Episode 11: Risk-based Oversight transcript
Will Barrett: A higher defect ratio could increase the likelihood that electrical work is deemed medium or high risk, and ESA could visit you more often. It's important for contractors to keep track of their defect ratio, and they can now access this information online, as well as ask a CSR when they call into the Customer Service Center. One of the positives of maintaining a low defect ratio is that ESA could visit you less often, so contractors can spend more time running their businesses and less time waiting for ESA to visit their site on low risk installations.
Karen Ras: It's been more than two years since ESA's launch of risk-based oversight. Since then, we've streamlined the process to make it even easier for businesses to comply and reduce burden. On this episode, we'll answer some of your most frequently asked questions and highlight the digital improvements we've implemented to help you do business with ESA.
Grounded in Ontario is a podcast for you, the province's licensed electrical contractors, master and certified electricians, and offers safety tips, tech, and best practices. Now, let's get grounded. Hello, and welcome to another episode of Grounded in Ontario.
I'm Karen Ras and I work for the Electrical Safety Authority. Today, we're talking about a topic that I know affects our licensed electrical contractor community, and that is risk-based oversight, otherwise known as RBO. With me today is Will Barrett, General Manager for Operations, Planning, and Support at ESA. He's going to talk with us about what contractors need to know about RBO, as well as tips for contractors to simplify the inspections process. Now, for those of you who are not familiar with Will, he is a Licensed Electrician and Master Electrician. He spent 18 years working in the electrical contracting world before joining ESA, working on a wide range of industries and installation types. Since joining ESA in 2017, he's filled the role of Inspector, Senior Inspector for RBO, and has mentioned he's now General Manager for Operations, Planning, and Support. Will, it's so nice to have you on this episode with us. I'm looking forward to digging into this topic, and I'm sure our listeners are as well.
Will Barrett: Thank you for having me, Karen.
Karen Ras: So Will, let's get started. Let's get back to the basics, and just level set for those listeners who may not be as familiar with RBO. What is it, exactly?
Will Barrett: RBO for wiring work is a process where ESAs oversight of an electrical installation is based on an assessment of the safety risk. Safety risk means the likelihood an event will occur and, if it does, how much harm will it cause? When a notification is open with ESA, it's assessed by the RBO system or engine using who, what, where criteria, and then a risk recommendation is provided to the inspector for consideration. RBO allows ESA to shift our efforts to higher risk installations and safety activities, including compliance, enforcement, and to address the underground economy. It also reduces the burden on contractor time and workflow by making it easier to comply with electrical safety regulations.
Karen Ras: Now, you mentioned the RBO system provides a risk recommendation. I'm just wondering if you can elaborate on that.
Will Barrett: As part of RBO, each wiring notification submitted to ESA is rated by our Risk Assessment System, as well as reviewed by an inspector prior to making a decision to visit. A risk rating is assigned to every notification when it's processed, high, medium or low. When scheduled, notifications are sorted into light groupings for each contractor based on risk, and the risk rating determines the visit ratio for that group of notifications. The visit ratio within selective inspection is one of RBO's key benefits. One visit for every 5% or 20% notifications filed by a contractor-risk rated low, one visit for every two notifications filed by a contractor-risk rated medium, and one to one for every notification filed by a contractor that's high risk. Contractors are advised that the inspector can still choose to make a visit regardless of the risk rating or site visit recommendation. Providing ESA with scheduling requests in advance, however, helps the inspector evaluate the work and, in turn, provide advanced notice to the contractor. ESA will make best efforts to communicate visit intentions with the contractor via text or email, based on the timing of the scheduled requests. If the contractor does not receive notice from ESA that the notification has been passed without a visit, or scheduled to a different day, they are to assume ESA will be attending the site for a physical inspection, and ensure there's access to the site until 4:30 PM.
Karen Ras: Thanks, Will. I know that RBO is just one tool that inspectors use. I don't think that many people understand that it is ultimately up to the inspector to use their judgment to make a site visit, regardless of the risk rating. But, as a contractor, can they request that an inspector attend their job site?
Will Barrett: Yes. LEC's will still be able to request a site visit, regardless of the risk rating. If your customer wants a visit, you can get a visit. Often, homeowners ask contractors this question all the time. "I've paid for notification fees, will I see an inspector?" Or, maybe they have a bit of anxiety about the job, and they want the inspector to come and make a physical visit. We always encourage that, no matter what, an inspector can visit a job.
Karen Ras: You mentioned the RBO system provides a risk recommendation. I'm wondering if you can elaborate on that.
