The Public Safety Act (Amdt.), 2024 adds a new power allowing the chief inspector of amusement rides and elevating devices to authorize non‑inspectors to carry out inspections when necessary, subject to qualifications set by regulation. Authorized inspectors must produce written reports and are barred from having any direct or indirect financial interest in the rides they inspect.
The government also gains explicit regulatory authority to set inspector qualifications and to license persons who inspect rides.
The bill abolishes the Public Safety Appeal Board and creates an internal appeal route to the deputy minister, with a possible further appeal to the Supreme Court on questions of law or jurisdiction. It also updates statutory cross‑references, replaces gendered language, and contains transitional and commencement clauses.
The changes centralize oversight and standardization of inspection practices but shift dispute resolution from an independent board to an executive review process, with practical implications for operators, inspectors and insurers.
At a Glance
What It Does
The bill permits the chief inspector to authorize qualified non‑inspectors to perform inspections, requires those authorized to file written reports, bans inspectorial financial interests in inspected equipment, and empowers the Lieutenant‑Governor in Council to create qualification and licensing rules. It repeals the Public Safety Appeal Board and establishes a 2‑step review path: an administrative appeal to the deputy minister, then limited judicial review in the Supreme Court on law or jurisdiction.
Who It Affects
Amusement‑ride operators and owners who must engage licensed inspectors; firms and individuals that perform inspections, who will face new qualification and licensing requirements; the provincial department and deputy minister, who gain a new internal review role; and insurers and legal advisers who handle compliance and appeals.
Why It Matters
It professionalizes and centralizes inspection standards for rides and elevating devices, while consolidating appeal authority inside the executive branch. That changes where safety disputes get resolved and reallocates administrative workload from an independent appeal board to the deputy minister's office.
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What This Bill Actually Does
The Act adds a new section (5.1) letting the chief inspector authorize a person who is not formally designated an inspector to conduct inspections of amusement rides and elevating devices when the chief inspector deems it necessary and the person meets qualifications set out in regulations. The authorized person must submit a written inspection report in a form the chief inspector prescribes, and the statute flatly prohibits any direct or indirect interest in the manufacture, sale, installation or maintenance of the equipment being inspected.
On the administrative‑law side, the independent Public Safety Appeal Board is removed. Instead, appeals of chief inspector notices, decisions or orders go to the deputy minister within 30 days.
The bill specifies what must be included in the written appeal (the decision being appealed, reasons, all supporting information and any materials the deputy minister requests). The deputy minister must begin review within 30 days of receiving the appeal, may confirm, revoke or vary the original action, and must issue a written decision with reasons and provide it to both the appellant and the chief inspector no later than 30 days after the deputy minister completes the review.
If a party remains aggrieved, they may appeal to the Supreme Court, but only on questions of jurisdiction or law.Regulatory powers are broadened: the Lieutenant‑Governor in Council can prescribe the qualifications for persons authorized to inspect rides and the licensing requirements for those in the inspection business, and licences are explicitly added to the list of regulatory instruments. The Act also makes a series of technical edits (replacing references to the Trial Division with 'Supreme Court' and switching to gender‑neutral phrasing) and carries transitional language directing that any appeal already before the abolished appeal board will be concluded by the deputy minister.
Several sections come into force by proclamation.
The Five Things You Need to Know
The chief inspector may authorize a non‑inspector to inspect amusement rides and elevating devices where the chief inspector decides it is necessary and the person meets regulatory qualifications.
Anyone authorized to inspect must submit a written report to the chief inspector in a form the chief inspector sets and must not hold any direct or indirect interest in the manufacture, sale, installation or maintenance of the inspected device.
The Public Safety Appeal Board is repealed; appeals of chief inspector decisions must be filed in writing to the deputy minister within 30 days and must include the notice or order being appealed plus supporting information.
The deputy minister must begin review within 30 days of receiving an appeal, may confirm, revoke or vary the decision, and must provide a written decision with reasons to the appellant and chief inspector no later than 30 days after completing the review.
A further appeal is limited to the Supreme Court and restricted to questions of law or jurisdiction — factual disputes are resolved through the deputy minister's review.
Section-by-Section Breakdown
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Delegation: authorizing non‑inspectors to inspect
This new subsection gives the chief inspector discretion to authorize persons who are not statutory inspectors to perform inspections, but only when the chief inspector considers it necessary and the person holds qualifications that the regulations will set. Practically, this lets the chief inspector fill capacity gaps (for example, surge inspections) or use specialized contractors subject to standardized entry criteria. The provision also requires written reports in a form the chief inspector determines and bars any inspectorial financial interest in the inspected equipment — a strict conflict‑of‑interest rule intended to preserve impartiality.
