Truck-to-Truck Propane Transfers

This article, related to truck-to-truck propane transfers, first appeared in the January/February 2015 edition of Propane Canada magazine.

Bulk Truck on BargeThere are times when there is a need to transfer liquid propane from one propane transport vehicle to another.  Typical uses for truck-to-truck propane liquid transfers are where a smaller tank truck is attached to a barge for island deliveries and specialty off-road tank trucks used for remote deliveries in the oil patch and mine sites.  The other times would be in cases of emergencies such as when there is a power outage at the bulk plant or a tank truck or cargo liner tank needs evacuating due to an accident.

Regulatory Requirements

The actual loading, transportation, and unloading of cargo liners and tank trucks fall under the Transportation of Dangerous Goods Regulations (TDG).  The loading aspect falls under the task of “offering for transport”.  The TDG Regulations do not specifically address truck-to-truck liquid propane transfers but provide general requirements that must be met during the loading and unloading process regardless of where the transfer takes place.  Therefore, one must ensure that all of the requirements legislated under the TDG
Regulations are met.

The TDG regulations, through the adoption of the CSA B620 Highway Tank and Portable Tanks for the Transportation of Dangerous Goods standard stipulate that when loading or unloading a cargo liner or tank truck, you must, during the transfer process, use the fail-safe brake inter-lock system and chock blocks at the rear wheels of both units involved in the transfer to ensure that both units involved do not move.

The CSA B620 general requirements require that the following conditions must also be met prior to starting the transfer process:

  • Connections must be inspected to ensure the propane liquid will be transferred into the proper connection;
  • The space available in the receiving tank must be verified to ensure that it is sufficient to accommodate the quantity of liquid propane to be transferred;
  • When remotely opening the internal safety control valve (ISC) , you are to have an unobstructed view of the cargo liner tank, delivery hose, and tank truck being filled, to the maxi-mum extent practicable; and
  • The periodic inspection or test intervals for tanks involved in the transfer must be up to date.

During the transfer process:

  • The driver is responsible for the transfer and must have been trained in propane hazards and emergency procedures;
  • The driver is to remain alert, within easy access of the supply and receiving flow shutdown controls, and to the extent possible, with the hose and both tanks in clear view except for brief periods to operate controls or to check the receiving tank;
  • When equipped with an off-truck emergency shutdown system, the driver must be in possession of the control at all times the tank valve is open, within 150 ft. of the tank and 25 ft. of the hose;
  • The driver must control the quantity of propane liquid being transferred; and
  • Immediately after the liquid propane has been transferred, all valves on both the supply and receiving tank must be closed and secured.

Provincial Regulations

The 2010 CAN/CSA BI49.2 Propane Storage & Handling Code requires that when offering for transport or transporting propane that the requirements of the TDG regulations must be followed.

The 2015 edition of the CAN/CSA B149.2 Propane Storage & Handling Code, to be published in August of 2015, also speaks to this issue.  The code stipulates that the contents of a cargo tank or cargo liner may be transferred to the cargo tank on another tank truck or cargo liner in an emergency.

The transfer of propane from a cargo tank or cargo liner for any purpose other than an emergency shall only be per-formed when specifically approved by the authority having jurisdiction.

It should be noted that for the purposes of the above provision, emergency means a sudden, urgent, usually unex-pected occurrence or occasion such as a general power failure, plant mechanical failure, incident, or vehicle mechanical failure requiring immediate action to protect or reduce the hazard to public safety.

Currently, two provinces, British Columbia and Ontario, have issued specific enhanced requirements over and above the TDG requirements as to how truck-to-truck propane liquid transfers are to be carried out in their provinces.

Until such time that the 2015 Code is adopted in your province, you must follow the TDG requirements if your province has not issued additional requirements.

British Columbia

British Columbia - BCSAOn December 30, 2010, the BC Safety Authority issued Directive # D-G5 101230 1 which outlines the operating procedure that needs to be in place for the tank truck to tank truck transfer of liquid propane along with the required training of the personnel performing this procedure.

General Details:
Clause 8.13.3 of the CAN/CSA B149.2-05 allows the transfer of propane product from one tank truck to another tank truck. In order to perform this procedure, an Operating
Procedure accepted by the BCSA must be in place that describes in detail how, when, and where this activity will take place, along with the specific training of the personnel performing this procedure in accordance with accepted industry practice.

Definitions:
Tank truck – A truck chassis and tank assembly as a complete unit for the bulk delivery of propane.

Cargo Liner – A vehicle that is used to transfer propane in which the tank constitutes the main structural member and that is towed by a separate motor vehicle.  Note: For the purposes of this Directive, the terms “Tank Truck” and “Cargo Liner” are interchangeable.

Filling Plant (bulk plant) – A facility, the primary purpose of which is the distribution of propane.  Such plants have bulk storage and usually have container filling and vehicle transfer facilities on the premises.  Bulk plants are considered part of this category.

Specific Details:
The above described Operating Procedure must be developed and delivered to the Provincial Safety Manager – Gas for acceptance.  Although Clause 8.13.3 of the CAN/CSA B149.2-05 allows for the transfer of propane from one tank truck to another, this activity shall not be performed by any individual who is not following an accepted Operating Procedure.

