Fittings CSA B125/ ASME 112 harmonized

CSA B125.1 &2/ ASME A112.18.2 harmonized

Low lead requirements emerging on the potable side in the USA including California and other states but not yet in Canada.

Gas Code US Federal and State Regulations

Canadian Gas Regulations Separate Provincial Gas Code and Regulations


then be submitted to the appropriate certification body for full compliance testing. Product compliance will be tested in four specific categories including materials, mechanical, performance and safety.

Common tests that are for US/Cdn Standards are conducted first. Then any required duplicate/divergent testing for particular certifications/standard in Canada or the USA will then be conducted. Once all tests, including the duplicate ones are completed, then the data will be submitted for completion of the certification process in certification agency. See Annex 2 for an illustration

If necessary, multiple but slightly dissimilar products can be developed to serve regionalized markets where divergent standards and protocols may be required for certification. In some cases, manufacturers may find themselves doing multiple tests for the same component depending on which version of a standard is being referenced for a particular finished product.

To help avoid unnecessary costs of duplicate testing, manufacturers will try to complete as much testing as possible with a limited number of different certification organizations, but in many cases, the manufacturer must use multiple certification and testing organizations to be able to comply with the requirements of all their intended marketplaces in North America.

c. Estimate the current costs of testing and certification requirements to the current different standards and identify the additional costs associated with the duplicative requirements

Total product certification costs are estimated at 3.5 – 5% of product costs. The total value of residential plumbing and heating products sold in North America in 2011 was about $90 Billion, with approximately $3.2 ‐ $4.5 Billion spent on certification for the combined markets. These averages are primarily for mature products and the certification costs for new products can be as high as 20%.

Industry estimates that 10 % of all certification costs are the result of duplication which results in a total North American industry impact between $320 and $450 Million. It is important to note that costs for the Canadian market are higher than the 10% average because the additional duplicate certification costs are disproportionately higher for the market size. As a result, it is estimated that Canadian consumers are paying between $120 and $150 Million each year just for duplicate certification on plumbing and heating products.

One clear example of duplication from a Canadian manufacturer of plumbing products shows that a single certification for one product is conducted as many as 9 times, with inspections for those same certified products may be conducted as many as 15 times. (Annex 3)

d. Provide information on how often is the product tested. Estimating for the period of time between testing/certification the quantity of the product produced.

Plumbing products pass through the certification testing process only once. This process typically takes between 6 weeks to 6 months or more depending on the number and complexity of tests that the product must undergo.

After all testing is completed and certification is approved, then the certification body will conduct periodic inspections to ensure that conformity is being maintained for each different certification attached to a product. Inspections are routinely conducted as many as 4 times per year, by each different CO that has certified a particular product and continue for the life cycle of the product including the duplicate certifications. Manufacturers indicate that the inspection costs eventually add up to many more times than the cost of the original certification testing.


e. Organizations providing the relevant certification services for each certification

In Canada there are 35 certification organizations accredited by the Standards Council of Canada, with each CO limited to a defined scope of standards to which they can certify a product. Each of these organizations has a webpage that can be accessed to verify if a particular product is listed with them as certified product and the scopes of accreditation can be accessed at the website of the Standards Council of Canada (SCC).

CO’s in Canada that are accredited to certify various plumbing and heating products include AHRI, BNQ, CSA, IAPMO, ICC, Intertek, LabTest, NSF, QAI, UL, ULC, WQA.

f. Who is paying for the additional cost of testing and certification?

It is the responsibility of the manufacturer of components or finished products to pay for product certification and ultimately the product cost to the consumer will reflect the testing, certification and inspection costs. Costs associated with duplicate certifications impact more severely on products that are sold in Canada due to its smaller market size.

A typical water heater produced for the North American market retails for $970 in the USA, while the same product has a price of $1100 in Canada. Industry estimates that $35‐$40 of this price difference is directly attributable to the duplicate certification requirements. 5

g. Which regulatory authorizations are required for each of the current standards for the product?

Most applicable standards for plumbing and heating products installed in Canada are specified in the Model National Plumbing Code, National Building Code and National Energy Codes. Adoption of these guidelines as a jurisdictional regulation is then up to the individual AHJ such as a province or large municipality. However, not all AHJ’s adopt the most current model codes and many will conduct their own review and make modifications to the model code before bringing it into force. The resultant fragmentation means that at any given time, different jurisdictions are enforcing different versions of similar standards.

Many municipalities will take referenced codes (or standards) and modify it within their bylaws to suit their needs or objectives. They do not always get approval via provincial legislation and there are many cases where modifications become a conflict with either provincial legislation or a national model code.

This conflict becomes a source of frustration for both the municipal authorities and provincial authorities and the manufacturers who are forced to comply with numerous inconsistent requirements.

To illustrate the example, the provincial/territorial plans to adopt the 2010 National Plumbing Code are totally varied as summarized in the attached Annex 4. Some jurisdictions actually do not intend to adopt the model codes or have chosen to adopt an older version. Furthermore, in many cases, even the model code does not always reference the most current standards available and as a result, manufacturers that have new products certified to the latest available standards can end up a step ahead of current regulatory requirements.

