CSA Approval on RVs brought into Canada by dealers

[forest]

But you are failing to realize that the MTO has no jusridiction when it come to 110v systems in an RV. That is strictly the jurisdiction of the Ontario Electrical Code, which the ESA enforces. Stating that the MTO accepts NFPA is not true. They don't care how it is wired for the 110v systems. The MTO cares that the vehicle portion meets their standards.
Please show me evidence where the OHTA refers to anything to do with CSA or RVIA.
QUOTE "The law which is the Ontario Highway Traffic Act accepts either CSA Z240 or RVIA NFPA 1192 which are RV specific".

As far as them checking compliance when registering the vehicle for license plates. What exactly do they do to check for compliance. Because all I have ever seen them do is take the VIN and put it onto an Ontario ownership.

Good example of the confusion as it relates to the same situation in BC.
http://www.th.gov.bc.ca/cvse/ctpm/Co...circ_09-10.pdf

[Murf2u]

We're kind of in Apples & Oranges territory here.

MTO & the HTA are only concerned with the vehicle portion of the equation.

Once it has 120 volt AC system on board and a plug, you're in ESA and Code jurisdiction.

The problem is the manner in which it crosses the border, if I bring in a non-compliant RV it doesn't matter, UNTIL I sell it. If it's imported for resale, it MUST meet code and be inspected and snickered as such by the ESA.

The chances of getting caught are slim, but very possible. When I insured my m/h the insurance company (agent) needed to physically see the unit to verify it was stickered as compliant. A friend did a bus conversion, his ins. co. also wanted to see the ESA approval before they'd insure it.

[BCinTOR]

Hi Myredracer,

Dealers in Ontario are stating that ESA and TSSA (propane) codes have to be complied with to service American units for liability reasons. But there is no government source to clarify if this is required beyond the RVIA certification required by OHTA.

Originally Posted by myredracer

I thought from I've read recently that it is the LP system and components that are the biggest (or only?) real concern. I read a few months back in the RV Times magazine (tech. talk section written by an RV dealer) that in some cases an RV needs a lot of reworking of LP stuff. Maybe this varies from province to province?

[BCinTOR]

Please read the shared doc: https://docs.google.com/document/d/1EwVoFluNVHD9w1g1CoCCXfNpaEjk4eW3hzlv8T7MhcQ/edit?usp=sharing

The BC clarification letter from 2009 is helpful. Note that Ontario changed the OHTA in 2011 to accept either CSA or RVIA. I've added the BC letter to the shared doc.

Has any followup clarification been issued since then? The BC letter says "A cross-ministry process is underway to look at providing comprehensive information related to the purchase and importation of recreational vehicles for both consumers and dealers"

OHTA does specifically quote RVIA NFPA 1192:

"4.1 ...Canadian Standards Association Standard Z240 RV or to United States Recreation Vehicle Industry Association standard NFPA 1192 or ANSI A119.2."
source:
http://www.ontariocanada.com/registry/view.do?postingId=6402
http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_940340_e.htm
The Highway Traffic Act in Ontario was changed in June 2011 to accept both standards: www.e-laws.gov.on.ca/Download/elaws_src_regs_r11291_e.doc
Alberta made the change back in 2009: http://rvia.org/?ESID=preleases&PRID=169&SR=201
Further re: ESA:

"The Canadian Electrical Code does not apply to vehicles, systems operated by an electrical or communications utility, railway systems, aircraft or ships; since these installations are already regulated by separate documents."Source: http://en.wikipedia.org/wiki/Canadian_Electrical_Code

CAN/CSA-B149.1-05 doesn't not apply to RV or mobile homes unless made permanent:

"4.8.1 The installation of gas-burning appliances and supply piping in mobile homes shall be in accordance with CAN/CSA-Z240.4.1.

4.8.2 When a vehicle ceases to be used as a mobile home or recreational vehicle and is placed at a location in a permanent fixed manner, the system shall comply with all applicable requirements of this Code."

Source: http://www.csagroup.org/documents/co...149_1S1_EN.pdf

Originally Posted by forest

But you are failing to realize that the MTO has no jusridiction when it come to 110v systems in an RV. That is strictly the jurisdiction of the Ontario Electrical Code, which the ESA enforces. Stating that the MTO accepts NFPA is not true. They don't care how it is wired for the 110v systems. The MTO cares that the vehicle portion meets their standards.
Please show me evidence where the OHTA refers to anything to do with CSA or RVIA.
QUOTE "The law which is the Ontario Highway Traffic Act accepts either CSA Z240 or RVIA NFPA 1192 which are RV specific".

As far as them checking compliance when registering the vehicle for license plates. What exactly do they do to check for compliance. Because all I have ever seen them do is take the VIN and put it onto an Ontario ownership.