The only exception is when a propane emergency exists and where it is decided this practice will reduce the risk of accident or severity of an incident.  In this case, a Remedial Measures Advisor from the Liquefied Petroleum Gas Emergency Response Corporation must be in attendance and permission from the Provincial Safety Manager or their designate must be received.

Guideline To Required Operating Procedure:
The following are intended as the minimum requirements:

Filling plants must meet the operating requirements described in section 28 of the Gas Safety. Regulation (GSR) and comply with the CAN/CSA B149.2-05.

Tank trucks or cargo liners must comply with all requirements as contained in the CAN/CSA B149.2-05.

Tank truck to tank truck transfer must be performed only by personnel trained in the Operating. Procedure, qualified as required by section 5.2.10f the CAN/CSA B149.2-05, and authorized in accordance with section 4(1)(d) of the GSR.

The facility complies with all Local Government requirements.

Required clearances and related clauses as stated in the CAN/CSA B 149 .2-05 are adhered to during the transfer process:

  • The aggregate amount of propane contained in any offloading tank truck and the approved stationary tank(s) shall not exceed the maximum storage capacity of the stationary tank(s).
  • A designated filling plant (bulk plant) used to transfer propane from one tank truck to another tank truck shall be approved by the Local and Provincial authorities having jurisdiction.

Ontario

Ontario - TSSA Logo 01The Ontario Code Adoption Document FS-211-14, which became effective on Oct. 1, 2014, states that:

The contents of a tank on a tank truck or a cargo liner shall not be transferred to the cargo tank on another tank truck or cargo liner unless the operation is carried out at a filling plant.

Except for an emergency such as a loss of power due to unexpected natural weather, the transfer of propane from a cargo tank to another tank truck or cargo liner at the filling plant shall be approved.

TSSA will consider the following before granting an approval to transfer propane from a cargo tank to another tank truck or cargo liner at a filling plant:

  • The filling plant shall hold a valid license.
  • The filling plant shall have a permanent licensed storage capacity of at least the largest tank truck, or the amount of the truck to truck transfer shall be specifically approved by TSSA.
  • The transfer shall be performed by a Propane Truck Operator (PTO) certificate holder.
  • The risks associated with the operation, including mitigation measures and emergency procedures in place.
  • Sufficient space to accommodate both tank trucks without blocking any emergency exits shall be maintained; and
  • All requirements and minimum clearances of CSA B149.2-10, including emergency shutoff valves shall be complied with.

Protective Clothing

In closing, remember you are handling liquid propane that can cause serious freezer burns and injury if the liquid comes into contact with your skin. You must, therefore, wear the proper protective clothing and gloves when connecting and disconnecting propane hoses during truck-to-truck transfers.

Neoprene_Gloves_Orange Safety Goggles

Training Available

To address your training needs, the Fuels Learning Centre’s “Loading & Unloading Propane Cargo Liners (TO01)” and “Loading and Unloading Propane Tank Trucks (TO02)” courses include the latest requirements for truck to truck liquid propane transfers by providing the specific TOG and provincial requirements.

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History of PRV Service in Canada

This article is a consolidation of information and experience gained over the years. It is provided to assist the reader in having an understanding of the propane industry’s experience with pressure relief valves (PRVs) in propane tank service.

Current Regulations Impacting PRVs

The updated Annex H of the CAN/CSA B51-14 Boiler, Pressure Vessel, and Pressure Piping Code states that for:

  • Propane tanks over 2,500 USWG, the maximum PRV service interval is to be 10 years.
  • Propane tanks 2,500 USWG or less, the maximum PRV service interval is to be 25 years.

In Ontario, a formal inspection of the PRV is conducted on a “maximum” of a three-year frequency with a record of the inspection being maintained by the propane distributor.  At bulk plants and propane dispensing facilities, inspections including the PRVs are conducted annually.

As each province adopts the 2014 version of the B51 code into regulation, an implementation plan will be prescribed in order to provide tank owners appropriate time to come into compliance with the new requirements.

Types of Pressure Relief Valves in Propane Service

There are two types of pressure relief valves in propane service:

  1. External spring type where the “spring” is located “outside” of the tank.
  2. Internal spring type where the “spring” is located “inside” the tank.

Approximately 95% of the propane tanks in service are equipped with a single internal spring type pressure relief valve.

Larger capacity tanks (10,000 USWG and larger) are normally equipped with single or multiple external spring type pressure relief valves. Tanks equipped with multiple external spring type pressure relief valves do not have to be taken out of service to replace the PRVs.

PRV Operation

Propane is known as a “sweet gas”, having no corrosive or other deleterious effect on the metal of the containers or PRVs.

PRVs used in propane service are constructed of corrosion-resistant materials and are installed so as to be protected against the weather.  The variations of temperature and pressure due to atmospheric conditions are not sufficient to cause any permanent set in the valve springs.

PRVs are visually inspected each time a propane tank is filled as part of the filler’s responsibility to ensure the tank and all of the visibly attached components are in acceptable condition.  PRV inspection programs ensure that the pressure relief valves found in unacceptable condition due to damage, corrosion or weeping are replaced so as not to create a potential safety hazard.

Persons conducting the inspection of pressure relief valves on propane tanks are trained on how to inspect PRVs and tanks. The Fuels Learning Centre offers a training program to instruct bulk truck drivers, service technicians, and plant operators how to inspect PRVs and tanks – Visual Tank & PRV Inspection (SO02).