Additionally, other federal and provincial regulations that mandate energy‐efficiency levels will supersede standards set out in the construction codes. The example of a domestic water heater clearly illustrates this overlapping and confusing jurisdictional authority, where National Energy Code

5 From interviews with industry & CIPH member companies.


guidelines, US DOE regulation, NRCan regulation and the Province of British Columbia regulation each have differing performance requirements, different enforcement dates and/or utilize different test methods to determine efficiency levels for the same product. Similar confusion exists between individual American states.

Too many different authorities have the ability to mandate enforcement of various standards or the creation of a new standard that better addresses their specific or even local particular areas of concern or objectives.

h. Barriers to removing the different standards/ duplicative testing/ certification of the product and allow for effective harmonization

A Centralized Standards Development Organization does not exist

Standards referred to by industry as ‘harmonized’ are not actually harmonized as a singular standard, but are separate standards that the SDO’s have agreed to mirror. Changes to one standard are not automatically adopted by the other and any such changes must go through the approved consensus process at each of the respective SDO’s. This is a duplicative process with additional associated costs and inefficiencies. The development of true harmonized standards would require the creation of singular North American standards development body that is also supported by the appropriate SDO’s.

SCC has established a firm policy to allow CO’s and TO’s to recognize each others testing data but many do not follow this policy and still require manufacturers to submit products for duplicate testing. Historically MOUs between testing organizations have solved this challenge but more rigorous enforcement of existing policy will be required to help streamline harmonization of standards.

Lack of comparative data on standards development and distribution

There is no central database to find information on what Canadian and/or American standards are approved or under development for a specific application. Such information could be used by the manufacturing and regulatory communities to help them determine the most efficient course of action when researching development of new products or regulations.

Overlapping jurisdictional authority

There is a need to provide more centralized authority for standards enforcement as the current system divides different compliance standards amongst many different jurisdictions.

For example, the enforcement of manufacturer energy‐efficiency compliance for a water heater is federal jurisdiction, while the sale of compliant product in some cases is a provincial jurisdiction. The actual onsite inspection comes under the regional safety authority that will ensure that the product is compliant to federal safety certifications and meets local installation standards but the local inspector does not enforce federal or provincial energy‐efficiency compliance.

Lack of synchronization in adoption of standards versions

The regulatory authority that is granted to the different jurisdictions allows each AHJ in Canada to determine their own process for the adoption of updated or new model codes and standards. The lack of a coordinating process between these authorities results in time lags in the adoption of new or updated standards and as a result, different versions of the same standards are being enforced in different trading zones at any given time. Even as more standards become harmonized, these regulatory differences will continue to result in the need for products to be certified to different versions of the same standard at any given time.


In the case of a water heater, even as bi‐lateral energy‐efficiency standards move toward harmonization, different implementation dates result in continued need for manufacturers to obtain different certifications for different jurisdictions.

Different versions of standards referenced at the same time

The codes and standards system will require a major reorganization to allow for the universal adoption of the latest version of any applicable standard. Some standards include reference to other standards and different versions of these secondary references necessitate duplicate or redundant certifications.

For example, a manufacturer may produce a single component that is used in the assembly of several different finished products. If that single component must be certified to NSF61, it may have to be certified to the 1999, 2003, 2005, 2007 or 2010 version of NSF61, depending on the current standard that applies to the finished product (Annex 3) in a particular jurisdiction. As Illustrated in Annex 3, one company may have their products certified by CSA and NSF but will still have to submit to a municipality (e.g. City of LA) OR a provincial authority (BNQ) for mirrored testing and inspections.

The competitive business environment of CBs and SDOs

The business model for testing and certification organizations is competitively‐based and multiple standards, tests and certifications provide greater business opportunities for these organizations. Elimination of duplication could reduce the size of market and the testing and certification industry may be opposed to such changes.

i. Are there existing mechanisms in place to remove the duplicative standards / testing / certification requirements?

There are no formal mechanisms or guidance to remove duplicate standards requirements. Current standards referred to by industry as ‘harmonized’ are not formally harmonized as a singular standard, but remain separate standards that the SDO’s involved have agreed to mirror. ‘Harmonization’ of any such standards was initiated by industry and the costs to support the process through the technical committees were borne by industry. Any future changes to one part of a ‘harmonized’ standard are not automatically adopted by the other and any such changes must go through the full consensus approval process at each of the respective SDO’s.

An example of this is the ASME A112.18.1/CSA B125.1 Standard for plumbing supply fittings. Both ASME and CSA created a Joint Harmonization Task Group under the jurisdiction of their respective Technical Committees for these particular standards with final approval at higher levels within each SDO. Formal approval of the joint standard was then granted by ANSI in the USA and the SCC in Canada. It is the balloting process differences that are not harmonized here as on either side of the border, the SDO must follow the SCC/ANSI process.

j. Estimating the approximate savings of eliminating duplicative standards, testing, and certification requirements per unit of the product

Industry estimates that approximately 10 % of all certification costs are the result of duplication. However, costs for the Canadian market are much higher than the average because the additional duplicate certification costs are disproportionately higher for the smaller market size. As a result, it is estimated that Canadian consumers are paying between $120 and $150 Million each year for duplicate certification on just plumbing and heating products.


A typical water heater produced for the North American market has a retail price of $1000 in the USA, while the same product sells for $1100 in Canada6. (Currency adjusted at $1 Cdn= $.97 US) Industry estimates that $35‐40 of this price difference is directly attributable to duplicate certification requirements. (Annex 3)

6. If a joint secretariat for standards harmonization was to be created to establish a process for determining whether the Canadian‐US standards applying to existing products were equivalent, who would support this initiative? Who may have reservations about this?