Will Barrett: Yes. ESA assesses electrical work using nine attributes. The attributes consider who does the work, what the work is, and where the work is taking place. It's important to note that the defect ratio is only one of the nine attributes that ESA uses to assess risk. It's not meant to be an evaluation on whether a contractor is a good contractor or not. It's the opportunity for you as a contractor to show us how code compliant you've been, based on your notification volume in the last 12 months. The defect ratio is calculated by dividing the number of notifications with one or more technical and/or warning defects by the number of notifications with one or more visits. In other words, the number of sites with defects divided by the number of sites that ESA has visited will equal the defect ratio. For example, ESA visits 10 sites where two had at least one technical defect, would equal two sites with defects over 10 sites visited, or a 20% defect ratio. Number of defective sites and sites visited are from the previous 12 month rolling window. Technical defects and warning defects are included in the calculation, but are weighted differently. An ESA inspector writes a technical defect when an electrical installation does not comply with the Ontario Electrical Safety Code. An ESA inspector writes a warning defect when the electrical installation does not technically comply with the OESC, and the likelihood of shock, fire, and exposure is low. Five warning defects are equal to one technical defect. Administrative defects, such as no access and postponement defects, do not count towards the defect ratio.
Karen Ras: Now, are there situations when RBO benefits are not available for a licensed electrical contracting business?
Will Barrett: Some contractors will not be eligible for selective inspection for a number of different reasons, such as defect ratio greater than the maximum allowed for the program, be it 4% or 10%, for three consecutive months. Or, notification volumes that are below the minimum threshold for the past 12 months. The contractor needs to have three consecutive months of good performance to get that benefit back. Leaving a life and/or property hazard at the site, which is when an ESA inspector determines that the electrical installation doesn't comply with the OESC, and presents a high likelihood of shock or fire. Unauthorized connection, three failure to file notifications in a three year period. Licensed electrical contractors have a shared responsibility for safety. If a contractor discovers existing hazards while on a work site, the contractor must advise ESA immediately, and can do so from our website, esasafe.com, or by calling into our customer service center, or by mail. One area where our inspectors have spent more time is with new contractors. You have to take on a minimum of 10 notifications with ESA to qualify for selective inspection. This is where our inspectors have seen the benefit of being able to spend more time with contractors that may be brand new to the industry.
Karen Ras: I think now is a good time where we can remind contractors, especially the newer ones, that there is a webinar available up on our YouTube channel, and we will post a link to that on this podcast page. How can the defect ratio impact the frequency of ESA site inspections? I think that this is a very, very common question that we get from our LEC's. Do you have any advice for listeners on how they can improve their defect ratio?
Will Barrett: A higher defect ratio could increase the likelihood that electrical work is deemed medium or high risk, and ESA could visit you more often. Defect and visit information is calculated monthly, and is available to contractors. After three consecutive months above the defect ratio maximum, you can expect to see the inspector more often. It's important for contractors to keep track of their defect ratio, and they can now access this information online, as well as ask a CSR when they call into the Customer Service Center. One of the positives of maintaining a low defect ratio is that ESA could visit you less often, so contractors can spend more time running their businesses and less time waiting for ESA to visit their site on low risk installations. Another benefit is eligibility for selective inspection and preauthorized service connections. ESA wants contractors to be able to enjoy these benefits, so knowing and maintaining a good defect ratio gives them a chance to qualify. The best way to improve the defect ratio is by ensuring you do code compliant work. I encourage all listeners to review our Top 10 Defects two part podcast episode for tips on what to look out for.
Karen Ras: Thanks, Will. That's a good tip about going back to listen to those episodes. I know I learned a lot from it, and it certainly helped me gain a better understanding of why we need to be aware of these defects. You mentioned contractors are eligible for preauthorized service connections and certain RBO programs if they maintain a good defect ratio. I'm just wondering if you can elaborate on that. What are some of these programs?
Will Barrett: In addition to selective inspection, contractors may be eligible for pre-authorized reconnection for service repairs and upgrades on residential and commercial sites. RBO programs apply to electrical installations that are specific and/or limited in scope. High voltage substation maintenance, low voltage service maintenance, pole line maintenance, central metering-both residential and agricultural, generators, pools and hot tubs, retrofit luminaires, small jobs-both residential, apartment, or commercial, and residential HVAC.
Karen Ras: What about eligibility?
