CAAR has helped members weather regulatory changes for 25 years.
When the members of the Western Fertilizer and Chemical Dealers Association (WFCDA) voted to form a national organization, they sought to achieve more clout with regulators. The new organization would be better positioned to help ensure decision makers considered the agri-retailer perspective when creating policy that would affect their businesses. No issue illustrates this better than the ongoing work CAAR has done on behalf of its members regarding anhydrous ammonia (NH3) regulations.
From the start, CAAR has taken a leadership role on anhydrous ammonia field tank safety. In 1995, in response to new NH3 tank hydrostatic testing regulations, the fledgling association went all-in on their lobbying efforts. According to CAAR’s first executive director, Jaqueline Ryrie, it took considerable effort just to get a meeting with the federal minister responsible for the file.
“What did it take to get the message across? Dedication and perseverance, perseverance, perseverance,” said Ryrie in the fall 1995 issue of The Communicator. “In Canada, where there is legitimate concern with the impact of regulation, change can be made. However, it doesn’t come without a lot of elbow grease on the part of the people.”
CAAR’s perseverance paid off and, by 1997, the association had helped to create an industry-run program that would serve as an alternative to the government’s B620 protocol for the next decade.
Under the direction of the Anhydrous Safety Council, the CAAR office and Transportation Committee began administering the NH3 Field Tank Safety Program in 1997. Their initial work included setting up a tank registration program, running courses to train and accredit safety controllers, implementing the auditing program and finding auditors from within its membership. By April 1998, 272 companies were participating in the program and had registered over 10,000 field tanks.
When retailers transitioned to the B620 safety standard in 2007, CAAR helped facilitate the change by offering a new Nurse Tank Safety Program (NTSP), administered by the Nurse Tank Safety Council of Canada. CAAR provided in-person training, information on how to apply to Transport Canada for facility registration, and a quality control manual. Former Ammonia Safety Council members were also eligible for a permit allowing five additional years under the existing protocol.
Around the same time, CAAR actively worked with the Fertilizer Safety and Security Council (FSSC) to provide input on the Ammonia Standards Program, on behalf of its membership. In the July 2008 issue of The Communicator, Dave MacKay, CAAR’s executive director, said that by proactively providing feedback, many aspects of the code that were perceived to be too onerous or impractical were modified.
“The CAAR Facility, Transport and Logistics Committee was able to eliminate a long list of retailer objections through a series of concessions and revisions negotiated with the FSSC Code Implementation Committee,” said MacKay.
In 2016, CAAR had the opportunity to reconnect with Transport Canada, working closely alongside Fertilizer Canada, to revise and update the NTSP. This continued level of involvement has resulted in a program that helps retailers stay informed and remain in compliance with B620 regulations, while meeting the needs of all sides.
“Working more closely with Transport Canada has led to a deeper understanding by both organizations of the regulatory pressures that retailers face and where improvements may be made,” said Delaney Ross Burtnack, CAAR president and CEO, in a 2016 Communicator article.
In addition to providing both in-person and online NTSP training and timely communication to retailers, CAAR remains involved in the program’s ongoing development by identifying opportunities to improve the program and by providing feedback on proposed changes.
B620 regulation changes were again CAAR’s focus when Mitch Rezansoff came in as executive director in 2018. CAAR wasn’t opposed to the legislation updates, but the implementation created potential problems for members and their customers. The increased frequency of required hydrostatic testing and visual inspections for NH3 truck and nurse tanks would have left approximately 20 per cent of tanks in Canada out of compliance.
With a long history of supporting its membership to successfully navigate regulatory changes, however, CAAR once again assisted members through the transition; this time by working with Fertilizer Canada to secure a temporary certificate TH 0653.1. The certificate, which was valid until the end of June 2018, allowed ag retailers enough time to complete hydrostatic testing and ensured NH3 resources for farmers. The experience was both a learning moment for Rezansoff and a win for CAAR.
“The work CAAR has done on the B620 issue is an excellent example of what we can accomplish for our membership,” says Rezansoff. “There is another round of proposed changes to B620 scheduled for spring 2020 and we are busy updating training and communications materials to ensure members are well-informed and prepared for a smooth implementation.”
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