Industry would be supportive of any initiatives that reduce duplicative certification and testing requirements. Additionally, the current consensus standard development process requires a great deal of industry input into the technical committees that write such standards. The commitment of personnel resources to the committees is critical to its success and there are large costs associated with the development and maintenance of duplicative standards in addition to the duplicative compliance process. Any measures that reduce these costs would be supported.

Some of the other stakeholders in the determination of standards equivalency would include Canadian federal ministries and their American counterparts in Health, Natural Resources, Environment and Industry. Depending on their size and mandated authority, other jurisdictions such as individual provinces and states would be affected by changes to the standards development and application process.

Many of these bodies rely on the standards development systems as a means to address some of their individual concerns and some of them may have reservations that a secretariat involving more stakeholders has the potential to dilute their authority. Other AHJ’s s such as a small province may be supportive of a secretariat that could provide access to resources that would relieve the need for individual research and regulatory development costs

The SDO’s and their governing bodies would be the most impacted group if a new secretariat for standards review were to be implemented. Although there are already clear cases of cooperation and harmonization of some existing standards, there is great potential for disagreement on which of similar standards is ‘the best’ in any discussion on equivalency. There is a tremendous amount at stake for these organizations and it would be expected that they would want to vigorously defend their current authority and intellectual properties.

7. Would Canadian and USA SDO/TO/CO’s be in favour, neutral or opposed to your proposal? Would Canadian‐US certification bodies be in favor, neutral or opposed?

Movement toward greater harmonization of bi‐lateral standards would have great impact on the business models of all SDO, TO and CO’s. Their individual support or opposition to a fundamental change in the governance model cannot be determined by other parties, but we have endeavoured to outline some of the anticipated impacts that could result from greater harmonization of standards and certification requirements.

Standards Development Organizations

The need for development of new safety and performance standards is not likely to diminish with greater regulatory cooperation. It is more likely that the increasing need to meet rapidly evolving

6 From Sears and Sears Canada catalogue


regulatory, industrial and environmental goals will create greater opportunity for technical collaboration to create new standards that are applicable to both sides of the border.

There is always a cost to develop any new standards, but increased collaboration and productivity could result in an overall decrease in the cost of development of new standards as individual SDO’s would be able to better focus on particular areas of expertise. However, there is also high potential for conflict during the process of determining which SDO may be best suited to the development of any particular new standard that may be destined for bi‐lateral adoption.

Certification Organizations/ Testing Organizations

Increased harmonization of standards would be expected to result in a decline of business for Certification Organizations. Current rules for conformity assessment do permit certification organizations to accept test data from other duly accredited laboratories with out further review. However, in practice this acceptance is often not granted and manufacturers have instead been forced to pay for duplicative testing.

Multiple differing standards that are regionally or nationally based offer more opportunity for certification services especially when some of the protocols are similar or overlapping. Eliminating those similar or overlapping protocols will inevitably result in fewer business opportunities for certification and testing organizations on both sides of the border. (Annex 8‐ PMI Position Statement on Universal Conformity Assessment)

8. What are the risks in determining whether Canadian and US standards applying to the same product are equivalent? What would be the resources required on the part of industry in order to identify existing standards that are equivalent?

In broad terms, standards are used to address health, safety and environmental requirements. At the same time, these objectives will vary between jurisdictions depending on 1) policy goals and 2) physical differences. The application of ‘one‐size‐fits‐all’ solutions may be cost‐effective, but the necessary compromises may also run the risk of creating gaps in the very protection that standards are meant to provide.

Health & Safety

Most product standards are developed to ensure the health and safety of the users of these products and that mandate will not change. When general human health hazards are identified in one jurisdiction, most others will soon respond with requirements that reflect universal concern. The Codes and Standards system can be flexible enough to change to accommodate new requirements. For example, in the plumbing industry, limiting the use of lead‐containing brasses and alloys in fixtures and fittings is an example where national standards are moving toward technical and temporal harmonization to ensure uniform protection for all North Americans. Future applications of harmonized standards for major health and safety issues will be well‐supported and there is little risk that such standards would require much compromise in their approval.

Physical Factors

While the base engineering principles for plumbing and mechanical systems in the US and Canada are essentially the same, there is a huge variance in the physical and geographical diversity of installation and use. Conditions of use across North America range from low to high temperatures, altitudes and humidity levels. As a result, certification standards and tests will often reflect these variations as products and building construction requirements for one geographic area may differ greatly from those developed for another. When the fundamental operating conditions differ significantly, then differing


standards and performance criteria may continue to be required and completely harmonized standards for such products could result in compromises that may be unacceptable to many stakeholders.

Government Policy Goals

Harmonization of product performance standards can only be accomplished if the policy goals of the respective governing bodies are also aligned and harmonization is a noted objective. This is especially critical in the areas of energy‐efficiency and water‐use conservation and their emerging technologies. This is currently of great concern for the plumbing and heating industry as performance requirements for energy‐efficiency are becoming increasingly divergent across national and provincial boundaries. (Annex 6).

