2202 2nd Avenue Regina, SK S4R 1K3 PH: (306) Toll Free: (866) FAX: (306) Toll Free: (866) Website:

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Sabrina Rose
5 years ago
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1 Costs 1. No indication of potential COSTS for tests etc. Note that most operators are volunteers and derive no income from operating. o Written exam fee remains the same This should be a one time cost o Decisions on licensing and practical test costs have yet to be finalized but will be modelled within the context of Costs of the 2 year licensing and practical examination within the 6 year cycle to remain consistent with the current annualized cost of the 5 year licence o TSASK operates on a cost recovery model as a not for profit company TSASK expects TSASK costs for licensing to rise due to the new expenses associated with the practical test TSASK recognizes that overall costs attributed to traction engine safety services (inspections, licensing, testing, etc.) are not recovered fully by associated fees TSASK does not intend to adjust fees to a cost recovery position TSASK may need to recognize some cost recovery for the additional expenses associated with driver tests at some point in the future when those costs are better known Practical Driving Exam 1. Where will the driving test take place and whose engine will be used? TSASK will be doing all the testing using the WDM fleet of traction engines in Saskatoon. That agreement is being finalized. TSASK envisions holding practical driving exams during the months of June to September at the WDM in Saskatoon because they have an area which is conducive to the elements that TSASK feels should be part of the exam (e.g. inclines, turns, etc.). Depending on the number of applicants, the number of days of testing will be determined. TSASK may consider holding the test in other areas of the province once the test is well established (over the next few years). Any other area that would like to hold a driver s test would have to have a course available that has all the elements of the test as the WDM in Saskatoon. 2. Who will be the driver tester? (only driving test needed is emergency stop [not belting, parking]) TSASK will provide an experienced invigilator for the driver test. At this time, Larry Postnikoff, Manager, Boiler & Pressure Vessel Safety & Inspections Unit, will be the TSASK Invigilator. He will then qualify other TSASK Inspectors to perform the driving test invigilation. TSASK believes there is more to the safe operation of a Steam Traction Engine than just the emergency stop. Although no belting will take place, the driving exam will include such things as starting, stopping, inclines and whatever else becomes the standard for the test. The test will be the same for all operators. 3. Concerning the driving test what would the test entail? Will the steering person be tested at the same time? The details of the driving test are being finalized. Once those are finalized, TSASK is planning on making a demonstration video of a driving test. As well, a paper will be released with the components of the test identified and TSASK s expectations for a successful result. Page 1 6

2 4. Traction engine operation is quite UNIT SPECIFIC. I don't see how TSASK personnel can remain proficient in all engine operation to the point of administering driving tests. The purpose of the driving test is to ensure that the operator has control of the unit. There will be basic skills and checks that TSASK is looking for on the test. This will be demonstrated in a video and in description so that all operators are clear what TSASK is expecting to see. The goal is to ensure that, regardless of what engine the operator may be on, they know the basic safety requirements to operate any engine. On another note, Alberta and Manitoba both require practical exams. TSASK is looking at the components of their tests as well as the qualifications of their driving test invigilators. TSASK will use this information in the creation of the driving test and in ensuring that jurisdictional requirements remain as consistent as possible across the provinces. 5. Is there an age restriction on being a steam traction engine operator? Yes. There are restrictions for Steam Traction Engine Operators under 16 years of age. The restrictions are detailed below: Anyone under the age of 16 may apply to participate in the Graduated Operator Licence Program. The rules of the program for obtaining a steam traction engine operator licence are applied the same. However, if you are under the age of 16, when you pass both (written and practical) parts of the provincial exam, your licence will be restricted until you reach the age of 16. The restricted licence holder shall: be under the constant supervision of a non restricted licenced steam traction engine operator; have a non restricted licence holder on the steam traction engine at all times whenever operating a steam traction engine. Upon turning 16 years of age, the restricted licence holder may apply to TSASK to have the restriction removed. No extra testing will be required to remove the restriction. The restricted licence holder shall prove continuity every two years and shall take the practical exam every 6 years just the same as an unrestricted steam traction engine licence holders. Approved Course 1. I don't see the need for 2 written exams as indicated one to get your learner s licence and another to get your operator s licence. How are they different? The course exam is not necessarily the provincial exam. The provincial exam is administered by TSASK or their representative. A course taken in Manitoba may be acceptable to the Chief Inspector in Saskatchewan; however, the course exam would be quite different than the Saskatchewan provincial exam. In the event a candidate took the WDM course offered in Saskatoon, the final written exam for the course is the provincial exam. In that case, TSASK would not require a second exam but would accept the results and hold them until such time as the candidate accumulates the necessary operational hours and then challenges their practical test. Remember, each part of the exam expires 24 months after the successful challenge of the exam. In other words, if the candidate does not complete the practical requirements and passes the exam in the two year window, they would be required to re write the written exam as the test validity would have expired. WDM is also in the process of applying to TSASK to have the WDM course qualified as meeting all the requirements for the candidate to challenge both parts of the provincial exam at the successful conclusion of the course. In other words, ensuring the course has enough operational hours for the candidates to immediately challenge the practical driving test. For other Power Engineering programs, TSASK has applied this concept of laboratory time in educational institutes so that candidates get steam time credits. TSASK sees the steam traction engine course at the WDM as a perfect opportunity to apply the same logic. Once the review is complete, TSASK will post their decision on the Steam Traction Engine webpage at Page 2 6