As previously stated the majority 95% of the PRVs in domestic service are PRVs with “internal springs” sitting within the propane vapour space, and are, therefore, not subject to corrosion or contamination.  The external components are protected from the elements by the use of protective caps, designed to keep moisture and debris out of the valve.  The protective cap is an item that a delivery driver checks to ensure it is in place and in good condition each time a delivery is made.  Missing or damaged caps are replaced by the delivery driver.

Current State

There are approximately 750, 000 propane tanks in Canada.  All of these propane tanks, regardless of size, are equipped with one or more PRVs.  The majority of the propane tanks are located at residences, farms, and commercial establishments.  Tanks are either owned by the propane consumer or leased from the propane company supplying the fuel.

Pressure Relief Valve Failure Statistics

We classify a pressure relief valve failure to be when the pressure relief valve failed to activate in an over-pressure situation or opened or partially opened in a non-overpressure situation.  The mechanical components of the valve failed to operate as designed.

Industry experience in Canada and the United States is an indicator that PRVs in propane service have experienced very minimal failure rates and should not be grouped or treated legislatively with PRVs in service with gases or fluids that may have an adverse effect and documented life expectancy on the PRV.

The propane industry is aware of only one reported failure on a stationary propane tank in which a used “external spring” pressure relief valve was reinstalled in a 2,000 USWG propane tank at a plant north of Kingston, Ontario in the mid-1990s.  The pressure relief valve partially opened when the propane tank was being filled.  This is one incident, in 25 years, that involved a type of PRV designed with an external spring, which represents approximately 5% of the PRVs currently in use.

As a result of this failure, a Directors Order was issued by the Technical Standards and Safety Authority (TSSA) instructing all propane marketers to inspect and replace as required pressure relief valves equipped with “external springs”.

Information received from the Ontario Fire Marshal’s Office (OFM) indicated the OFM was not aware of any specific cases involving propane PRVs.  Fire Marshall Office (FMO) statistics are gathered through fire and explosion reports received from the fire services and FMO investigators.  A propane release without fire would not be reported to the FMO.

The National Propane Gas Association (NPGA) in the United States has no statistics on PRV failures in stationary propane tanks.  NPGA staff are not aware of any incidents of this nature.  The National Board of Boilers and Pressure Vessel Inspectors in Columbus, Ohio was also not aware of any incidents involving the failure of PRVs in propane service.

The NPGA did, however, commission a study examining relief valve performance in cylinders.  These valves are smaller and more susceptible to damage.  Cylinders, unlike tanks, are meant to be portable and readily transported by the general public.  The study found there was broad scatter and inconsistency in relief valve performance regardless of valve age, manufacturer or source location.

PRV Manufacturers

There are three manufacturers of pressure relief valves currently used in Canada; Engineered Controls (Rego), Fisher Controls and Sherwood.  A review of the literature published by the three manufacturers shows that Fisher recommends a 15-year replacement cycle, while Rego and Sherwood recommend a 10-year replacement cycle.

Of the three manufacturers of pressure relief valves, one of them currently provides replacement parts for servicing PRVs in propane service.  Replacement of the pressure relief valve’s components still requires removal of the pressure relief valve from the tank so the components are accessible and can be replaced in a facility equipped with the proper tools and trained personnel.

The safe, useful life of a pressure relief valve can vary greatly depending on the environment in which it lives.

Pressure relief valves are required to function under widely varying conditions. Corrosion, aging of the resilient seat disk, and friction, all proceed at different rates depending upon the nature of the specific environment and application.

Predicting the safe useful life of pressure relief valves is obviously not an exact science. The conditions to which the valve is subjected will vary widely and will determine its useful life.

Rego states in their literature “The LP-Gas dealer must observe and determine the safe useful life of relief valves in his territory”.

Summary of PRV Failure in Canada

  • The majority (95%) of the PRVs in domestic propane service are PRVs with internal springs situated within the vapour space and not subject to corrosion, contamination, or dam-age.
  • There are no industry statistics (from Canada or the USA ) confirming that failure of PRV’s in propane service are a safety issue – only one documented incident in Ontario in the last 25 years.

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Bonding of Bulk Delivery Vehicles

This article, related to the requirements of bonding bulk delivery vehicles, first appeared in the 2014 Nov/Dec edition of Propane Canada Magazine.

Bonding Clamp

I have recently been involved in a project that looked at the regulatory requirements for bonding between a propane delivery vehicle and the propane container being filled.

The project’s scope included a review of the following documents:

  • Transportation of Dangerous Goods Regulations – Part 1 Classification, Clauses 2.13 & 2.14;
  • CSA-B622-03 Selection and Use of Highway Tanks, Multi-Unit Tank Car Tanks, and Portable Tanks for the Transportation of Dangerous Goods;
  • CSA-B620-09 Highway and TC Portable Tanks for the Transportation of Dangerous Goods;
  • CAN/CSA-B149.1-10 Natural Gas & Propane Installation Code Sections 7 & 8;
    Canadian Electrical Code;
  • National Fire Code of Canada Clause 4.1.8 (4.1.8.2);
  • Alberta OHS Code;
  • Alberta OHS Explanation Guide;
  • BC OHS Regulation;
  • NFPA 58 LP Gas Code Handbook Clauses 3.7.1.3 & A3.7.1.3;
  • United States OHSA Regulations; and
  • Static Electricity in the Propane Industry published by the Propane Education & Research Council (PERC).