Harmonization efforts in the current standards system takes a long time and this time lag creates opportunity and need for individual AHJ’s to introduce their own often different proposals, objectives, solutions and policies. One of the risks in determining standard equivalency will be the need to compromise on accepted policy goals. When trying to determine the “best” standard, the lowest common denominator is not likely to meet the stated policy goals of all key stakeholders.

At this time, the plumbing and heating industries are already working closely with many different government agencies and in general terms, the mutual goals are reasonably aligned. More rapid development of harmonized standards would be beneficial to all parties for achieving improved energy‐efficiency and water conservation goals.

9. How should provinces/municipalities be engaged in order to secure support for this initiative?

All of the AHJ’s are important to the ultimate success of this initiative. The AHJ’s and their field inspectors are often at the frontline of application of codes and standards and their experience is often the proverbial ‘canary in the mine’ when particular codes or standards may not be working as intended. They typically identify issues that can be brought to a national forum for discussion.

Regulators in Canada often play an active role in standards and code development and the creation of a system for more centralized determination of selected codes and standards would require individual AHJ’s to relinquish some of their own authority. The loss of some of their current autonomy would also reduce some their needs for individual committees, researchers and other standards programs. However, these productivity gains would likely be offset by a greater need for education and training programs for enforcement officials. There will also be a continuing need to address local or regional needs that universal standards cannot meet, so the AHJ’s will require some resources to support a mechanism or forum to address local or regional standards exceptions.

As an example of this type of forum, the plumbing industry holds an annual meeting of the Canadian Advisory Council on Plumbing where industry, provincial and federal regulators and certification organizations meet to discuss issues relating to standards and codes. This unique model could be used as a template for discussion at municipal levels or at the top levels of bi‐lateral national regulators.

10. What types of new products currently under development would likely get strong industry support in Canada for the development of harmonized standards between Canada and the US before the product is commercialized?

Industry would encourage greater harmonization of standards in areas related to energy‐efficiency and water conservation, and other emerging issues related to resource conservation. The elimination of


duplicative testing would allow for better resource allocation to meet the challenges of emerging technologies and materials needed to address these issues.

Policy responses to environmental protection have resulted in the rapid development of varying regulations at all levels of government including municipalities, states, provinces and federal departments. In many cases, currently referenced standards and/or model codes are lagging behind the immediate needs of these authorities having jurisdiction (AHJ) and in the absence of clear guidance, these have individual AHJ’s have created individual regulations designed to meet their own needs.

The resulting fragmentation of codes and regulations creates numerous different solutions covering the same or similar products. It has also created unintended conflicts of interest and different jurisdictions or even internal departments can find themselves working at cross‐purposes. Manufacturers may have to create special products for these many different markets; or as is the case in BC, the impact has been a reduction in consumer choice and/or rising consumer costs as some hot water heater manufacturers have withdrawn products that do not meet their unique energy‐efficiency requirements.

11. What types of existing products subject to two distinct standards / testing / certification requirements would likely get strong industry support in Canada to eliminate duplicative requirements and generate cost savings?

Industry would support elimination of duplicative requirements where they exist for almost all current products in the sector including heating appliances, greywater/rainwater systems, hydronic systems, backflow preventors, soil pipe and drinking water treatment systems.


Acronyms AB Accreditation Body

AHJ Authority Having Jurisdiction

ANCE Mexican Conformity Assessment System and Standardization

ANSI American National Standards Institute

ASA American Supply Association

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials International

CACP Canadian Advisory Body on Plumbing

CANENA Council for Harmonization of Electrotechnical Standards of the Nations in the Americas

CB Certification Body (same as CO)

CEA Consumer Electronics Association

CEMC Consumer Electronics Marketers of Canada

CEMRA Electrical Manufacturer Member Representatives Association

CIPH Canadian Institute of Plumbing & Heating

CO Certification Organization

CODD Certifications Organizations Due Diligence Taskforce (Created by CACP and managed by CIPH)

CSA Canadian Standards Assocoation

DoE US Department of Energy

EC Environment Canada

EFC Electro Federation Canada

EPA US Environmental Protection Agency

FCS (IECEE) Full Certification Scheme

HC Health Canada

HVAC Heating Ventilation & Air Conditioning

IAJAP Industry Advisory Joint Advisory Panel

IAPMO International Association of Plumbing and Mechanical Officials

IC Industry Canada

IECEE International Electrical Commission for Electrical Equipment

JAB Joint Advisory Body

MOU Memorandum of Understanding

NAW National Association of Wholesalers


NEMA National Electrical Manufacturers Association

NIST National Institute of Science and Technology

NRCan Natural Resources Canada

NSF National Sanitation Foundation Interantional

NSF 61 National Sanitation Foundation (Standard 61 for Drinking Water System Components)

NYCE Electronics Standardization and Certification (Mexico)

