From:

R.GOPAL
95/6-Sathya Nagar,
Beside of water tank
Ammapet,
Salem-636003.

To:
The Secretary,
Central Boilers Board,
Ministry of Commerce and Industry,
(Deptt. of Industrial Policy and Promotion)
Room No. 358, Udyog Bhavan,
New Delhi 110 107.
Letter Dated: 23 -05-2015.

Sir,
Sub: Fees Structure for Inspection of Boilers Gazette Notification
Suggestions - Submitted Regarding.
Ref : Gazette Notification No. G.S.R.285(E), dated 15-04-2015.
***
I submit following suggestions in respect of the Gazette Notification reference
cited.
It is submitted that the scales of Inspection fee is interlinked to the Fees
Sharing between a private competent person and the state Government and shall not
be decided in isolation.
I submit that a private competent person may be paid 50 percent of the
inspection fees subject to a maximum of Rs.15,000/- per boiler and the balance of
Inspection Fees may be paid to Boilers Department.
In this connection, I submit that functions of a Boilers Department is not
limited to inspection and certification of boilers. The Boilers Department has to
implement the total Act in the state which includes periodical visits to factories using
boilers to verify safe operation, deployment of certified manpower stipulated in the
Act, check use of uncertified boilers and also giving advice to the boiler owners
regarding proper operation and maintenance of their boilers. Further, Boilers
Department shall keep safe custody of Records, launch Prosecutions, enquiry against
complaints, investigate into accidents, examining appeals, granting exemptions,
conducting various examinations etc.. The number of Inspectors in the State are based
on number of boilers in use in the State and consequent work load and also inspection
fees received for inspection and certification of boilers. If the entire inspection fees of
a boiler is given to a Private Person who inspects and certifies a boiler, then the
Boilers Department will be deprived of its entitled revenue that is necessarily required
to maintain the Department. Further, it is not required that a Private Person shall be
paid more than Rs.15,000/- for inspection and certification of one boiler.
In the proposed fee structure, Inspection Fee is Rs.1,000/- for a small Boiler
whereas the fee for a 800 MW Boiler is Rs. 2,64,000/-. For inspection of a small

boiler in a remote corner of the State, the Boilers Department shall spend very much
more than the fee of Rs. 1,000/-. However, there will be savings in case of big Boilers.
On the whole, the expenditure becomes comparable to the Income. No private person
will be interested to take Rs.1,000/- and inspect small boilers going to every nook and
corner of the State. They will be interested only in inspecting big size boilers with
huge amount of Inspection fee. If this is allowed, there will be imbalance and
instability in the Financial Condition of Boilers Department.
Further, it is pertinent to state the capability of Private Persons as per the
existing Indian Boiler Regulations. In accordance to the existing Regulations, a
private Person having 5 years experience on a 1(one) Tonne per hour capacity boiler,
who passes theory examination conducted, is entitled to inspect and certify the fitness
of 20,000 tonnes per hour capacity Thermal Power Plant boiler. In case of Boiler
Inspectorates, such work is allocated to Inspectors having vast experience on such
boilers. Permitting such inexperienced Private Person to inspect and certify a 20,000
tonnes per hour capacity boiler itself is absurd. Such inexperienced Private Persons
need not be pampered by giving 100 percent of the Inspection fees to the detriment of
the functioning of State Government Boilers Department and also against public
interest and safety.
Therefore, it is submitted that the Government of India may kindly consider
sharing of the Inspection fees between the Private Person and Boilers Department.
The private person may be paid 50 percent of the inspection fees subject to a
maximum of Rs.15,000/- per boiler and the balance of Inspection Fees may be
paid to Boilers Department.
Yours truly,

(R. GOPAL)

From:
L. Srinivasa Raghavan,
ESSAR Engineers,
88, Chittu koil street,
Salem 636001.

To:
The Secretary,
Central Boilers Board,
Ministry of Commerce and Industry,
(Deptt. of Industrial Policy and Promotion)
Room No. 358, Udyog Bhavan,
New Delhi 110 107.

Letter Dated: 23 -05-2015.

Sir,
Sub: Fees Structure for Inspection of Boilers Gazette Notification
Suggestions - Submitted Regarding.
Ref : Gazette Notification No. G.S.R.285(E), dated 15-04-2015.
***
I submit following suggestions in respect of the Gazette Notification reference
cited.
It is submitted that the scales of Inspection fee is interlinked to the Fees
Sharing between a private competent person and the state Government and shall not
be decided in isolation.
I submit that a private competent person may be paid 50 percent of the
inspection fees subject to a maximum of Rs.15,000/- per boiler and the balance of
Inspection Fees may be paid to Boilers Department.
In this connection, I submit that functions of a Boilers Department is not
limited to inspection and certification of boilers. The Boilers Department has to
implement the total Act in the state which includes periodical visits to factories using
boilers to verify safe operation, deployment of certified manpower stipulated in the
Act, check use of uncertified boilers and also giving advice to the boiler owners
regarding proper operation and maintenance of their boilers. Further, Boilers
Department shall keep safe custody of Records, launch Prosecutions, enquiry against
complaints, investigate into accidents, examining appeals, granting exemptions,
conducting various examinations etc.. The number of Inspectors in the State are based
on number of boilers in use in the State and consequent work load and also inspection
fees received for inspection and certification of boilers. If the entire inspection fees of
a boiler is given to a Private Person who inspects and certifies a boiler, then the
Boilers Department will be deprived of its entitled revenue that is necessarily required
to maintain the Department. Further, it is not required that a Private Person shall be
paid more than Rs.15,000/- for inspection and certification of one boiler.

In the proposed fee structure, Inspection Fee is Rs.1,000/- for a small Boiler
whereas the fee for a 800 MW Boiler is Rs. 2,64,000/-. For inspection of a small
boiler in a remote corner of the State, the Boilers Department shall spend very much
more than the fee of Rs. 1,000/-. However, there will be savings in case of big Boilers.
On the whole, the expenditure becomes comparable to the Income. No private person
will be interested to take Rs.1,000/- and inspect small boilers going to every nook and
corner of the State. They will be interested only in inspecting big size boilers with
huge amount of Inspection fee. If this is allowed, there will be imbalance and
instability in the Financial Condition of Boilers Department.
Further, it is pertinent to state the capability of Private Persons as per the
existing Indian Boiler Regulations. In accordance to the existing Regulations, a
private Person having 5 years experience on a 1(one) Tonne per hour capacity boiler,
who passes theory examination conducted, is entitled to inspect and certify the fitness
of 20,000 tonnes per hour capacity Thermal Power Plant boiler. In case of Boiler
Inspectorates, such work is allocated to Inspectors having vast experience on such
boilers. Permitting such inexperienced Private Person to inspect and certify a 20,000
tonnes per hour capacity boiler itself is absurd. Such inexperienced Private Persons
need not be pampered by giving 100 percent of the Inspection fees to the detriment of
the functioning of State Government Boilers Department and also against public
interest and safety.
Therefore, it is submitted that the Government of India may kindly consider
sharing of the Inspection fees between the Private Person and Boilers Department.
The private person may be paid 50 percent of the inspection fees subject to a
maximum of Rs.15,000/- per boiler and the balance of Inspection Fees may be
paid to Boilers Department.
Yours truly,

( L. Srinivasa Raghavan )