3 2. How are instructors chosen? Perhaps it does not matter as long as the student can pass the tests. Instructors for the approved courses are not chosen by TSASK; therefore, TSASK cannot comment on how they are chosen. For TSASK exams, TSASK Inspectors or their designate will be invigilating the exams. 3. I feel the exam(s) should be able to be 'challenged' without a course through self study and/or prior knowledge. TSASK did look at that option but decided that the benefits of taking a course were too valuable and have elected to follow the requirements of ABSA who do require a course. The excerpt below was taken from ABSA s AB 240 Special Steam Powered Traction Engine Syllabus for clarity. 4.0 ELIGIBLE TO WRITE: To qualify to take a Special Steam powered Traction Engine Operator s Certificate of Competency examination, a candidate must have successfully completed a course satisfactory to the Administrator. 4. My licence does not expire until fall 2016 and am not at present aligned with any museum that has a traction engine, but do get the opportunity to operate an engine somewhere for a weekend. This weekend usually starts on a Wednesday, and includes all aspects of getting an engine ready: hand holes, filling with water, oiling, inspecting injectors, starting fire, driving, etc. I was contemplating going to Austin, Man. and doing their steam school in June. But if this is not going to gain me any future Sask. credit, I may not go. You will not be required to take the practical driving test until January 1 st, 2016 (next year). When your licence expires, you do not need to provide any form of proof of continuity. The fact you have to take the practical exam to renew your licence is proof enough of competency. As for the course, you will have to decide if the course is of benefit. Since you already hold a licence in Saskatchewan, the taking of an approved course is not necessary. However, if you fail to pass the competency exam more than three times (seems unlikely if you are operating at least once a year), then a course will be required in order to reapply for your licence. Also, taking the course in Manitoba would not have provided for any recognition by TSASK under the current program. Log Books and Time Verification 1. Who can sign off the hours for the new operators? The verification of time in your log book should be signed by another licensed Limited Power Engineer (traction) licence holder. If outside of Saskatchewan, a licensed Steam Traction Engine Operator is perfectly acceptable to verify the time. TSASK will recognize American Steam Traction Engine Operators as eligible to sign off hours. 2. Will hours outside of Saskatchewan count? TSASK will accept time for operations in other jurisdictions provided the time is verified in the log book. Steam Traction Engine Operators from other jurisdictions shall be able to verify time in log books for Saskatchewan operators. Again, TSASK will also recognize American Steam Traction Engine Operators. Fusible Plug 1. New plugs each year? Yes. TSASK will give the new fusible plug to the owner or their designate upon the successful completion of all the tests required that year. Typically, after a successful internal/external inspection, the TSASK Inspector will leave the fusible plug with the owner/operator in preparation for the hydro test. Page 3 6