OEM Original Equipment Manufacturer

ONSPEX CSA's enginered testing organization

OSHA Ocupational Health and Safety

P&H Plumbing & Heating

PIAC Plumbing Industry Advisory Council

PMI Plumbing Manufacturers International

RCC Regulatory Cooperation Council

RFP Request for Proposal

RFSOQ Request for Statement of Qualifications

SCC Standards Council of Canada

SDO Standards Development Organization

SDOJAP Standards Development Organization Joint Advisory Panel

SOQ Statement of Qualifications

TO Testing Organization

UL Underwriters Laboratories


Annex 1‐ CIPH member companies INDEX OF CIPH MEMBER COMPANIES As of June 27, 2012 * Subsidiary ++ Specialty Wholesaler MANUFACTURERS A.O. SMITH WPC CANADA ADS CANADA INC. ALLIED ENGINEERING CO. ALTREK INDUSTRIES LTD. AMERICAN STANDARD BRANDS ANTRIM MARKETING GROUP INC. ANVIL INTERNATIONAL CANADA ARMSTRONG LIMITED [S.A.] BAINS OCEANIA BATHS BELANGER .UPT BIBBY-STE-CROIX BLANCO CANADA INC. BOSHART INDUSTRIES INC. BOW PLUMBING GROUP INC. BRADFORD WHITE CANADA BRYMER INDUSTRIES INC. CB SUPPLIES LTD. CAMBRIDGE BRASS, INC. CANPLAS INDUSTRIES LTD. CAPPRODUCTS LTD. CELLO PRODUCTS INC. DAHL BROTHERS (CANADA) LIMITED DANFOSS INC. EMERSON CANADA ENVIROGARD PRODUCTS LTD. ERICO CANADA INC. FAIRVIEW FITTINGS & MANUFACTURING LTD. FONDERIE LAROCHE LTÉE FRANKE KINDRED CANADA LIMITED G.F. THOMPSON CO. LTD. GATES CANADA INC. GRAVENHURST PLASTICS LIMITED GREAT LAKES COPPER INC. GREENWAY WATER TECHNOLOGIES GROHE CANADA INC. GRUNDFOS CANADA INC. HEATLINK GROUP INC. HONEYWELL LTD. HYTEC PLUMBING PRODUCTS* IBC TECHNOLOGIES INC. INDUSTRIES DETTSON INC. INDUSTRIES GRANBY INSINKERATOR (CANADA)* IPEX INC. JENKINS-NH VALVES KOHLER CANADA LAARS HEATING SYSTEMS COMPANY* MAAX BATH INC. MASCO CANADA LIMITED

MASCO CANADA (BRASS CRAFT DIVISION)* MASCO CANADA (DELTA FAUCET CANADA DIVISION)* MASCO CANADA (MASTER PLUMBER DIVISION)* MASCO CANADA (PLUMB SHOP DIVISION)* MIROLIN INDUSTRIES CORP. MOEN INC. MORDEN NATIONAL SALES AND MARKETING INC. MUELLER STREAMLINE CO. NOVA TUBE INC. NOVANNI STAINLESS INC. NY THERMAL INC. OAKVILLE STAMPING AND BENDING PENTAIR CANADA INC. PREPER – PLS TECH INC. REHAU INDUSTRIES INC. RHEEM CANADA LTD./LTÉE ROYAL PIPE SYSTEMS SANIFLO SLANT/FIN LTD./LTÉE SLUYTER COMPANY LTD. SOLENO INC. TACO (CANADA) LTD. TAYLOR PIPE SUPPORTS TEKMAR CONTROL SYSTEMS LTD. TEXEL GEOSOL INC. UPONOR, LTD. USINES GIANT FACTORIES INC. VANGUARD PIPE & FITTINGS LTD.* VICTAULIC LTD. VIESSMANN MANUFACTURING CO. INC. WATERGROUP COMPANIES INC. WATERLINE PRODUCTS CO. LTD. WATTS WATER TECHNOLOGIES (CANADA) INC. DRAIN DIV.* MANUFACTURERS (CONT’D.) WATTS WATER TECHNOLOGIES (CANADA) INC. POWERS DIV.* WATTS WATER TECHNOLOGIES (CANADA) INC. RADIANT DIV.* WATTS WATER TECHNOLOGIES (CANADA) INC. VALVE DIV.* WEIL-McLAIN CANADA SALES INC. WHITE RODGERS* XYLEM, RESIDENTIAL & COMMERCIAL WATER ZURN INDUSTRIES LTD. MASTER DISTRIBUTORS ACUDOR ACORN LIMITED AMTROL CANADA LTD. BMI CANADA INC. CASH ACME CANADA CCTF CORPORATION CONBRACO INDUSTRIES, CANADA DOBBIN SALES LIMITED


FERNCO CONNECTORS LTD. GLOBE UNION CANADA INC. JOHN L. SCHULTZ LTD. LYNCAR PRODUCTS LTD. M.A. STEWART & SONS LTD. MESTEK CANADA, INC. NCI MARKETING INC. NOVO WATER (A DIVISION OF CANATURE NORTH AMERICA) OATEY CANADA SUPPLY CHAIN SERVICES CO. PAC PVF TRADE INC. PFISTER FAUCETS (FORMERLY PRICE PFISTER) RAPTOR CUTTING TOOLS INC. S.I.E., A DIVISION OF LAURENTIDE CONTROLS THE ALLIED GROUP OF COMPANIES THORNDALE INTERNATIONAL INC. URECON LTD. WILO NORTH AMERICA MANUFACTURERS’ AGENTS ALLAN FORREST SALES (1991) LTD. ALLIED TECHNICAL SERVICES INC. ALTATECH AGENCIES LTD. ANCAMNA SALES LTD. AQUA TECH SALES & MARKETING INC. ARMCO AGENCIES INC. AXFORD AGENCIES ALBERTA LTD. BARCLAY SALES LTD. BARCLAY SALES (ALBERTA) LTD.* BARRETT SALES (1998) LTD. BELLBROOK SALES INC. BPL SALES LTD. CAN-AQUA INC. CAN AQUA INTERNATIONAL LTÉE. CAN-MECH AGENCIES LTD. CANADIAN AQUALINE SALES INC. CARDINAL SALES & MARKETING CENTON SALES CORP. CHARD MARKETING INC. CON-CUR WEST MARKETING INC. DARKE MARKETING INC. DAVE EDISON AGENCY LTD. DAVE VALLIERES & ASSOC. INC. DC SALES DEVCO SPECIFICATION SALES & MARKETING DISTECH INC. DYNAMIC AGENCIES (2000) LTD. EQUIPCO LTD. E.S. GALLAGHER SALES LTD. FENNELL MARKETING & SALES LTD. FLOW SALES FLUID SOLUTIONS SALES AGENCY LIMITED G.R. NIVEN SALES INC. GREAT DIVIDE MARKETING GREAT LAKES MARKETING INC.