Good example of the confusion as it relates to the same situation in BC.
http://www.th.gov.bc.ca/cvse/ctpm/Co...circ_09-10.pdf

[Murf2u]

Originally Posted by BCinTOR

Further re: ESA:

"The Canadian Electrical Code does not apply to vehicles, systems operated by an electrical or communications utility, railway systems, aircraft or ships; since these installations are already regulated by separate documents.

Ok, now were really stretching to try to deflect away from the point at hand.

The Canadian Electrical Code is a separate parallel code but is Federal, not Provincial. Likewise there is a Federal Building Code as well as Provincial ones.

To say the CEC does not apply is correct, BUT, it does NOT mean that the Provincial statute doesn't apply either.

The Canadian Building Code doesn't apply to a house in Ontario, but just try to build without complying with the Ontario Building Code.

If it is imported for resale, and it's designed to be plugged into the electrical grid in Ontario, it MUST be either certified as compliant, or inspected by the ESA.

[BCinTOR]

Certainly ESA is the Ontario version of federal CEC. The wikipedia quote simply states that CEC/ESA does not apply to vehicles which is true.

We're not in agreement that ESA applies to RV's legally imported with RVIA certifications accepted by Transport Canada, OHTA, and insurance companies.

You, like the Ontario dealers, assert that ESA is required but have no government source to clarify or back this up and it's an opinion that doesn't align with Transport Canada or OHTA.

Certainly this is my opinion too and readers will have to decide for themselves if this is only a dealer created issue.


Other related details:

RVIA NFPA 1192 has specific sections for electrical and propane just like CSA Z240 does.

Ontario Highway Traffic Act (OHTA) accepts CSA Z240 or RVIA NFPA 1192 which I’ve provided the relevant links for in the prior post.

If your unit is following CSA standards the precedence is Transport Canada Motor Vehicle Safety Regulations (MVSR), then CSA Z240 which also covers electrical requirements, then if not covered by CSA Z240 then CEC.
Source:http://www.scc.ca/en/standardsdb/standards/7249
Source:http://www.scc.ca/en/standardsdb/standards/7244

Originally Posted by Murf2u

Once it has 120 volt AC system on board and a plug, you're in ESA and Code jurisdiction.

Originally Posted by Murf2u

Ok, now were really stretching to try to deflect away from the point at hand.

The Canadian Electrical Code is a separate parallel code but is Federal, not Provincial. Likewise there is a Federal Building Code as well as Provincial ones.

To say the CEC does not apply is correct, BUT, it does NOT mean that the Provincial statute doesn't apply either.

The Canadian Building Code doesn't apply to a house in Ontario, but just try to build without complying with the Ontario Building Code.

If it is imported for resale, and it's designed to be plugged into the electrical grid in Ontario, it MUST be either certified as compliant, or inspected by the ESA.

[Murf2u]

Originally Posted by BCinTOR

You, like the Ontario dealers, assert that ESA is required but have no government source to clarify or back this up and it's an opinion that doesn't align with Transport Canada or OHTA. Certainly this is my opinion too and readers will have to decide for themselves if this is only a dealer created issue. Other related details: RVIA NFPA 1192 has specific sections for electrical and propane just like CSA Z240 does. Ontario Highway Traffic Act (OHTA) accepts CSA Z240 or RVIA NFPA 1192 which I’ve provided the relevant links for in the prior post.

Again we're taking compliance with ONE statute as meaning you comply with ALL of them. That is NOT the case.

The OHTA covers the legality of a vehicle going down the road. It does nothing to determine your compliance with the electrical code.

Every Provincial Electrical Code I've seen requires compliance with CSA Z240, compliance with RVIA NFPA 1192 is NOT good enough. The 1192 code doesn't cover all of the items CSA Z240 does, nor does it have the same requirements.

If you (or anyone else) don't believe me you can contact the ESA at 1-800-559-5356 and ask to speak to someone in the ESA field evaluation Services Group and ask them if an inspection is required.

[BCinTOR]

I just got off the phone with a field technician at ESAFE which is the 800 number you provided.

If you ask him, is an inspection from ESAFE required on an RV that doesn't have a CSA sticker the answer is yes.

If you ask him if RVIA NFPA 1192 is accepted since it is recognized by Transport Canada and OHTA as an alternative to CSA Z240 he'll refer you up the chain to ESA to ask for clarification from the regulator as ESAFE are only the inspectors and not the regulator.

Still no clarity.

Note that the cost of ESAFE inspection is $139/hour if a buyer chooses to get it done on their own: http://www.esasafe.com/assets/files/esasafe/pdf/2013_ESA_Fee_Schedule.pdf

Originally Posted by Murf2u

If you (or anyone else) don't believe me you can contact the ESA at 1-800-559-5356 and ask to speak to someone in the ESA field evaluation Services Group and ask them if an inspection is required.

