James Hogarth, Business Manager Ontario Pipe Trades Council 400 Dundas St. E., Suite 206 Whitby, ON L1N 0K1

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1 James Hogarth, Business Manager Ontario Pipe Trades Council 400 Dundas St. E., Suite 206 Whitby, ON L1N 0K1 Ontario College of Trades Board of Governors 700 Bay Street, Suite 1700 Toronto, ON M5G 1Z6 Dear Board of Governors: On behalf of the Ontario Pipe Trades Council, I am writing to express my support for the classification review of Sprinkler and Fire Protection Installers (sprinkler fitters). We believe that the trade should be made compulsory. Sprinkler fitters perform complex and physically demanding work that requires considerable training and expertise in order to do it correctly. People s lives depend on sprinkler systems being properly installed and cared for, and we believe that ensuring all sprinkler fitters are trained and certified is a small step that will go a long way towards protecting public safety. The sprinkler fitting industry has changed dramatically in recent years due to advances in technology and improvements in fire safety legislation. Today there are a variety of different types of sprinkler systems on the market, and dozens of rules and regulations governing their use. This has made the job more complex than it has ever been before. We believe it is high time that the requirements for working in the trade reflect the industry s new realities. This submission will discuss the trade in detail, and will explain some of the reasons as to why OPTC believes it should be mandatory for those working as sprinkler fitters to be certified. Thank you for considering our submission. Regards, James Hogarth Business Manager Ontario Pipe Trades Council

2 ABOUT THE ONTARIO PIPE TRADES COUNCIL The Ontario Pipe Trades Council (OPTC) is a member of the United Association of Journeymen and Apprentices of the Plumbing and Pipefitting Industry of the United States and Canada. First designated as an Employer Bargaining Agency by the Ministry of Labour on April 12 th 1978, the OPTC today represents 16 local unions in Ontario and has a membership base of approximately 22,000 journeypersons and apprentices. The unions represented by the OPTC include: Local 46 (Scarborough) Local 67 (Hamilton) Local 71 (Ottawa 1) Local 401 (Bowmanville) Local 527 (Waterloo) Local 628 (Thunder Bay) Local 800 (Sudbury) Local 853 (Markham) Local 663 (Sarnia) Local 787 (Brampton) As an organization, the OPTC works to promote the benefits and interests of the pipe trades in Ontario. We strive to educate legislators and the public about the many technical, commercial and environmental advantages our members bring to the construction industry. We advocate for safe working conditions, fair wages and benefits, public health and safety and journeyperson and apprenticeship training in both the public and private sectors. Training in particular is an integral part of the OPTC s mission. In addition to helping journeypersons upgrade their skills, the OPTC delivers high-quality apprenticeship training at its 17 state-of-the-art training centres for a number of trades, including sprinkler fitting. Our apprentices receive rigorous health, safety and environmental training that goes well beyond what is currently required by law. The OPTC invests more than $100 million in training each year to ensure that the knowledge and expertise of our members is passed on to tomorrow s generation of young professionals. 1

3 ABOUT THE TRADE Sprinkler fitters install and maintain high- and low-pressure piping, equipment and devices to supply fire protection systems with water, foam, carbon dioxide and other materials in residential, institutional, commercial and industrial buildings. Sprinkler fitters must perform their work in accordance with relevant legislation including the Building Code and the Fire Code. There are many hazards associated with the work sprinkler fitters perform. When unqualified sprinkler fitters work, they pose a considerable danger not only to the public, but to themselves as well. Some of the hazards that sprinkler fitters are likely to encounter on the job include: Dangers associated with lifting heavy pipes, standing for extended periods of time, and working in confined spaces; Dangers associated with using chemical solvents, adhesives and epoxies; and Dangers associated with exposure to welding fumes, heavy metals and chlorinated compounds during welding or torch cutting. It should also be noted that many of the older buildings that require retrofitting contain additional hazards that sprinkler fitters must be properly trained to deal with, including exposure to asbestos, lead and countless other chemicals and contaminants. 1 People who operate in the industry without formal training are likely to be unaware of these risks, and may contract serious health problems in their lifetime as a direct result. Compulsory certification will ensure that all sprinkler fitters have a thorough understanding of the risks they face and the proper ways to deal with them. 1 UA Local 853 and CASA Re: Sprinkler Fitter and Fire Protection Installer Ratio Review Submission, page 9 2