HARRIS ATLANTIC SALES LTD. HG SPEC INC. HY-LINE SALES LTD. HYDRO-MECHANICAL SALES LTD. HYDRONIC AGENCIES LTD. ICON AGENCY LTD. J. LEVANDIER SALES INC. J. WRIGHT SALES LTD. J.F. TAYLOR ENTERPRISES LTD. J.L. SALES LTD. JESS-DON DUNFORD LIMITED JONES GOODRIDGE INC. JSA SALES INC. KM AGENCY LTD. KEN PARTINGTON SALES LTD. KERN INDUSTRIES (1989) LTD. KLIMAR AGENCY INC. KVC INDUSTRIES CORP. LES AGENCES J. PIERRE SYLVAIN INC. MANUFACTURERS’ AGENTS (CONT’D.) LES AGENCES LAMBERT & BEGIN INC. LES AGENTS DE MFR VISTAQUA INC. LES VENTES BERGERON SALES INC. MAR-COM SALES MAR-WIN AGENCIES LTD. McKELL MARKETING LTD. MECH-TECH MARKETING INC. MECHANICAL SYSTEMS 2000 INC. MIDCAN HYDRONICS MIDWEST ENGINEERING LTD. MORGAN GROUP (THE) NEROHTEK SALES AGENCY ONWARD SALES & MARKETING LIMITED PALSER ENTERPRISES LTD. PAR FOUR PLUMBING PRODUCTS INC. PARMENTER & ASSOCIATES PELCO SALES POINTS WEST MARKETING INC. PRO-WEST SALES LTD. QUADRA MARKETING AND SALES INC. QUEST SPECIALTY SALES LTD. R.M. BELLAMY SALES LTD. RAFALES AGENCIES INC. REPCO R.N.G. MARKETING INC. ROLAND LAJOIE INC. [LES ENTREPRISES] ROSS H. BARBER & ASSOCIÉS LTÉE SHORELINE MECHANICAL SALES LTD. (FORMERLY BELL & BELL SALES LTD.) SHOWERLINE SALES LTD. SIERRA SALES & MARKETING LTD. SMITH AGENCIES SOURCE WEST SALES INC. SPECTRUM SALES AGENCY LTD. STRINGER SALES INC. TITAN SALES AND MARKETING TRISON SALES INC. TRUSTEK SALES INC. VANTAGE MARKETING LTD. VENTES TECHNIQUES NIMATEC INC.


WALMAR MECHANICAL SALES LTD. WATERLINE PRODUCTS CO. LTD.* [Sales Agency Div] WESTCAN MECHANICAL SALES LTD. WESTPOINT SALES INC. WILLIAM SCOTT INC. WHOLESALERS AMATI PLUMBING SUPPLY LTD.++ ANDREW SHERET LIMITED B.A. ROBINSON CO. LTD. BARDON SUPPLIES LTD.* BARTLE & GIBSON CO. LTD. BOONE PLUMBING & HEATING SUPPLY INC.* CARSON SUPPLY CENTRAL PLUMBING SUPPLY INC. CRANE SUPPLY CRONKHITE SUPPLY – ALBERTA REGION* CRONKHITE SUPPLY – B.C. REGION* DAVIES SUPPLY GROUP LTD. DESCHÉNES & FILS LTÉE - MONTRÉAL* DESCHÉNES & FILS LTÉE - QUÉBEC* DESCO PLUMBING & HEATING SUPPLY INC* DON PARK, A NOBLE COMPANY ECCO SUPPLY++ EDDY GROUP LTD. EMCO CORPORATION EMPIRE CANADA FLOCOR INC. (FORMERLY MUELLER FLOW CONTROL) FRONTIER PLUMBING & HEATING SUPPLY FULFORD SUPPLY LIMITED GAGNÉ & FILS QUINCAILLERIE (FORMERLY QUINCAILLERIE LAMBERT INC.) GARTH INDUSTRIAL++ GRO-MEC INC. GROOM-CALLAGHAN* GROUPE COTÉ-HUOT INC. GROUPE DESCHÉNES INC. GROUPE MABURCO PLOMBERIE CHAUFFAGE INC. GUILLEVIN INTERNATIONAL CO. HAMILTON HYDRONICS LIMITED++ HILL SUPPLIES++ HOWELL PIPE & SUPPLY++ HUDSON PLUMBING SUPPLIES LTD.* INDEPENDENT MECHANICAL SUPPLY INC.++ ISLAND DISTRIBUTORS LTD. J.U. HOULE LTÉE J.W. BIRD AND COMPANY LIMITED JAMES G. CRAWFORD LTD. KOTYCK BROS. LTD.++