Acts, Regulations, Standards & Codes

Transportation of Dangerous Goods Act & Regulations
1075 PlacardThe handling and transportation of propane is governed by the Transportation of Dangerous Goods (TDG) Act and Regulations. The regulations govern the construction of bulk transport vehicles with respect to the propane tank and attached components used in the transfer to or from the bulk transport vehicle.  The TDG Regulations also govern the loading and unloading of the bulk transport vehicle. The TDG Regulations classify propane as a Class 2.1 Flammable Gas.

CSA-B622-09
This Standard is adopted by the TDG Regulations and states under the heading of Loading and Unloading, that “a means of containment shall not be used where a fire hazard exists; precautions have been taken to prevent a difference in electrical potential between conductive surfaces and to ensure safe dissipation of static electricity through bonding or grounding, or both, as appropriate”.

Comment: The Standard stipulates that a container cannot be used where a fire hazard exists and requires that precautions be taken to prevent electrostatic discharge.

CAN/CSA-B149.2 Propane Storage & Handling Code
The Code applies, for purposes of this document, to the storage, handling, and transfer of propane and the installation of containers and equipment to be used for propane at customer locations.

The Code states that all tank trucks, tank trailers, and cargo liners must be designed, fabricated, and marked in accordance with the requirements of CSA B620.

The electrical requirements of the Code and the sections dealing with propane cylinder and tank filling are silent on the subject of controlling static electric charges during the propane transfer between the containers and a propane bulk transport vehicle. However, the Code does state that, where specified for the prevention of fire or explosion during normal operation, ventilation is considered adequate where provided in accordance with the provisions of the Code.

The Code requires that propane is transferred from one container to another by a person who is the holder of a certificate recognized by the authority having jurisdiction. The propane container must be filled in a location that is well ventilated.

Comment: For purposes of this document the CSA-B149.2 Code is silent and does not provide any regulatory requirements with respect to the issues of static electric charge during the process of transferring propane from a propane bulk transport to a consumer’s propane cylinder or tank.

The National Fire Code
The Code does speak to the control of static electric charge, however, the Code states that it does not apply to the transportation of flammable liquids or combustible liquids under the TDG Regulations.

Comment: For purposes of this document the National Fire Code requirements do not apply. The Code references the TDG Regulations when it comes to handling and transporting propane.

Canadian Electric Code
The objective of the Code is to establish safety standards for the installation and maintenance of electrical equipment. The scope of the Code covers all electrical work and electrical equipment operating or intended to operate at all voltages in electrical installations for buildings, structures, and premises. This includes factory built relocatable and non-relocatable structures, and self-propelled marine vessels stationary for periods exceeding five months and connected to shore supply of electricity continuously or from time to time.

Comment: For purposes of this document the Canadian Electrical Code requirements do not apply. The Code does not specifically address the issues of controlling static electric charge during the process of transferring propane from a propane bulk transport vehicle to a consumer’s propane cylinder or tank.

Alberta OHS Code
The Alberta OHS Code states that “if the work requires that the contents of metallic or conductive containers be transferred from one container to another, an employer must ensure that static electricity is controlled while the contents are being transferred.”

Comment: The OHS Explanation Guide when referring to Section 163 (2.1) states that “when transferred into or out of containers, flammable liquids can cause a static charge to build up on the container. This charge could create a difference in voltage potential between the containers, creating the possibility of an incendive spark igniting the vapours from the liquid. Effective control of static electricity can include actions such as grounding and bonding.”

The OHS Explanation Guide published on the Alberta Human Services website clarifies that the product under discussion in Part 10 Section 163 (2.1) is flammable liquids, not a flammable gas such as propane.

For purposes of this document the Alberta OHS Code Part 10 Section 163 (2.1) requirements do not apply. The Code requirements for bonding or grounding are for flammable liquids, not flammable gases such as propane.

B.C. OHS Regulation
The Regulation states that metallic or conductive containers used to transfer flammable liquids must be electrically bonded to each other or electrically grounded while their contents are being transferred from one container to the other.

Comment: While the B.C. OHS Regulations discuss the requirement for Flammable Gases in other clauses within the same section, the specific clause for grounding or bonding references Flammable Liquids only, not Flammable Gases.

For purposes of this document the B.C. OHS Regulations requirements do not apply as they only require bonding or grounding for flammable liquids, not flammable gases such as propane.

NFPA 58 Code
NFPA 58 is an American Code that is not mandated for use in Canada. That being said, NFPA Codes and Standards are often used when an equivalent Canadian Code or Standard does not exist or for comparison of requirements where a Canadian Code or Standard does exist.

On the subject of grounding or bonding, NFPA 58 Code stipulates that grounding or bonding is not required. The NFPA 58 Handbook explains “because liquefied petroleum gas is contained in a closed system of piping and equipment, the system need not be electrically conductive or electrically bonded for protection against static electricity.”

American Occupational Health & Safety Administration (OHSA) Regulations
These regulations state that “since liquefied petroleum gas is contained in a closed system of piping and equipment, the system need not be electrically conductive or electrically bonded for protection against static electricity.”

