Summary of Comments Submitted by Procodeservice, LLC
Procodeservice, LLC submitted 11 comments regarding proposed updates to Michigan Boiler Rules under PA 407 and Part 9a. The comments primarily focus on ensuring that the rules remain consistent with Michigan law, existing codes, and practical boiler inspection and installation practices.
Read the proposed updates: PA 407
A brief summary of the major issues raised is provided below.
Full comments submitted by Procodeservice can be reviewed here: https://procodeservice.com/lara-actions/
1. Consistency with Michigan Statutes
Several comments raise concerns that portions of the proposed rules may conflict with requirements already established in Michigan law under the Skilled Trades Regulation Act (PA 407). The comments recommend revising rule language to ensure that administrative rules do not exceed statutory authority and remain consistent with existing law.
2. Clarification of Responsibility for Boiler Installation
One comment notes that the proposed rules appear to place certain responsibilities on boiler owners, even though Michigan law generally requires that licensed boiler installers perform permitted boiler installations.
The recommendation is to clarify that compliance responsibilities fall on the licensed installer performing the workrather than the owner.
3. Notice of Violations Should Be Sent to Permit Holders
Another comment states that the proposed rules do not clearly require that permit holders receive notices of violation.
The comment recommends that when violations are issued during boiler installations, the licensed installer holding the permit should also receive the notice, not just the boiler owner.
4. Maintaining Clear Installation Requirements
One comment recommends clarifying boiler installation rules so that installations must comply with:
5. Boiler Clearance Requirements
A comment raises concerns about clearance requirements between boilers and surrounding equipment or walls.
The recommendation is to ensure that the rule language clearly references applicable standards and allows reasonable compliance with manufacturer instructions and existing codes.
6. Deviation Requests to the Chief Boiler Inspector
One comment addresses procedures allowing installers to request deviations from rule requirements by submitting drawings and manufacturer instructions to the Chief Boiler Inspector.
The suggestion is to clarify this process to ensure consistent review and approval procedures.
7. Alignment with Existing Michigan Codes
Several comments emphasize the importance of ensuring that the boiler rules align with existing Michigan codes, including references to other applicable administrative rules governing installation and safety standards.
8. Protection of Potable Water Supply
One comment addresses a proposed rule requiring connections to potable water systems to comply with the Michigan Plumbing Code.
The concern raised is that the proposed language may require existing boiler installations to be retrofitted, which may not be necessary unless a health or safety issue is present.
The recommendation is to limit this requirement to new boiler installations.
9. Preservation of Existing Installations
Related to the potable water issue, the comments note that the Michigan Plumbing Code allows lawfully existing systems to remain in service if they do not present a hazard.
The recommendation is to ensure the boiler rules follow this long-standing principle.
10. Safety Valve Testing ProceduresOne comment addresses inspection procedures for pressure relief valves during CSD-1 inspections.
Existing rules allow technicians to perform a manual lift test of the safety valve rather than raising boiler pressure until the valve opens.
The comment recommends preserving this option for technician safety during inspections.
11. Maintaining Practical Inspection Practices
Overall, the comments emphasize that the proposed rules should maintain practical inspection and installation practices currently used by licensed boiler professionals while ensuring safety and compliance with Michigan law.
Important Note
This summary is provided for informational purposes to help inspectors understand the issues being discussed as part of the rulemaking process. Inspectors and other stakeholders are encouraged to review the full comments and proposed rule language before participating in the public hearing.
Full comments submitted by Procodeservice can be reviewed here: https://procodeservice.com/lara-actions/
Read the proposed updates: PA 407
A brief summary of the major issues raised is provided below.
Full comments submitted by Procodeservice can be reviewed here: https://procodeservice.com/lara-actions/
1. Consistency with Michigan Statutes
Several comments raise concerns that portions of the proposed rules may conflict with requirements already established in Michigan law under the Skilled Trades Regulation Act (PA 407). The comments recommend revising rule language to ensure that administrative rules do not exceed statutory authority and remain consistent with existing law.
2. Clarification of Responsibility for Boiler Installation
One comment notes that the proposed rules appear to place certain responsibilities on boiler owners, even though Michigan law generally requires that licensed boiler installers perform permitted boiler installations.
The recommendation is to clarify that compliance responsibilities fall on the licensed installer performing the workrather than the owner.
3. Notice of Violations Should Be Sent to Permit Holders
Another comment states that the proposed rules do not clearly require that permit holders receive notices of violation.
The comment recommends that when violations are issued during boiler installations, the licensed installer holding the permit should also receive the notice, not just the boiler owner.
4. Maintaining Clear Installation Requirements
One comment recommends clarifying boiler installation rules so that installations must comply with:
- Manufacturer instructions
- National Board Inspection Code (NBIC)
- Applicable Michigan administrative rules
5. Boiler Clearance Requirements
A comment raises concerns about clearance requirements between boilers and surrounding equipment or walls.
The recommendation is to ensure that the rule language clearly references applicable standards and allows reasonable compliance with manufacturer instructions and existing codes.
6. Deviation Requests to the Chief Boiler Inspector
One comment addresses procedures allowing installers to request deviations from rule requirements by submitting drawings and manufacturer instructions to the Chief Boiler Inspector.
The suggestion is to clarify this process to ensure consistent review and approval procedures.
7. Alignment with Existing Michigan Codes
Several comments emphasize the importance of ensuring that the boiler rules align with existing Michigan codes, including references to other applicable administrative rules governing installation and safety standards.
8. Protection of Potable Water Supply
One comment addresses a proposed rule requiring connections to potable water systems to comply with the Michigan Plumbing Code.
The concern raised is that the proposed language may require existing boiler installations to be retrofitted, which may not be necessary unless a health or safety issue is present.
The recommendation is to limit this requirement to new boiler installations.
9. Preservation of Existing Installations
Related to the potable water issue, the comments note that the Michigan Plumbing Code allows lawfully existing systems to remain in service if they do not present a hazard.
The recommendation is to ensure the boiler rules follow this long-standing principle.
10. Safety Valve Testing ProceduresOne comment addresses inspection procedures for pressure relief valves during CSD-1 inspections.
Existing rules allow technicians to perform a manual lift test of the safety valve rather than raising boiler pressure until the valve opens.
The comment recommends preserving this option for technician safety during inspections.
11. Maintaining Practical Inspection Practices
Overall, the comments emphasize that the proposed rules should maintain practical inspection and installation practices currently used by licensed boiler professionals while ensuring safety and compliance with Michigan law.
Important Note
This summary is provided for informational purposes to help inspectors understand the issues being discussed as part of the rulemaking process. Inspectors and other stakeholders are encouraged to review the full comments and proposed rule language before participating in the public hearing.
Full comments submitted by Procodeservice can be reviewed here: https://procodeservice.com/lara-actions/