M.P.H. SUPPLY, A NOBLE COMPANY MAIN MATÉRIAUX DE PLOMBERIE ET CHAUFFAGE INC. MARCEL BARIL LTÉE MARKS SUPPLY INC. MATERIAUX DE PLOMBERIE PMF INC.++ WHOLESALERS (CONT’D.) MCKEOUGH SUPPLY* M.I. VIAU & FILS LTÉE NEAR NORTH SUPPLY INC.++ NELCO INC. NIAGARA PLUMBING* NOBLE (FORMERLY NOBLE TRADE) NORTHEAST EQUIPMENT LTD.++ NUROC PLUMBING & HEATING* PRODUITS BCM LTÉE++ RÉAL HUOT INC.* SEXAUER LTD.++ SINCLAIR SUPPLY LTD.++ SMITH STOCKLEY LIMITED SOURCE ATLANTIC TECNICO CHAUFFAGE LTÉE TRIANGLE SUPPLY LTD. UNIVERSAL SUPPLY CO. INC. WESTERN PLUMBING & INDUSTRIAL SUPPLIES LTD. WESTLUND INDUSTRIAL SUPPLY* WOLSELEY CANADA YORKWEST PLUMBING SUPPLY INC. ASSOCIATE MEMBERS ALLPRISER BRITISH COLUMBIA INSTITUTE OF TECHNOLOGY CSA GROUP GEORGIAN COLLEGE HPAC MAGAZINE INTERTEK TESTING SERVICES NA LTD. MECHANICAL BUSINESS MAGAZINE MEDICINE HAT COLLEGE MOHAWK COLLEGE OF APPLIED ARTS & TECHNOLOGY NAIT: NORTHERN ALBERTA INSTITUTE OF TECHNOLOGY PLUMBING & HVAC RAVEN HYDRONIC SUPPLY LTD. RED DEER COLLEGE SAIT POLYTECHNIC SASKATCHEWAN INSTITUTE OF APPLIED SCIENCE AND TECHNOLOGY (SIAST)


Annex 2‐ General Certification Process

Prototyping

Engineering Design

Internal Compliance to Standards

Production Model

Submittal for Certification testing

Materials Testing

Mechanical Testing

Performance Testing

Safety Testing

Common US

and Canadian Standards Compliance

Tests

Common US


Tests

Common US


Tests

Common US


Tests

US Standards Compliance

Tests

Canadian Standards Compliance

Tests


Tests


Tests


Tests


Tests


Tests


Tests

Data

Collation to US

Standard

Data

Collation to Cdn. Standard

Data

Collation to US

Standard

Data


Data

Collation to US

Standard

Data


Data

Collation to US

Standard

Data


US Certification testing Canadian Certification

US/Canadian Mark award where applicable

Manufacturer

Certification & Testing Organization

Periodic Auditing for

Compliance for each iteration of each standard for each country or market

the product must meet compliance

Feedback loop for at “fail” during the testing


Annex 3‐ Manufacturer’s Certification Costs for US and Canada Summary of Costs For the Following 3 pages Sector: PEX, Pipe & Fittings Source: Single manufacturer Distribution: Global Number of Products: Hundreds of Plumbing Fittings Sources of Duplication: Certification Costs: $1.8M for 2011 (TOTAL)+ Duplication: Tests % of total frequency total cost

for duplication Certification BD 7.2% done 7 times $130,773 Certification S 5.7% done 9 times $103,697 Certification M 8% done 9 times $148,011 Inspection Costs* 69% done 15 times $1,254,483* Note: + The company utilizes 19 different Certification and Testing Bodies to comply with all the markets they are selling into. * inspections account for 45 days lost production time‐ production time not included in the inspection costs Pure Duplication of tests and costs BNQ – 5% of costs. BNQ inspects independently and takes their own samples to submit for NSF for testing. City of LA – Submit certified product for testing for local compliance. NB# ‐ In certain markets the cost of local compliance is a function of Certification S and are acceptable due to the size of the market Legend: Certification BD ‐ New Product certification costs Certification S ‐ Sales Costs to Add to existing product lines, companion certifications and local compliance Certification M ‐ Manufacturing Certification Costs Inspection ‐ Cost of maintaining certification of all products


Annex 4‐ National Plumbing Code Adoption for Canada.

2010 NATIONAL PLUMBING CODE

Alberta Will be adopting the 2010 National Plumbing Code in Mid‐2013.

British Columbia Will be adopting the 2010 National Building Code Part 7 in October, 2011.

Manitoba Will adopt the 2010 National Plumbing Code with in six months of NRC

publication.

New Brunswick Proposed adoption date in late in 2011

Newfoundland The NPC is adopted under the Provincial Department of Transportation and

Works Project Management and Design Administration Manual.

Northwest Territories Never adopts the National Plumbing Code. City of Yellowknife inspects plumbing

and adopts the current National Code within 6 months of release.