Observations

Static Electricity
Static electricity is generated when liquids move and come into contact with other materials. If the accumulation of static is sufficient, a spark may occur in the presence of a flammable vapour-air mixture, and ignition may result. Where a static spark and flammable mixture may occur simultaneously, suitable preventative measures are required to avoid ignition.

Static Electricity Danger 01Propane industry experience has shown that there have been a number of fires and explosions in which an electrostatic charge was the source of ignition. For this to occur liquid propane must be released at a high velocity, creating a mixture of liquid drops, then vapour, air, and water drops (due to condensation of water vapour in the air from the refrigerating effect of vaporizing liquid) can generate an electrostatic charge. This charge might be of sufficient energy to cause ignition of the mixture.

High-pressure propane liquid releases as described in the previous paragraph can occur when the pressure relieve valve (PRV) on a liquid-full propane container releases the liquid propane to the atmosphere due to over pressurization of the propane container. PRVs are installed within the 20 percent vapour zone on top of the liquid propane. This type of electrostatic charge is not created during the normal propane transfer process from a bulk transport vehicle to a consumer’s propane cylinder or tank.

Fire Hazard Analysis
Fire TriangleFor a fire hazard to exist, three components – fuel, air and an ignition source must be present. The ignition source must occur simultaneously with the fuel vapours and air being mixed at the point of ignition within the fuel’s range of flammability.  For propane, the flammability range is 2.4 to 9.5 percent volume in air, and requires an ignition temperature of 493⁰ to 549⁰ C. Below 2.4 per cent, the mixture is too lean to ignite. Above 9.5 percent, the mixture is too rich to ignite. Removing one or more of the three components removes the fire hazard.

Propane Liquid Transfer
The transfer of propane liquid between the bulk transport vehicle and the consumer’s cylinder or tank is a closed system with the delivery hose fill nozzle being threaded to create a leak tight seal to the fill valve of the propane container prior to the transfer of liquid propane taking place.

A minimal amount of controlled propane vapour/liquid is released to the atmosphere during the filling process through the fixed liquid level gauge. The gauge indicates when the propane container is filled to its maximum permitted volume. Once the container is filled, the gauge is shut off, stopping the release of propane vapour to the atmosphere.

Filling ASME Storage tankThe fill nozzle releases a legislated amount of propane liquid, approximately 2 to 4 cc to the atmosphere when the nozzle is first loosened from the container’s fill valve. This propane, along with any released from the fixed liquid level gauge, is well dispersed by the time the fill nozzle is removed from the fill valve of the container. If a static electric arc should occur at this point, there is no fuel to ignite.

Preventing Fire Hazards
Fire hazards, when filling customer’s propane containers, are controlled in several ways:

  1. Fill valves on the propane cylinders and tanks are made of brass, eliminating sparks from metal-to-metal contact;
  2. The metal propane-receiving cylinders and tanks are installed in contact with the ground;
  3. The actual transfer of liquid propane to the cylinder or tank is a threaded connection within a closed system, eliminating a static electric charge build-up due to liquid flow from arcing during the fill process;
  4. The B149.2 Code governs the distances that cylinders and tanks must be located from a source of ignition;
  5. Propane cylinders and tanks are filled outdoors in well-ventilated areas;
  6. Propane released during the filling process is low pressure and well dissipated by the time the fill nozzle is disconnected from the brass fill valve; and
  7. Operators are required to wear clothing which will not generate static electric charge while transferring propane.

The seven items listed above prevent the three essential components occurring simultaneously, which are needed to have an area or process classified as a fire hazard.
Therefore, the volume filling of a consumer’s cylinder or tank does not create a fire hazard. In addition, the existing operating procedures and equipment utilized satisfy the requirement that precautions are to be taken to prevent electrostatic discharge during the transfer process.

Conclusions

Current industry practices provide suitable preventative measures to avoid ignition of any propane released to the atmosphere during the filling of consumer propane containers. Therefore the need for bonding between a propane bulk transport vehicle and propane containers during the transfer process is not required.

There are no legislative requirements that require a person to bond between a propane bulk transport and a customer’s cylinders or tanks during the transfer process. The only legislated requirement to ground or bond is provided in the TDG Regulations where a fire hazard exists or precautions to prevent electro-static discharge have not been taken.

As stated above, current industry practices provide suitable preventative measures to avoid ignition of any propane released to the atmosphere during the filling of consumer propane containers. Therefore, the TDG Regulations do not apply and the need for bonding between a propane bulk transport vehicle and propane containers during the transfer process is not required.

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Keeping Regulatory Training Current

Most records of training for compliance training are valid for three years. A lot can happen in terms of regulatory requirements in three years. This article, summarizes information from two articles which first appeared in the Sep/Oct and Nov/Dec 2014 editions of Propane Canada Magazine. This article discusses the importance of ensuring you are keeping regulatory training current so that your employees remain properly trained.

 

As detailed in previous articles earlier this year the B149.1 – Natural Gas and Propane Installation Code and the B149.2 – Propane Storage and Handling Code have been extensively amended for publication by the Canadian Standards Association in 2015.

Also, the B149.3 – Code for the Field Approval of Fuel Related Components on Appliances and Equipment and the B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles will have new Codes published by the Canadian Standards Association in 2015.

