Sil-Fos

Well it seems that the TSSA is the correct organization to say if you are complying with Ontario's safety standards. I would expect that you have or can get a reasonable grace period so that you can meet these new standards. I am surprised that you're told that you must use a particular brand product (Sil-Fos) for your welds, brazes, and solders instead of an approved grade that many manufacturers can produce. I am also surprised that your existing infra-structure is not grandfathered as acceptable but new plumbing and repairs must be assembled to meet this new standard.

Review the documentation you've been given from the inspector very carefully. Remember that the verbal communication by the inspector, while often helpful, can be misunderstood or misquoted. It is the written report that is binding.

This sounds like a royal pain. If preserving the existing lines, the joints will need to be unsoldered, cleaned, and resoldered with Sil-Fos or equal. It might be easier to do all new runs, or even to convert to HDPE.

How are the extant air lines joined at present?

Over a beer or six, ask the TSAA inspector to substantiate his interpretation and ruling with regulatory citations (please).

I'm not sure what TSSA is but it sounds like our elf & safety mob,or factory safety inspectors, The question is is this an existing installation if it is I can't see how they have the authority to make you change the installation, I think I would contact someone high up in TSSA and ask them to clarify this instruction it could be that the inspector doesn't understand the regs and how to apply them, also there is the fact that he is telling you to use a specific product which I doubt is legal.

Once again we're working with sparse information and only know one perspective on this inspection result.

First, personnel safety inspection does not care how long an installation has been operational for a good reason. An installation technique from the past may have been found to fail catastrophically only after decades of operation. There maybe unknown factors of the previous catastrophic failures that fooled installers for years that this was a sound technique for installation. A discovered unsafe installation regardless of it being a previously acceptable installation technique or just this particular poor installation has yet to kill anyone, are unacceptable excuses to ignore a safety violation.

At the same time, a safety inspection team is not infallible. I'm certain that there is a safety violation dispute procedure in Ontario. To challenge a violation one must have independant access to the standard that the OP is apparently not meeting. The written report should name the standards that the safety team is referencing. In the case of legacy installations I expect that waivers maybe granted if sufficient reasoning and data is presented.

I am in the HVAC trade and the TSSA is the Judge ,Jury and Executioner controlling body. The should not tell you to retrofit your air lines unless you are doing maijor changes. As for "Sil-Foss", it is a generic name now. If you have to use it; use the 15% silver. More money less problems. Note: it is totally incompatabile with any tin/ lead based solders. They the then may turn around and demand a brazing certificate. Bigger problems

Question the ruling and ask where in the book the ruling is or is this guy on a power trip.

Here,Here,Rhubarb rhubarb.

Bazzer

Some Inspectors have to justify there position by quoting obscure regulations and or nit picking, It would be fair to get a clarification from the department concerned. In retrospect silver soldered copper lines are superior to soft solder and as far as I am concerned easier to do than soft solder and can usually be sure that there will be no leaks,also mechanicaly superior to soft solder. I would certainly recommend all new installation be done this way.

Thanks for all the informative posts we are a printing company that has been conventionally soldering with a lead tin based solder for the past 23 years and never have had a air line break at the join we operate web presses and binder equipment my guess is that we have at least a thousand connections within our plant. A combined effort between our health and safety officer and our purchasing department identified this issue in a pre-start inspection on a poly bag machine ( inserts magazines into poly-bags for mailing ) by a independent outside contracting firm we hired. The TTSA became involved as the machine without CSA or any international approval required a "special inspection to ensure it met Canadian Standardards" This is the item that opened up this can of worms ( for lack of a better term ) we now have been advised that we need a staff member on site with a brazing certificate and the cost to register and test this person will cost us around 4K. I do not think that we will require to retroactivelly re-work our existing air lines. The term Sil-Fos was mentoned and I am going to ask for what act this item falls under. A conference call last week suggested that any line in excess of 15 PSI required Sil-Fos I think that the inspector is for some reason quoting the requirements for a line that carries "steam" as this I understand is a requirement under the steam and boilers operational procedure. How this could have any reference to a line that only carries compressed air the TSSA will have to explain. But being a Government agency that reports to no one other than itself this may be a challenge.

If this is something that is going to be enforced without cause I think that the burden on the small manufacture is something that they at this time do not need to worry about.