4 2. How many heat cycles before ruined? The NBIC states that fusible plugs shall be changed after 500 hours of service if operational hours are tracked. If not, the fusible plug shall be changed every 3 calendar years. TSASK has opted to pay for the fusible plugs and has required that the plugs be changed annually thus minimizing having to track the time the fusible plug has been in service. 3. Vintage engines run only a few days a year, e.g. one show. Does that mean before another show the plug should to be changed? If the shows take place all in the same calendar year, there is no need to change the plug. The fusible plug will be changed annually at the regular inspection of TSASK. 4. Although not an engine owner, I see the TSASK proposal to be an unnecessary complication. As there are only 22 engines currently operating in Saskatchewan, they are readily accounted for by unit numbers rather than fusible plugs. The fusible plug will not be used to track the engines. The fusible plug will be change annually at TSASK s expense so that any Saskatchewan operating unit has a fusible plug issued by TSASK. Hydrostatic Test Requirements 1. While I'm not a resident of Saskatchewan, and this has no direct effect on me, I am happy to see what I consider a sign of progress. That said, I am hoping you can explain to me the reasoning behind what I consider two baffling rules. First, the requirement to operate at less than 100 PISG. While I grant you that an operating engine at virtually any pressure is better than one which is not allowed to operate, an arbitrary decision of a maximum of 100 PSIG seems to have rather little thought behind it. There are many engines, which, while in excess of 100 years old have more than adequate boiler & stay thicknesses to operate safely, well above that. TSASK can assure you that the 100 psig rating was not arbitrary. In Part 3 of the Steam Traction Engine Operations in Saskatchewan Final Findings and Path Forward paper (on the website), you will see a section called, Saskatchewan Hydrotest Rational, which explains how TSASK (actually the Boiler and Pressure Vessel Safety Unit which was TSASK when it was part of the Government) arrived at the 100 psig operating pressure and subsequent hydrotest pressure of 200 psig. The adoption of the 100 psig (690 kpa) was actually taken into the Saskatchewan Boiler and Pressure Vessel Legislation so it is part of the law for the province which is why TSASK weighed options around different operating pressures so carefully during this round of consultations. Having said that, TSASK is prepared to allow the operation of steam traction engines using the NBIC requirements for inspections which would mean the engine could exceed the 100 psig rating. TSASK will have to look at each application to exceed the 690 kpa limit on a case by case basis as it would require a special variance by the Chief Inspector to allow the engine to operate in Saskatchewan. 2. I can appreciate adopting such a policy for the sake of simplicity and to minimize the work on the inspection authority, but I would suggest that perhaps this could be amended to read, "All steam traction engines are limited to a maximum safety valve pressure of 100 psi until such time as the owner/operator can demonstrate through appropriate NDT and National Code calculations that the boiler is safe to operate at a higher pressure". I appreciate that there is much concern about old pressure vessels, I challenge you to find a case in the last 50 years where a properly maintained and inspected boiler, under the supervision of a competent operator has failed. Minimizing the work on the inspection authority did not enter into the decision to adopt 100 psig maximum operating pressure. The steam traction engine community experts at the time the decision was made agreed to the 100 psig operating pressure as they felt there was no need to operate higher as they could do all they wanted to do with their steam traction engine at that pressure. Further, the requirements of CSA B51 Clause (and also in adopted into legislation in Saskatchewan) is to slowly derate the engines every year after 20 years of operating service for lap seam riveted boilers. Saskatchewan s alternative to that derate is the 200 Page 4 6

5 psig hydrostatic test. Saskatchewan is very proud of its history with steam traction engines and wants to see the continued safe operation of these historic engines. As to changing the comment to read as you suggested, TSASK will certainly look at that as there is clarity to the statement. 3. In addition, such a restriction can actually add an element of danger for larger engines (>75BHP) because at lower pressures these heavier engines don't move as efficiently as they do at 125 PSIG and above. The risk of T/BDC center stall is greatly increased and the ability to emergency stop the engine significantly reduced. When the discussions on the 100 psig operating limit took place, this must not have been seen to be an issue for Saskatchewan. This is a mutually agreed to pressure from the steam traction engine community of the day. 4. My second point concerns your 200 PSIG hydrostatic test requirement. First, and most importantly, there is no guidance (that I could find) on your website on how to conduct a proper hydrostatic test, and I can see the very likely possibility of less experienced operators filling their boiler with cold water and immediately raising the pressure to 200 PSIG, putting extreme and unneeded stress on the pressure vessel, and then immediately relieving that pressure on completion of the test. Thankfully, hydrostatic tests have to be witnessed by a TSASK Inspector unless a Quality Control Program or Quality Management System has been registered with TSASK and then TSASK may delegate that responsibility to the company inspector(s). A registered procedure for doing a hydrotest has to be part of the manual documents. No one would be allowed to complete a hydrotest except by using an approved procedure by TSASK or by following the instructions of TSASK Inspectors. TSASK is in the process of building a second video which explains how TSASK does the hydrostatic test on a steam traction engine. Once there is an engine in the province ready for the test, TSASK will be going out and filming the procedure. The video will then be posted on the Steam Traction Engine page of the TSASK website. 5. As someone with 30+ years of experience in the field, I feel this policy is going to lead to the early demise of many engines, and be the cause of many unnecessary tube and stay replacements. The 200 psig hydrostatic test has been a requirement for over 20 years (I can only state how long I have been involved with TSASK. The actual length of time is likely longer). To my knowledge, TSASK has never caused a failure on an engine using the 200 psig requirement. That level of pressure during the test has been successfully used here for years. 6. Again, I wish to stress that while I'm very pleased to see thought being given to this, I feel that the arbitrary values and processes which have been decided on indicate a lack of informed input on the operation of antique boilers. Again, the restricted operating pressure of 100 psig was not arbitrary. And, TSASK did consult both with the Steam Traction Engine community as well as specific leaders such as the Western Development Museum (which operates around 10 steam traction engines in the province) and the Steam Association of Saskatchewan. TSASK also talked with two other jurisdictions Manitoba and Alberta in the development of the draft policy paper. Further, TSASK is very fortunate to have on staff one of the recognized steam traction engine community leaders who has been deeply involved in the steam traction engine community in Saskatchewan. In addition, TSASK also has other inspectors who are steam traction engine enthusiasts. TSASK has taken a hard look at all areas of this draft policy and have certainly considered the comments given by these stakeholders. TSASK has done nothing arbitrarily with regard to these beautiful historical engines. Page 5 6