The provincial adoption of the 2015 codes will start to take place sometime after January 2015.  Some provinces adopt the codes as soon as they are published, while other provinces adopt several months later.  It is, therefore, important that, as users of the Codes, you are aware of when your particular province will adopt the Codes that regulate the work you perform.

Ontario Adoption of Codes

Ontario - TSSA Logo 01Ontario has issued an Ontario Code Adoption Document (CAD) for both 2010 editions of B149.1 and B149.2 codes which become effective October 1, 2014. The CAD adopts many of the changes that will appear in the 2015 editions of the B149.1 and B149.2 codes.  The CADs are available on the TSSA website for download.  Significant changes made by the Gaseous Fuels amendment include:

  1. Permitting press-connect fittings;
  2. Re-classifying clothes dryers in accordance with the certification standard;
  3. Adding a new section regulating unvented heaters installed in livestock or poultry facilities;
  4. Incorporating Director’s Order FS-051-04 (re B-Vents not certified for exterior applications installed outdoors) into the code, for ease of reference; and
  5. Adoption of TSSA-MFSE-2014 for field approval of mobile food service equipment.

The Propane Storage & Handling Code Adoption Document adopts the 2010 edition of the Code and new requirements approved by the B149.2 and B149.5 Code Committees for the 2015 Code which are considered important to be implemented in Ontario now and addresses gaps in the current codes to enhance safety.

Major changes in this version include the following:

  1. New definitions added for “construction site” and “cylinder exchange”;
  2. New requirements for cylinder storage, including storage at construction sites and rooftops;
  3. New requirements for cylinder exchanges;
  4. Reiterating the need for compliance with Branch Standard #9 or a full risk and safety management plan for facilities in heavily populated or congested areas; and
  5. New certification requirements for valves, components, and accessories for propane vehicle conversion; replacing IGAC Protocol 01-97.

Code Updates Referred to in TDG Regulations

At the same time there is a new, 2014 edition of the B620 – Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods and B622 – Selection and Use of Highway Tanks, Multiunit Tank Car Tanks, and Portable Tanks for the Transportation of Dangerous Goods, Class 2.

While Transport Canada recently adopted the 2009 editions of the CSA/B620 and CSA/B622, the 2014 editions are completed and ready for adoption. It is important for one to keep abreast of the latest Codes and Standards as you know eventually any new requirements will become law.

Training Requires Updating

Once the Codes and Standards are adopted there will be an immediate training need for persons who perform work that is regulated by these documents.  In Ontario, this is October 1, 2014, which means that training programs that are used by the propane industry to train people must reflect the latest regulatory requirements as of October 1, 2014, for Ontario and in other provinces early next year.

This does create some issues as the current Record of Training (ROT) retraining requirements are once every 3 years, which means that people can actually be working in the field for up to 3 years before they are trained on the new regulatory requirements.

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Given that 2015 is the year for the issuance of new codes it may be advisable for employers in certain segments of the industry such as gas technicians, propane cylinder, cargo liner and bulk delivery and propane construction heating, to have their employees trained on the new requirements rather than wait until such time that the person’s ROT is up for renewal.

One of the largest impacts is going to be in the construction industry where the requirements for the storage and use of cylinders have been extensively amended. If your cylinder delivery driver is not aware of the new requirements he could inadvertently create a non-compliance situation which could result in fines and disruption of service to your customer.

For example, Ontario Director’s Order FS-095-06, issued November 2013, states that “when distributors provide fuel to tanks or cylinders not connected to the premises, the distributor shall ensure that the fuel storage is compliant with Ontario Regulation 211/01”.

If not aware of the new requirements, the contractor who uses the propane cylinders and construction heaters can also inadvertently create a non-compliant situation which could result in fines and impact the ongoing construction of the building. The contractor could also be at a disadvantage from an efficiency perspective if he does not know the new requirements with respect to the use and storage of propane cylinders on rooftops.

Another example is the increased size of cylinders which may be stored in cylinder exchange cabinets. Due to demand from the RV industry, the maximum was changed from 20 lb. 30 lb. cylinder sizes. The cabinet maximum capacity of 500 lb. (25 x 20 lb., or 16 x 30 lb., or a combination thereof) has been maintained. If you were not aware of these new requirements you could be missing out on an opportunity to serve the recreational market with the larger propane cylinders.

The CSA-B620-14 has new requirements for “off truck emergency shutdown system” to include tanks in non-metered propane delivery as well as engine shutdown when the engine air intake senses flammable vapors. When adopted, drivers of unmetered deliveries need to be trained in the inspection and use of these new requirements

It does not make economical or practical sense to train people with outdated training programs. As indicated by the examples above it is crucial to one’s business that employees are trained in understanding the latest regulatory requirements.

Status of publication of the 2015 series of CSA Codes and Standards

2015 B149.1 – Natural Gas & Propane Installation Code
The committee last met on June 12, 2014. Public Review took place from March 12 to May 12, 2014; and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting of the Technical Committee (TC) will take place in February 2015 if needed for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B149.2 – Propane Storage & Handling Code
The committee last met on June 11, 2014. Public Review took place from March 12 to May 12, 2014, and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting will take place in February 2015 if needed, for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B139 – Installation Code for Oil Burning Equipment
The Technical Committee last met on June 24-26, 2014 to disposition Public Review comments and finalize the technical content in the Draft. The ballot for the approval of the Code took place from Sept. 3 to Oct. 3, 2014. The scope has been changed to include fuel oil storage tanks of all sizes including underground tanks. The Code is now divided into two major parts, B139.1 – Large Installations and B139.2 – Residential and Small Commercial Installations. Publication is scheduled for April 1, 2015, in both English and French.