4 A GROWING INDUSTRY The importance and effectiveness of sprinkler systems as a form of defence against fires cannot be overstated. Studies have shown that a single sprinkler head can extinguish a typical residential fire in less than four minutes. 2 In addition to the proven ability of a sprinkler system to save lives, most studies suggest that properly functioning sprinkler systems reduce property damage by anywhere from 70-85% compared to residences without sprinklers, which is why most insurance companies offer discounts on premiums for buildings where sprinkler systems are installed. 3 Growing awareness about the effectiveness of sprinkler systems is serving as a catalyst for industry growth in Ontario. In addition to existing legislation that requires sprinkler systems be present in all industrial and high-rise residential buildings, the Government of Ontario recently made changes to the Fire Code requiring all retirement homes to be retrofitted with sprinkler systems within the next five years. Additionally, many organizations and groups are lobbying to make sprinkler systems mandatory in all low- and mid-rise residential buildings, and some construction companies have taken it upon themselves to automatically incorporate sprinkler systems into their new development projects. 4 While this increased adoption of sprinkler systems should be lauded, we must be careful to ensure that only those who are competent and certified are installing and maintaining them. Without enforcing compulsory certification, unqualified or inept people may try to take advantage of this new demand, endangering the lives they are meant to protect in the process. In the past, improper sprinkler

5 installation of automatic sprinkler systems has caused the following problems in buildings in the province: Improper maintenance of the sprinkler system in an Ottawa nursing home caused the system to freeze, and then flood the facility. The system was turned off and left out of service for the winter; Sprinkler heads at the Peterborough Sports Complex were installed above a suspended ceiling, providing no protection below the ceiling; Toronto office workers were put at risk when sprinkler heads were installed in the ceiling, but no pipes were connected to the heads; and A dry system in Kingston was filled with anti-freeze, a poisonous substance that threatened the safety of the people of the building and had the potential to contaminate the public water supply. 5 SPRINKLER SYSTEMS AND THE ENVIRONMENT As previously stated, one of OPTC s goals is to promote the environmental benefits of the pipe trades. Properly installed sprinkler systems are an effective tool for reducing the negative environmental impact of fires. Research conducted by insurance company FM Global in partnership with the Home Fire Sprinkler Coalition found that sprinkler systems reduced the greenhouse gases emitted from fires by 98%. As well, the researchers observed that in an emergency situation, sprinkler systems had a significant impact on water conservation. Their study found that the amount of water needed to fight a fire could be cut by upwards of 90% when a functioning sprinkler system was present. Researchers also 5 UA Local 853 and CASA Re: Sprinkler Fitter and Fire Protection Installer Ratio Review Submission, page 6. 4

6 noted that sprinklers significantly cut down on pollution by reducing both wastewater runoff and burned materials that end up in landfills following fires. 6 Sprinkler fitters who are not properly trained and certified are unlikely to be cognizant of the environmental aspect of their job, and will not know how to maximize their opportunities to protect the environment when they work. Through certification, we can make sure that all sprinkler fitters receive green training and understand that environmental protection is an essential part of their job. TECHNOLOGY HAS INCREASED THE COMPLEXITY OF THE TRADE Though it may have been permissible for sprinkler fitters to work uncertified many years ago, that time has long since passed. There are few trades that have been as radically affected by technological change over the years as that of the sprinkler fitter. Today there are a variety of sprinkler systems on the market, such as water based and wet systems, dry systems, deluge systems, pre-action systems and early suppression fast response. 7 However, in total, there are more than 1,000 types of sprinklers heads on the market, each with unique design requirements. 8 All of these systems are complex and unique, and sprinkler fitters must have a thorough understanding of each in order to do their job effectively. Advances in industry technologies have also resulted in the need for sprinkler fitters to be highly skilled with computers. Many sprinkler systems today are controlled electronically, meaning sprinkler fitters must be computer-literate in order to work UA Local 853 and CASA Re: Sprinkler Fitter and Fire Protection Installer Ratio Review Submission, page 3 8 Provincial Advisory Committee (2003). Recommendation for Compulsory Trade Status: Sprinkler & Fire Protection Installer page 4. 5

