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2004-10-04 Communiqué - Amendments to E-26
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Measurement Canada Response to Stakeholder Feedback on the implementation of Bulletin E-26, in PDF format, 94 KB
To view the Bulletin E-26 (rev.2)
Bulletin E-26 "Reverification Periods for Electricity Meters and Metering Installations" was implemented in November 2003 to establish the policies and principles by which reverification periods for meters shall be initially established as well as lengthened, shortened, or extended, as objective evidence warrants. Under the Electricity and Gas Inspection Act, the Director has the authority to determine meter reverification periods.
Issue
In setting out these policies and principles, the bulletin also addressed a significant discrepancy that became more apparent in recent practice. In the past, no distinction was made in assigning a reverification period to a new or used meter of the same type, based ostensibly on the assumption that a used meter would be suitably restored to the state of a new meter (i.e., through a renewal process). However, it was learned that in general, the reservicing that was actually being applied to used meters was inconsistent and may not have been based on meter manufacturer information.
The notion that any used device or appliance should be considered as reliable as a new device or appliance is simply not consistent with common thinking in the area of performance reliability. As a practical reference, no vendor of used devices or appliances offers time-related performance warranties that are equivalent to those offered to new devices. In the case of used meters, the fact that the device is operating or can be physically adjusted (calibrated) to operate within performance specification requirements at a particular moment in time, without any future real time performance monitoring or quality level determination, is simply not sufficient to support the reverification period extensions that were being provided.
In January of this year, Measurement Canada issued a communiqué and a revision to Bulletin E-26 in order to delay the implementation of section 5.3.2 and to solicit feedback from industry on alternatives that would address the Agency’s concerns.
Feedback Received by Measurement Canada
Some meter owners have acknowledged the concerns raised by Measurement Canada and are very interested in determining what steps they may need to take to improve their re-servicing procedures so that they will provide for meters which meet the reliability objectives.
The written feedback received by the Agency has mostly focused on the economic and resource impact projections relative to the Bulletin’s implementation. Although consideration of the potential impacts on stakeholders is an essential part of the Agency’s policy or requirement amendment process, Measurement Canada’s expectations were that affected stakeholders would acknowledge the issue which the Bulletin seeks to address and would identify alternative proposals which could be implemented to correct the issue.
Measurement Canada’s Decision
Consequently, Bulletin E-26's principles will not be modified, however section 5.3.2 of the document is amended to address the implementation related feedback received. The amended section 5.3.2 of Bulletin E-26 will become effective as of January 1, 2005.
Measurement Canada will develop new programs and policies that will assist industry in fulfilling their obligations, while assuring Canadians that sound measurement programs and practices are being implemented:
- an additional approach will be pursued under specifications PS-E-11 whereby the initial reverification period of electronic meters could also be extended on the basis of actual performance data that would demonstrate the accuracy of meters over time. This would provide industry with an alternative way to possibly obtain a 10-year initial reverification period for electronic meters that have been sold over the last ten years;
- a target date of January 1, 2006 is being set for the completion and implementation of compliance sampling program requirements for all electricity meters (electromechanical and electronic); and
- the compliance sampling program will be generally applicable to all meter types.
With the cooperation of the electricity industry, the work on the above initiatives should proceed in a timely manner and mitigate the impact of Bulletin E-26.
In summary, Bulletin E-26 includes a formal requirement that a used meter needs to be renewed in order for it to receive the full initial reverification period at the time of subsequent reverification. Additionally, the Bulletin sets out an alternative, which is consistent with past policy for extending reverification periods through compliance sampling, where a meter is reserviced and not renewed it may be returned to service provided that all specified reverification requirements have been met. However, given the distinction between a new meter and a used meter, the reverification period applicable to these meters upon subsequent verifications shall not exceed two-thirds of its initial reverification period. (Realization of this objective has been staged in consideration of implementation related impacts).
In order for a used meter to be considered renewed for the purposes of the Bulletin, a documented analysis of the meter’s design with respect to reliability will need to be performed by technical personnel who are professionally qualified to make such assessments as to which components require replacement, repair, or adjustment and what workmanship standards need to be applied. It is expected that this expertise lies within the meter manufacturing community in meter design engineers and reliability engineers. Measurement Canada is not willing to assume this responsibility nor does it possess the necessary expertise to make these assessments and determinations.
Questions and Answers
1) When does Bulletin E-26 come into effect?
Bulletin E-26 was effective the date of its authorization and release. However, the section of the Bulletin which addresses reverification period extensions for meters that are not part of a lot inspected by compliance sampling methods, will be made effective gradually as follows:
- effective January 1, 2005, 5/6 of the initial reverification period; and
- effective January 1, 2009, 2/3 of the initial reverification period.
2) Will the introduction of Bulletin E-26 require accredited organizations to undergo an audit in relation to the quality manual procedural changes necessitated as a result of Bulletin E-26’s application?
Accredited organizations that have stated reverification periods on their quality management system documentation will be required to amend the stated reverification periods in accordance with Bulletin E-26. Conformance to this requirement will be verified at the time of surveillance audit. So, no additional audit will be required.
3) Will the full application of Bulletin E-26 on January 1, 2005 affect the reverification periods already granted to meters that are currently in-service?
No. Meters which have been previously verified and sealed in accordance with the requirements that were in effect at the time of the meter’s verification or reverification, shall continue to be due for reverification as per expiry of the period that was originally granted to the subject meters. However, when these meters are recalled at the end of their reverification period and this date falls after January 1, 2005, the revised requirements of Bulletin E-26 shall apply at the time of their reverification.
4) As a result of Bulletin E-26’s issuance, has the reverification period for all electricity meters now been shortened?
The maximum permissible reverification periods applicable to electricity meters, which are reverified under the requirements of Measurement Canada’s compliance sampling program, are unaffected (with the exception of polyphase energy meters with 8 year initial reverification periods, the maximum reverification period is now 5 years). All other meters inspected through 100% meter inspection and not renewed as part of the meter refurbishing activities will be subjected to an amendment in the maximum permissible reverification period.
Bruce Lyng
Manager, Utility Metering Division
Measurement Canada
Tel.: (613) 952-0636
Fax: (613) 952-1736
E-mail: lyng.bruce@ic.gc.ca
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Measurement Canada