Gas Appliances and Related Accessories
The CSA Gas Technical Committee held a joint meeting with the U.S. Z21/83 Technical Committee on Sept. 30. 2014. The following new standards were approved:

  • CSA 3.8, Gas-fired Equipment for Drying Crops;
  • Z21.10.1/CSA 4.1, Water Heaters Volume 1; Z21.10.3/CSA 4.3, Water Heaters Volume Ill;
  • Z21.54/CSA 8.4, Gas Hose
  • Connectors;
  • Z21.19/CSA 1.4, Refrigerators Using Gas Fuel;
  • Z21.56/CSA 4.7, Pool Heaters; and
  • Z21.58/CSA 1.6, Outdoor Cooking Appliances.

Oil Burning Appliance Standards (B140 Series, B211 & B212)
The B 140 series of Standards have been reaffirmed; however, they are in need of review and updating. The last Technical Committee meeting was held on May 2, 2012. CSA will be looking at reconstituting the TC to begin work on these documents.

Carbon Monoxide Detectors Standard
The Technical Committee has been reinstituted for a new edition of the CSA 6.19 standard. The TC’s first meeting was Sept. 25, 2014, with the publication date projected for September 2016.

Introduction of the Fuels Learning Centre

Recent events provided a business opportunity for me to partner with Bill Egbert in the creation of a new training provider for the fuels industry.  The company is called Fuels Learning Center Limited (FLC) which will not only provide training modules to the propane industry but also the fuel oil and natural gas industries.

Fuels Learning Centre

As most of you are aware Bill was for many years, the General Manager of the Propane Training Institute. I was under contract to the Canadian Propane Association to write new training programs and update existing programs with the latest technical and regulatory requirements.

The Fuels Learning Centre currently has nine provincially approved training courses which reference the latest regulatory requirements of the Codes and the Standards to be adopted:

These programs, when successfully completed, will provide the provincially acceptable ROT and where required the TDG qualifications for persons who need to be trained in the handling and use of propane.  We have been able to streamline these programs to focus more on what a person needs to know and less of what is not required to know to safely perform their tasks.

 

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Documenting Compliant Propane Installations

This article, explaining the importance of documenting compliant propane installations,  first appeared in the 2014 Jul/Aug edition of Propane Canada Magazine.

The CSA B149.1 Natural Gas & Propane Installation Code requires that a propane technician must ensure that appliances, accessories, components, or equipment installed by him/her are installed in compliance with the Code. The person initially activating the appliance must also validate that the appliance is left in safe working order.

One issue not spelled out in the Codes is: “How do you prove years later, that you left a compliant safe operating propane installation?” Companies that operate under a due diligence umbrella have processes in place that include documenting the installation to show that, at the time of installation, the installation was completed by a qualified employee, it was done so in compliance with the Code, and the appliances were left in safe operating condition.

Personal due diligence refers to actions that are reasonable under the circumstances and that would be expected from a reasonable person. In other words, it means taking responsibility for your actions, making your own decisions, and being able to explain logically your actions and decisions. The role of the propane technician in the due diligence process is to make the decision to use approved materials to install the appliances, piping, tubing, fittings, regulators, venting systems, etc., and to install only approved appliances for the purpose for which they were designed.

Using Approved Appliances

The Code defines “approved” as being acceptable to the authority having jurisdiction (AHJ). The Code identifies which materials are acceptable with respect to piping, tubing, fittings and venting systems.

These materials are acceptable to the AHJ when the Code is adopted by provincial or territory regulation. An appliance, equipment, a component or an accessory is acceptable to the AHJ if it bears the label or symbol of a designated testing organization or a label or symbol authorized by the AHJ certifying that it complies with an approved standard or laboratory test report. Designated testing organizations are identified in the provincial or territory regulations that adopt the Codes.

Approval Labels from Recognized Testing Organizations

You should be familiar with the labels and symbols of the designated testing organizations authorized by your provincial or territory AHJ. Designated testing organizations that certify appliances and components are:

  • Canadian Standards Association (CSA)
  • Intertek
  • Underwriters Laboratories of Canada (ULC)
  • Underwriter Laboratories Inc. (ULI), which is US based. The ULI label must bear a small “c” to show that the approval designation is acceptable in Canada.

CSA SymbolIntertek logoUL Certified

The use of approved materials, appliances and components, and installing them in compliance with the Code and manufacturers’ installation instructions, shows that due diligence has been applied in the physical aspects of the installation.

Written documentation, supported by digital photographs is a good way to record that the physical aspects of the installation complied with the Code and manufacturer’s installation Instructions. A propane technician needs to verify that the propane supply pressures are correct and that the appliances operate as designed. Cycle the appliances several times to make sure the operating and safety controls are functioning properly.

The weak link in proving that a propane installation was compliant and that the appliances were left in a safe operating condition is the failure to complete the documentation in a manner that accurately records the essential elements of the installation’s operating characteristics. Even though the physical aspects of an installation may have been completed to Code, the lack of accurate documentation can, at a later date, bring the integrity of the entire installation into question.