7 Certification will provide sprinkler fitters with evolving training and will help them stay ahead of the curve with regards to new processes and technologies affecting their industry. MAKING THE SWITCH TO COMPULSORY CERTIFICATION Those who have opposed compulsory certification in the past have argued that the cost associated with bringing in a certified sprinkler fitter to every job site (as opposed to using someone who will work at a price set by the builder) constitutes an undue financial burden. However, even if a minimal price increase occurs, it is a small price to pay when you think of the expertise, accountability and quality that comes with using certified tradespersons. Also, it s important to remember the most important gain from certification the health and safety of Ontario citizens. The price that has been estimated for compulsory installation is $1 to $2 per square foot, representing approximately 1% of the total building costs. 9 Quite frankly, cost increases on budgetary items that represent roughly 1% of the total building budget should not be a concern for homebuilders if it is in an attempt to protect the lives of the general public. In terms of assisting uncertified people currently working as sprinkler fitters get trained and certified, the transition process should not be difficult if they have another Certificate of Qualification, such as a certified plumber. The Government of Ontario has set a number of precedents to transition noncertified workers, including recognition of hours worked and a demonstration of skills testing. Furthermore, a number of other provinces have made the right decision to grant compulsory certification for Sprinkler and Fire Protection Installers. Manitoba, Quebec, New Brunswick and Nova 9 Provincial Advisory Committee (2003). Recommendation for Compulsory Trade Status: Sprinkler & Fire Protection Installer page 4. 6

8 Scotia have all ensured compulsory certification and may be used as an additional resource when creating the proper process for transition. CONCLUSION The sprinkler fitting industry is at a crossroads in Ontario. The combination of swelling demand and increasingly complex technology has created a situation where the province will soon have more people performing a task that they are less qualified than ever before to do. The trade is already compulsory in other jurisdictions such as Manitoba, New Brunswick, Nova Scotia and Quebec, and we believe it is time for Ontario to prove to its residents that it is just as committed as these other provinces to keeping them safe. In addition to protecting the public, compulsory certification will help protect people working in the trade, as well as the environment. Sprinkler fitters must perform physically demanding work using a variety of tools that are dangerous in the hands of untrained people. And outside of the dangers they pose to themselves and others, uncertified sprinkler fitters can negatively affect the environment. When sprinklers don t work, it results in greenhouse gas emissions, wasted water, pollution runoff and increased garbage in our landfills. Certification will ensure that all sprinkler fitters in Ontario understand the environmental aspect of their job. Technology has drastically changed the sprinkler fitting industry. While it may have been acceptable in the past for someone with a basic knowledge of piping systems to perform the work of a sprinkler fitter, it is certainly no longer the case today. The industry has become highly specialized and there are now many different sprinkler systems on the market. The increasing use of computers and electronics in sprinkler systems has only added to their complexity. The legislative requirements for working in other 7

9 trades have changed to reflect new technologies, and we believe sprinkler fitters should be treated the same. While it s true that the labour costs associated with installing sprinkler systems may rise as a result of the switch to compulsory, the reality is that any change is likely to be minimal, and the cost increase is worth it if saves even one life. When sprinkler systems fail to act or act incorrectly, it blemishes our industry and dissuades people from using a device that has otherwise been proven to save lives. Certification will prevent unnecessary mistakes, bring accountability to our industry, and ensure that Ontario remains a leader in protecting the safety of its citizens. 8

Establishing Sprinkler Fitting as a Compulsory Trade

Establishing Sprinkler Fitting as a Compulsory Trade Introduction All mechanical trades in Ontario are currently compulsory certified except for sprinkler and fire protection installers it is quite literally