Will Barrett: Eligibility is dependent on a contractor's notification volume and defect ratio. RBO programs allow ESA to apply a predefined visit ratio for eligible electrical work. For example, LEC's can be eligible for residential pre-auth if they have at least five residential service changes, repairs, or upgrade notifications within the past 12 month rolling window, and a less than or equal to 10% defect ratio. RES pre-auth does not include brand new service work. The parameters are similar for commercial pre-auth. Five commercial service changes, repairs, upgrade notifications within the past 12 month rolling window, and a less than or equal to 10% defect ratio. New commercial service work is also included from the benefit, and eligibility counts.
Karen Ras: That's great. Certainly, this provides another avenue for contractors who do compliant work to focus their time on running their business, and not waiting for ESA to visit the site. I know we've been hard at work to provide more accurate tools for our contractors so they have a better idea of timeframes when we do have to come for a visit. Now, can you tell us about some of those digital innovations?
Will Barrett: In the summer of 2021, ESA implemented a new mapping tool in certain areas of the province that provides inspectors with a flexible system of planning inspection routes, and enables ESA to communicate inspection timelines with customers. The inspector mapping tool enables ESA inspectors to plan their day, and allows for easier management of emergencies or changes in schedule to help ensure electrical inspections take place in a timely fashion. One of the key benefits of the new system is that it offers improved communication tools so inspectors can let customers know when they will be arriving via text or email message. The site contact could receive an email or text in the morning proposing a time window when the inspector is expected to arrive. The site contact may receive another message when the inspector is on their way to the site. This will help customers plan out their day and ensure that the appropriate contact is on site to meet the inspector when they arrive.
Karen Ras: Thank you for that information, Will. I also know one of ESA's objectives is to reduce the burden on contractor time and workflow, while continuing with oversight for safe electrical installations. Can you explain some of the steps we've taken to improve our systems and processes?
Will Barrett: Inspection flag options were recently added to the ESA online services system to make it more efficient for contractors to provide required information to ESA. On the site details page, contractors can select applicable flags to identify a hoarding, meth lab, or Grow Op site, if this information is known. This feature creates a record of important health and safety, and inspection information for our inspectors. When applying for repairs following a storm or disaster, contractors can now file online rather than calling into the Customer Service Center. On the job page, contractors can check the storm disaster toggle and select from a list of applicable events, such as fire, flood, windstorm, or lightning strike to advise ESA.
Karen Ras: Certainly, with the increase in frequency and severity of storms, and we certainly saw that firsthand with the massive storm in May, I can imagine these types of tools are very helpful for our contractors. Are there any tips that you can think of that will help our listeners streamline the inspection process?
Will Barrett: When submitting an application for a notification to ESA, contractors are asked to provide accurate and detailed location and site contact information. Additional details are important, and especially valuable on large sites and/or for multi-phase installations. This information is shared with the inspector to ensure the visit is as efficient as possible.
Karen Ras: What a great tip. It reminds me of the example that Trevor had mentioned in one of our earlier episodes, about hospitals needing to provide more details because it can be so awkward approaching the front desk and no one knows where to redirect you. Now, before we close, I do want to ask a question submitted by one of our listeners, Mike from Mississauga. They wrote that they were eligible for preauthorized connection, but the scope of work didn't quite fall into the categories of the benefit. For example, commercial pre-authorizations are limited to services that are less than or equal to 400 Amp, and a maximum voltage of 208V, 3 phase. Residential pre-authorization is limited to less than or equal to 200 Amp and a maximum voltage of 240V, single phase. Can you explain why?
Will Barrett: The above point is correct, regarding the parameters for residential and commercial pre-auth. There are many reasons why the work could have fallen outside the pre-auth eligibility. For example, the work could have been considered net new, brand new construction, or a change from a single phase to 3 phase, which is not included in the pre-auth benefit. The work could have involved a residential installation with a service larger than 200 Amps, or the site could have been an apartment building. The contractor could have pre-authorized eligibility in residential but not in commercial, or in one of the other programs depending on the site and the work involved.
Karen Ras: Will, thank you for this helpful answer and for joining me on this episode of Grounded in Ontario. I hope our listeners have taken away some important reminders like I have. In case you missed our two part episode on the Top 10 Defects, you can access it on our website at esasafe.com/podcast. As always, we welcome your feedback and suggestions for future episode topics too. Thank you for listening.
Thanks for listening to Grounded in Ontario. If you have any questions on this topic, or any other electrical safety topic, we want to hear from you. Email us at firstname.lastname@example.org. We plan to answer some frequently asked questions in future episodes. Make sure you follow this podcast wherever you get your audio content so that you'll get notified about new episodes. Until next time, be safe, work safe, and stay grounded.