Appeal process moved inside the department (appeal to deputy minister)
Section 26 creates a formal administrative appeal to the deputy minister within 30 days and prescribes what an appeal must contain: the original notice/decision/order, reasons for appeal, and all supporting information plus anything the deputy minister requests. The deputy minister has the authority to confirm, revoke or vary the chief inspector's action and must begin a review within 30 days of receiving the appeal. The text requires a written decision with reasons and delivery to both parties no later than 30 days after the review is completed, but it does not set a maximum duration for completing the review itself.
Judicial review narrowed to questions of law or jurisdiction
The Act replaces appeals to the abolished board with a right to appeal the deputy minister's decision to the Supreme Court, but only on matters of jurisdiction or law. That confines factual and technical disputes about inspections to the administrative review and preserves court intervention for legal errors and jurisdictional overreach. For parties used to broader remedial avenues, this is a substantive narrowing of judicial access.
Regulatory authority for qualifications and licensing
The Lieutenant‑Governor in Council gets explicit authority to prescribe inspector qualifications and to regulate licensing of businesses that carry on inspection services. The Act also inserts 'licences' into the list of regulatory tools. This creates a framework to professionalize inspection practice and to set enforceable entry standards, but the substance of those standards will be left to regulation, not statute.
Abolition of the appeal board, transitional finish, and housekeeping changes
The repeal of the Appeal Board (s.25 and ss.27–27.2) eliminates an independent adjudicative layer; appeals already before the board when the Act comes into force are to be concluded by the deputy minister. Schedule C to the Public Service Commission Act is updated to remove the statutory appointment reference to the abolished board. The bill also replaces references to 'Trial Division' with 'Supreme Court' and modernizes gendered language. Several provisions come into force by proclamation, giving the government discretion over the implementation timeline.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Provincial department and deputy minister — gains centralized control over appeals and standard‑setting powers, allowing faster policy alignment and a single administrative decision‑maker for ride safety disputes.
- Amusement‑ride operators seeking consistent inspection standards — statutory authority for qualifications and licensing can produce predictable, uniform inspection criteria across the province.
- Inspection firms and professionals who meet the forthcoming regulatory qualifications — licensing can raise barriers to entry for less‑qualified competitors and help firms market verified competence to operators and insurers.
- Public safety and compliance officers — the chief inspector can deploy authorized inspectors to address capacity shortfalls and require standardized written reports, improving recordkeeping and oversight.
Who Bears the Cost
- Individual inspectors and small inspection businesses — will face licensing, qualification and compliance costs, and the new conflict‑of‑interest prohibition may exclude some practitioners with industry ties.
- Amusement‑ride owners and operators — may face higher inspection fees or narrower choice of inspectors as licensing and conflict rules reduce the pool of available inspectors.
- Former Public Safety Appeal Board members and independent adjudicative infrastructure — the abolition removes an arm's‑length forum for disputes.
- Departmental staff and the deputy minister's office — must absorb increased review workload, case management and decision‑writing duties previously handled by the Appeal Board.
Key Issues
The Core Tension
The bill pits a desire for centralized, consistent oversight and quicker administrative resolution against the loss of an independent adjudicative body: it strengthens regulatory control and professionalizes inspection work but concentrates dispute‑resolution power inside the executive branch, trading independent review for administrative efficiency and regulatory flexibility.
Two implementation risks matter. First, the statute delegates key content — inspector qualifications and licensing rules — to regulation without setting detail or minimum standards in the Act itself.
That leaves substantive threshold questions (training hours, testing, continuing education, fees, disciplinary measures) to future rulemaking; outcomes will depend heavily on regulatory design and resourcing. Second, the appeal path trades an independent adjudicative body for an internal executive review.
While centralizing appeals can speed decisions and harmonize outcomes, it concentrates discretion and may reduce perceived impartiality; the statutory timelines require only that the deputy minister 'begin' review within 30 days and issue a decision within 30 days 'after completing the review,' but do not cap how long the review itself may take. Those timing gaps can create uncertainty for operators and appellants.
Other practical questions remain. Enforcing the conflict‑of‑interest ban on authorized inspectors requires active oversight and accessible sanctions; absent robust licensing and audit powers, the prohibition could be porous.
The transitional provision directs the deputy minister to finish appeals already before the abolished board, but that consolidates existing contested matters under the executive at the same time as substantive regulatory changes take effect, which could affect parties' strategies. Finally, shifting appeals to the deputy minister and narrowing court review to law/jurisdiction may increase the number of legal challenges on pure legal grounds as parties attempt to preserve remedies in the courts.
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