Nova Scotia

Nunavut Never adopts the National Plumbing Code and has no plans to.

Ontario Will adopt the 2010 National Plumbing Code, with modifications, in late 2011.

Prince Edward Island Has adopted the 2005 edition in Oct of 2009, no plans on adopting the 2010 code

at this time.

Quebec Will adopt the 2010 National Plumbing Code, with modifications, in early 2012.

Saskatchewan Still in the process of adopting the 2005 National Plumbing Code.

Yukon Will adopt the 2010 National Plumbing Code around April, 2011.


Annex 5‐ ANSI/NSF 61 Integration into Canadian Standards


Annex 6‐ Divergence in the U.S. and Canada for Heating, Ventilation, Air Conditioning, Refrigeration (HVACR), Water Heating Industry (Updated Dec. 2011), & Selected Plumbing Items (updated by CIPH) Source AHRI

Product U.S. Federal Stds. Canadian Federal Stds. Canadian Province Stds.

Water Heaters

Gas/Electric: energy efficiency standards measured in Energy Factor (EF)

Gas: Same Energy Factor standard as U.S. Considering revising to be more stringent than revised EF adopted by DOE in April 2010. Electric: Efficiency standard only measures standby loss

BC: Established separate energy efficiency standards

Furnace Gas: 78% AFUE (proposed to be increased to 80% AFUE and 90% AFUE depending on region)

90% AFUE. NRCan has additional reporting requirements which are not required in the U.S. such as:

- Maximum heat input and output capacities

- Average annual electrical energy consumption If the unit has an integrated cooling component

- Blower motor consumption (BE) in watts and voltage at heating speed

- Blower motor consumption (Bec) in watts and voltage at circulation speed

- Power burner motor consumption (PE) in watts, and voltage

- Standby power consumption when the unit is powered and on standby

BC: Established separate energy efficiency standards. Manitoba: Established separate energy efficiency standards.

Boilers U.S.‐Canadian efficiency standards are identical, however, Canadian standards have confusing uncertain implementation date.

U.S.‐Canadian efficiency standards are identical, however, Canadian standards have confusing uncertain implementation date.

N/A

Residential Unitary AC & HP

U.S.‐Canadian efficiency standards are identical.

U.S.‐Canadian efficiency standards are identical; however, NRCan has proposed reporting of COP at 0F and 17F which are not required in the U.S. In addition, both U.S. and Canadian test procedures do not provide for the testing at 0F.

Air Handlers

U.S. regulations under development

Reporting of electric energy consumption per CSA 823 will be required effective Jan 1, 2012

N/A

Chillers U.S.‐Canadian efficiency standards are identical.

U.S.‐Canadian efficiency standards are identical. However, NRCan requires reporting of model number that is not consistent with

N/A


industry practice.

Hydronics No standard referenced in code. CIPH is in discussion with IAPMO on adoption in the US.

Canada reference CSA B214 into the plumbing code

N/A

Plumbing Greywater

NSF 350 in effect CSA B128 referenced in Code N/A

Plumbing Low Lead Plumbing Fittings

US Law with NSF 372 supporting standard. Passed January 2011, coming into effect January 2014

CSA B125.3 being modified now for just fittings N/A

Plumbing Cisterns

IAPMO proposed a standard

CSA B126 out for public review currently N/A

Drinking Water Treatment Systems

States apply NSF Standards

CSA B483 proposed for the 2015 model National Plumbing Code

QC‐ already applying both NSF and CSA Standards (2008) ON‐ poised to reference CSA standard in code


Annex 7‐ CIPH’s Letter to PTPACC on Codes Fragmentation


Annex 8‐ PMI Position Statement on Universal Conformity Assessment Approved May 2000 – Revised November 2011 Accredited certification agencies for plumbing products are accredited through either Standards Council of Canada (SCC) or American National Standards Institute (ANSI), which use International Organization for Standardization (ISO) guides for accreditation of certification agencies. Under this accreditation, certification agencies are permitted to accept test data from laboratories accredited under ISO Guide 25 to specific standards. Plumbing manufacturers urge that test data generated by testing laboratories accredited under ISO Guide 25 by organizations such as SCC, National Voluntary Laboratory Accreditation Program of the National Institute of Standards & Technology (NVLAP), American Association of Laboratory Accreditation (A2LA), National Evaluation Service (NES) and International Conference of Building Officials ‐ Evaluation Services (ICBO‐ES), should be accepted by certification agencies, accredited through SCC and ANSI, without further review. In addition, plumbing products and materials already listed/certified by an accredited certification agency for specific referenced standards, using test data generated by an accredited testing laboratory, should have that listing/certification accepted by other certification agencies, without further review or auditing. One of Plumbing Manufacturers International’s (PMI) goals is for plumbing products to be tested and certified once, and recognized worldwide. It is imperative that test data generated by nationally and internationally accredited testing laboratories be recognized and accepted by certification agencies in order to reach this goal. Similarly, the listings and certifications of accredited certification agencies must also be recognized and accepted universally by the appropriate certifying agencies in each jurisdiction. Accredited certification agencies providing such a service will be the preferred provider for plumbing manufacturers. Source: http://www.pmihome.org/i4a/pages/index.cfm?pageid=3301

A VALUE PROPOSITION FROM THE CANADIAN INSTITUTE OF PLUMBING

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