How Much is New Text in Each CEC?
May 28th, 2017
The Canadian Standards Association (CSA) sells the right to read electrical laws in Canada. That is, if you need to know how to wire something, somewhere, if you need to know the laws that apply to electrical wiring, you can pay money to CSA and they’ll give you access to those laws.
Right now, the CSA is charging each of us $180 to read electrical laws (called the “Canadian Electrical Code, or CEC”). They charge more if you’re in Ontario, it’s over $200 there. Have you wondered what you’re getting for these fat fees?
Whatever you’re getting had better be good. After all, the CSA amends electrical law in three year cycles, so electricians have to pay money to CSA every three years because compliance with electrical law is, you know, fairly important to electricians.
In each three-year cycle, the CSA takes $11MM in taxpayer dollars in access payments. That’s a lot of money, and it’s your money, but then CSA does a lot of work, you’re getting a lot of value for your payment.
Or are you?
According to CSA, the value is immense, the amendments to electrical law are always bragged as substantial, significant, industry-altering, hence the pricey price.
The latest amendment to electrical law was released in 2015. Once again, the CSA talked it up; “major changes,” they said, “more than 200 updates and revisions,” all of which “will affect your installations”.
The CSA emphasized the newness of the 2015 edition, pointing out that this edition “supersedes the previous editions.” That is, the laws that you’ve already paid for are now throw-away, you’ll need to pay again to know the new ones, the ones with all of the “major changes”.
They made the same claim in Court. In their collection of Court actions against PS Knight Co, the CSA has consistently claimed that each amendment of electrical laws is unique, each being a vastly different document. Indeed, the Court was told, each amendment is so completely redrafted that each iteration of electrical law is an entirely new legislative text.
We knew that’s nonsense. Some electrical regulations are carried through several iterations of law without any changes whatsoever. Some text can be traced back for decades. Yet CSA is claiming that each iteration is unique and new.
So we put CSA to the test. We wanted to know exactly how much of each “new” text in electrical law is actually new. We wanted to test that text objectively and scientifically. We needed reliable results, because these would be entered as evidence in Court. Here’s what we did.
We took the full text of the last three iterations of electrical law, being the 2015, 2012 and 2009 editions, and ran all 2,000+ pages through some fairly sophisticated plagiarism detection software, to compare each of the texts against each other. The resulting report is very detailed, stating exactly how much of each document is unique vs. how much is copied and from which previous iteration. With this, we can report what $11MM of taxpayer’s money is paying for.
The quick answer? Two percent.
The amount of actual new text in each iteration of electrical law is approximately 2%. The other 98% is copied from existing electrical law.
In the 2012 edition for instance, the amount of newly drafted text was 1.53%. Everything else was copied from the 2009 edition.
Likewise, in the current 2015 edition, through five sections of law (numbered as Sec. 30 - 38), only 1.67% of the text of law is actually new material. The sum of text across these five sections is 20,990 words, of which 20,640 words are copied directly from the 2012 iteration of law.
Back to the bumf, the CSA claims in advertising the 2015 edition that “Section 62 has been completely rewritten.” Oh, really?
Comparing the current Section 62 text with the previous iteration is a fascinating exposure to red highlighting. That is, plagiarism test results show copied text in red highlight, and the 2015 Section 62 text is pretty plastered with it.
Some sections are so similar, they’re almost photocopies. In 2012 for instance, throughout Sections 60 - 86 of the law, 99.41% was copied from 2009. Again, in the same edition, new text throughout Sections 10 - 18 amounted to just 0.87%, and Sections 30 - 38 was only 0.71%. In fact, the most new material was found in Sections 40 - 58, where 4.61% was amended. Of course, that still leaves over 95% of that section of law unchanged from the previous iteration.
How’s that for “completely rewritten”?
Consider that throughout Sections 60 - 86 in the 2012 edition, all of the new text amounted to only 141 words. On Twitter, that’s five tweets. Is that worth $180?
Well, it gets worse.
You see, plagiarism detection software doesn’t discriminate within text. It treats all text as equal, merely measuring differences between them. Page numbers will be seen as new edits, as pagination changes due to formatting, font size, etc. Same goes for page references within text. As the locations of text are shifted in formatting, so will each page number reference within that text. Same thing with table numbers, and so on. Critically, all of this shows in test results as “new” and “unique”. The amount of actual revision of law is therefore even lower than the test results indicate.
That said, let’s be clear that some minor changes to text make for major changes to law. Take a biblical example, as; “Thou shalt not commit murder.” Removing the word “not” would be a minor change to text, yet a major change indeed.
Legal history is crammed with electrical law examples of small grammatical changes that fundamentally alter the application of that law. In each iteration of electrical law there are indeed materially significant amendments to be found. It’s just that there aren’t nearly as many of them as advertised, and not nearly sufficient to charge taxpayers $11MM to access them.
And some changes look like excuses to sell more amendments.
Consider for instance, Rule 10-404 of electrical law. This regulation used a rule heading which previously read; “Non-metallic wiring systems”. Now it reads; “In non-metallic wiring systems”. Got that? The “in” is now in.
Another example; the change in heading from “Circuit” to “Circuits”. Nothing changed in the text it referred to.
Previously, a heading within Rule 10-614 read thusly; “each fitted with a locknut and grounding bushing”. The CSA changed it to read; “each fitted with a locknut and a grounding bushing”. The plagiarism test caught the inclusion of the second letter “a”. Does that change the application of law?
They did the same thing at Rule 10-804, as originally; “one of the following; a) conductor of copper […]” Then reading with CSA’s “major changes” included; “one of the following; a) a conductor of copper […]” The letter “a” is new.
These changes are grammatical, some are formatting changes, but very few are material in that they don’t alter the content or the application of law.
Then there are silly changes.
For example, in Rule 12-706 a space was added between two words in subsection 3. That’s it, nothing else.
The same thing happened in Rule 18-106 in subsection 2. It happened again in Rule 18-108.3.b.
Actually, there are dozens of instances of spacing insertions throughout the text and each of these counts as a change to the previous edition, yet none of these affects the content of law. In fact, the average user wouldn’t notice these changes at all. An extra space between words wouldn’t be noticed without a plagiarism test.
Get the idea? Of the approx. 2% of new material, quite a bit of that 2% is actually non-material change. Real change to electrical law then, is well below 2% of each edition.
We deal with this all the time at PS Knight Co, and it annoys us all the time. We have to redraft our guidebooks every three years to accommodate CSA’s padding the law to look more new than it really is. They change the location of information, “amalgamating” Rules, yet the text of those rules, being the requirements of law, is almost always unchanged. Yet because the location changed, we have to redraft our explanations of the requirements, reformat print documentation, pay for reprinting, and so forth. All of this adds cost to the customer, and it’s mostly unnecessary.
Real amendments, really needed, should be really inserted. All else should really be culled.
As for the body of electrical law itself, if the actual changes are less than 2%, and if the change is isolated to, say, a couple of Sections, then the CSA could just change those sections and honestly admit that the balance of law is unchanged. Why don’t they do this? Well, then the CSA couldn’t justify taking another $11MM from us. That’s why.
The bottom line is that padding the law to increase sales is unacceptable.
That’s our view.