In my case , Our company would be able to absorb the additional costs and adminsitrative burden as we are large enough to do so but .... that still does not make it fair justified or under the laws of fundamental justice right.

Lead-tin solder might weaken or melt in steam service, and it can leach lead into otherwise potable water. In those cases, it should be replaced. I'm not sure about air lines, where strength would be the main issue.

we only carry air for indistrial use in our lines

cheers

Joint connections are rated for pressure and temperature, along with the media being contained in the system. While a brazed joint is superior to a soft soldered joint, under ambient temperatures, I believe the soft solder is adequate for pressures and temperatures generally encountered within a plant environment. I would be carefule at the compressor discharge, since I have seen compressed air temps near 100C. Soft solder capabilities would begin to get marginal with compressed air pressure at those temperatures. If you can confirm the soft soldered joints are only after the air dryers and aftercoolers, you should be able to make an arguement to have the current installation grandfathered. Good luck.

Keep in mind that my advice is from south of the border, and is free. It is therefore probably worth every thing you paid for it! Use with caution!

How many times do you have to re make copper lines which require re soldering? very few I would think. It would be more convenient and cheaper to call in a gas fitter to do do one or two fittings rather than going to the expense of training a staff member who might leave the job due to unforeseen circumstances.

Finally got it Sil-Fos is silver solder, for air lines I can see no need to change at all, Iv'e had soldered air lines running at 150psi for the past 20 years without one failer and no leaks, If this were water or steam in the food industry then yes silver solder is necessary.

Bazzer.

Just remember the TSSA inspector will have the final word on pass or not pass at inspection time.

Instead of 95/5 (tin & lead) if the inspector will allow use Stay-Brite #8 soft solder. We have used that for many years in the refrigeration trade under high and low pressures and you could clean and blend the Stay-Brite into the existing Soft solder joints for added strength if the inspector requires.

Sil-Foss / Harris 15% will last longer than most any other brazed joints, though expensive now at $86.00 for a 20 stick pac. Luckily it is only 1/2" lines so one stick (18") should get you through 7 - 10 joints with an experienced brazer.

We once had a TSSA audit. He and I went around to several instalations to confirm adhearance to the rules. There were two new identical roof top HVAC units side by side from a well known manufacturer. The serial numbers were consecutive. One label had the CSA logo and the other one did not. The printer at the factory glitched.

The TSSA rep demanded that the unit be removed and sent back to the factory for inspection and relabling. Absoulot stupidity.

Called the manufacfturer Rep and the CSA. Together they placed a new label on the unit, took a picture and told the TSSA rep to bugger off.

That idiot no longer works for the TSSA.

As for Brazing: not to long ago we did a large AC job with lots of piping. As one of the certified, I did the piping plan, got the permit and when the inspector from the TSSA came to sign off on the job. I had to explain the rules to him, as he had never did a brazing inspection, nor was he taught how to.

Training the enemy....

Unfortunately yes.

But we still needed that approval from the TSSA in order to do the start up and satisfy the customer and conform to code and regs.

It sounds like the Rossm knows the issues and the course of action that he should take.

When will you start being a thorn in the side of the TSAA? Don't rollover and let us know how you get on. Good luck

Of course. Sil-Fos is a generic and proper name of a common brazing alloy. In order to help you further, I need to know which Ontario. Notwithstanding, look up Med-Gas and NFPA Code 99 requirements, as this would be similar.

Ontario Canada

If you can believe it they are quoting the Ontario Regulation 220/01 as the Act that covers boilers and pressure vessels. As I suspected...

Read the act and it Interpretation, under code 223/01 the movement of air only was not applied to the "code adoption document" I would ask that the inspector be reviewed by his supervisor.

I agree, good plan, many inspectors are not that knowledgable.

Sometimes they try to talk you into a "brazing certificate" or certification this open up a new can of worms as then you give them the authority to inspect on a monthly basis and being like most government employees that have to justify positions and budgets you can then expect a visit from them like clockwork.

Good answer, sounds like you know the regs and correct interprtation.

Thank you. I noticed you mentioned "...the media being contained..." Too many people forget that! I am constantly correcting people on R410a. This further relates to your commenting on the compressor discharge.

DRFREON