6 General Comments 1. In reading the first line of your document, the first thing that struck me was your numerous references to The Steam Traction Industry. This is not an industry in any way. It is a HOBBY. There is no revenue generated by displaying a traction engine; therefore, it shouldn't be called an industry. I would doubt there is a single engine in Saskatchewan used in any kind of industry. In your document, I would like to see all the words industry changed to HOBBY. TSASK s used the following definition of industry when writing the paper: o an activity or domain in which a great deal of time or effort is expended. TSASK felt this fit the steam traction engine world quite well. However, in subsequent discussions with other steam traction engine enthusiasts, this word has not sat well with a few people. In Saskatchewan, the Western Development Museum s large collection of traction engines could not be called a hobby. The effort the WDM expends in keeping these wonderful pieces of Saskatchewan and Canadian history alive is exemplary. Thom Cholowski of the WDM(and Larry Postnikoff before him) sees the survival of the steam traction engines as part of his job and takes all necessary steps to keep them alive and well. So after talking with a few people, TSASK has moved to the word, community which both the SAS and WDM felt was a better choice. TSASK will be revising the final version of the paper with the word, community instead of industry before making public. 2. On a personal note. I started in the steam game over 50 years ago. Observations: o Some people become very good operators but are unable to use tools, e.g. change sight glass or install handhole plugs. o I always taught get someone qualified to fix it. o You are the pilot, not the mechanic. All great points. This is why public consultation is so important. The experience in this community is a wealth of knowledge. Not only does TSASK not want to lose the steam traction engines, TSASK does not want to lose the experience of the people operating them. Good advice as you mentor the new operators coming into the community! 3. I wouldn't allow an operator to run the Vulcan if he hadn't done so for 24 months without a trial run witnessed by a qualified operator. TSASK is really glad to hear that this is your position. TSASK feels the same which is why the continuity requirement. In discussions with both the WDM and the SAS, most owners would require an operator to get checked out thoroughly under the guidance of a knowledgeable operator before allowing the new person to operate the engine. And anyone who has not operated for more than 24 months needs to have a refresher for sure. Again, that is why TSASK required that continuity be demonstrated in the log books. 4. First off, let me say that I am very pleased to see another province adopting a somewhat reasonable attitude toward antique power. Thank you very much. TSASK has been working on the paper for close to a year and have made some good progress in developing the new draft policies. TSASK has done a lot of consultations and the results are in line with what TSASK feels were the biggest issues in Saskatchewan. TSASK also worked with Alberta and Manitoba to make sure that the three jurisdictions were harmonizing as much as could be reasonably done. Ideally, TSASK would like to see reciprocity between Manitoba, Saskatchewan and Alberta for both the operating licence for the engine and for the Steam Traction Engine Operators. Those discussions will carry forward. Eventually, the intention is to talk with BC, too. Page 6 6

Steam Traction Engine Operations in Saskatchewan Final Findings and Path Forward

Steam Traction Engine Operations in Saskatchewan Final Findings and Path Forward In the spring of 2014, TSASK participated in three public forums with the Steam Traction Engine Industry to discuss their