[BCinTOR]

These two articles speak about the in progress harmonization of CSA Z240 with RVIA NFPA 1192. Certainly they must cover the same items or this wouldn't be possible.
RV Standards | RV Business

Originally Posted by Murf2u

Every Provincial Electrical Code I've seen requires compliance with CSA Z240, compliance with RVIA NFPA 1192 is NOT good enough. The 1192 code doesn't cover all of the items CSA Z240 does, nor does it have the same requirements.

[CGPRV]

Hello everyone. I felt I needed to chime in, if for no other reason than to add more confusion on the matter. I can only speak from first hand experience, so anything posted here reflects the facts surrounding that.

I imported my first RV 4.5 years ago and since have imported many more. Before importing the first we called ESA and the RIV and, as you BCinTO, got the run around to start but finally got some answers.

We see and hear a lot of statements made with no evidence to back them up, in absence of evidence either way, there is, as you say BCinTO, more confusion.

Looks like you already called ESA and got the run around, as we did, but in the end they told us that once our RIV cert (yes it is for the MTO/HTA) was completed on an RVIA compliant unit that NOBODY could say that it was not legal for use in Canada on the roads and use as an RV. We have all of our notes and references from those conversations still in a file as well. We even called the manufacturer of the RV.

Now obviously things have changed over the past 4 years but if anything (in my opinion) changes are for the better for the cross border RV shopping consumer, especially with the harmonization that BCinTO mentioned above. But still confusion will exist until we get the correct authority to officially comment on it, or the legislation/wordings become clear without ambiguity.

[Murf2u]

Originally Posted by BCinTOR

I just got off the phone with a field technician at ESAFE which is the 800 number you provided. If you ask him, is an inspection from ESAFE required on an RV that doesn't have a CSA sticker the answer is yes.

If you ask him if RVIA NFPA 1192 is accepted since it is recognized by Transport Canada and OHTA as an alternative to CSA Z240 he'll refer you up the chain to ESA to ask for clarification from the regulator as ESAFE are only the inspectors and not the regulator.

Ok, I'm going to say it again. Apples and Pineapples are NOT the same thing. You need to be healthy to have a drivers licence, but your doctor can't give you a drivers licence, and the DOT can't give you a medical.

You stated it, the ESA said if the RV doesn't have a CSA sticker it needs an inspection. Period. Full stop.

They're NOT experts beyond that. They probably don't even know what the RVIA NFPA 1192 is, let alone if it's sufficient.

[CGPRV]

...I have asked this of many many people, a number of dealers and various Gov't agency reps over the years, prove that statement please. Please give us all documented (written) proof from generated by the appropriate government authority that what you say is correct. If you can we'd all be able to share it with everyone else, not to mention we'd really appreciate the waters becoming less cloudy on this issue.

[bobmac]

BCinTOR

I think you have done an outstanding job in compiling and summarizing the key issues with standards compliance. I agree 100% with your conclusions.
I have imported two Winnebago products since 2010. Winn produces a "parts catalog" for every model they make detailing all component parts including the different parts when units were built to CSA standards. The differences were trivial and included things like a different propane swivel and different plastic P traps - hardly significant. In total there were less than 10 items different in a 40ft Class A MH. We are fortunate that the CSA accepted the RVIA standard as it means lower cost for units exported here.
One has to remember that the CSA and ESA used to be selfishly motivated to preserve their own jobs with slightly different but unique to Canada standards that added nothing in value or enhanced safety over equivalent US standards. It was a case of the monkeys guarding the peanut jar.I have dealt with Cdn dealers who insist on ESA approvals and even used to have CSA built vehicles inspected by ESA. hopefully, those days are over.
Thanks for your contribution to setting the record straight on the standards compliance.

[Murf2u]

Originally Posted by bobmac

We are fortunate that the CSA accepted the RVIA standard as it means lower cost for units exported here.

Thanks for your contribution to setting the record straight on the standards compliance.

Actually, it's more muddled, not clearer.

If you went back and actually read the articles linked to you'd see that it clearly states that there were 100's (in total) of amendments made to the RVIA standards in order for them to be equalized. In fact, one of the key paragraphs was actually posted above, one lots of folks seemed to have glossed over;

"This includes RVIA manufacturer members located in Canada producing units for the Canadian market. In the Canadian provinces that require RVs to be built to the Z240 Standard, manufacturers must meet the NFPA 1192 Standard and apply the appropriate RVIA seal as an RVIA membership requirement as well as meet the Z240 Standard and apply the appropriate Z240 seal. Please note that as a result of these changes, the Canadian RV Association will no longer be offering a CRVA seal. “

Note the wording "as well as meet the Z240 Standard and apply the appropriate Z240 seal.".

The confusion seems to be based on the rather liberal provisions we in Canada enjoy, that is the right to import a non-compliant product for PERSONAL USE.

I can import a left-hand drive car that does not comply to crash test standards, etc., for example. I cannot however LEGALLY import it for resale, or even sell it subsequent to my importation. However, once I have an Ontario ownership, there's nothing in the MTO system to stop me transferring it.

In order to resell it however I must, by law, ensure it complies with all required items.