Questions that are often raised after an incident, in cases where documentation is inaccurate or lacking, is if the propane technician, in fact, completed the pressure test of the piping or tubing system, or if the installer actually verified the propane supply pressures and confirmed the operating and safety controls functioned as intended, etc.

To prove that an installation was compliant and appliances were left in safe operating condition, my advice to propane technicians is to take a few photographs and to apply as much due diligence in completing the written documentation as in performing the physical aspects of the installation.

Use a Checklist as Part of Documentation

While certified propane technicians know how to install appliances they must be properly trained on the company’s documentation which records the installation and setup of the appliances. Most companies use a checklist type of form to record the installation and appliance setup.

warranty-iconA checklist is a greatly condensed way of identifying the items that must be checked. However, a checklist that lists “yes”, “no” or “n/a” as the answer to specific questions about the appliance installation can lead to misunderstandings if the technician is not trained on the use of the particular form. The checklist form needs to be supported by a document that speaks to all of the questions on the form. The support document is used to identify specific code sections, provide guidance when assessing an installation, and provides triggers for the technician to investigate further.

Appliances that use interior air for combustion present one of the most complicated issues a propane technician must address; is there sufficient combustion and ventilation air in the space the appliance is installed?

The checklist supporting document can provide guidelines, examples, and references which the propane technician can use to determine if, indeed, the space provides sufficient air to meet the needs of the appliance.

From a corporate perspective, it is important that the documentation your company uses to document appliance installations is adequate to prove that a compliant installation was completed and the appliance was left in safe operating condition.

The propane technician needs to complete the documentation accurately addressing all questions. Checkboxes left empty leave one wondering if the technician addressed the question. If the question is not applicable to the particular installation then indicate as so, rather than leaving a blank. Finally, take a few digital photographs and put them in the customer file.

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Changes in 2015 Version of B149.2 Propane Storage & Handling Code

This article, related to Changes in 2015 Version of B149.2 Propane Storage & Handling Code, first appeared in the May/June 2014 edition of Propane Canada magazine and was updated in October 2014.

In 2015, the Canadian Standards Association (CSA) will issue new versions of the B149 Codes scheduled for release by CSA in August 2015. The 2015 Codes are meant to replace the current 2010 Codes in use. For the propane technician working in the field, it can be a challenge to determine what has been deleted, added or amended, since the last Code was published.

This article provides a summary of the clauses that have been amended, added and deleted in the CAN/CSA B149.2 Propane Storage and Handling Code.

B149.2-10 CoverThe 2015 editions of the Codes are the completion of a 5-year code cycle that CSA uses to keep the Codes updated to address new technologies, new installation materials, and changing building environments. The committees who update the codes also consider changes to improve the usability of the document. Many of the amendments consolidate subjects so that a gas technician has to only look in one place for the requirements of a specific component. For example, the requirements for appliance installation, regardless of where the appliance is being installed, home or RV, are now in the CAN/CSA B149.1 Natural Gas & Propane Installation Code instead of being split between this code and the CAN/CSA B149.2 Propane Storage & Handling Code.

The adoption of the 2015 Code is done by each province and territory separately with some Authorities Having Jurisdictions (AHJ) adopting the Codes immediately, and others taking several years. A person must use the most current Code adopted in their Province or Territory for new or upgrading propane installations. In addition, each Province or Territory can, when adopting the Codes add, amend or delete clauses from the Code by way of their Code Adoption Document (CAD).

Ontario Adopts 2015 Code

Ontario - TSSA Logo 01Since this article was first published in Propane Canada magazine, the Technical Standards & Safety Authority (TSSA) issued an amendment to their Propane Code Adoption Document which is effective October 1, 2014. TSSA felt that new requirements in the 2015 version of the Code are considered important to be implemented in Ontario right away and addresses gaps in the current Code to enhance safety. In particular, the new requirements pertaining to cylinder use and storage at construction sites will become effective as of October 1, 2014.

The following is a summary of revisions included in the 2015 edition of the CAN/CSA B149.2 – Propane Storage & Handling Code.

Section 1 – Scope

The scope of the CAN/CSA B149.2 Propane Storage and Handling Code has been amended to remove sections that were transferred over to the CAN/CSA B149.1 Natural Gas and Propane Installation Code; namely the installation of appliances, equipment, components, accessories, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles when propane is to be used for fuel purposes;

The scope has also been amended to include maintenance as a requirement for containers and equipment to be used for propane at customer locations, in distribution locations, and filling plants.

The section of the scope that identifies areas to which the Code does not apply was also amended to exclude transportation of propane and the manufacture, selection, and use of standardized means of containment under Transportation of Dangerous Goods (TDG) Act and Regulations

Item (j) of the exclusions was amended to exclude any equipment extending downstream from the inlet to any container pressure regulator, commonly referred to as the 1st stage regulator. The propane system downstream of the 1st stage regulator outlet is governed by the CAN/CSA B149.1 Natural Gas and Propane Installation Code.

The rationale for this change was that regardless of who owns the propane storage container, the propane distributor or customer, the container must be maintained. Safety requirements for systems and components should not be different for various owners.

Item (k) of the exclusions was also amended to exclude the installation of propane fuel system components and tanks on vehicles covered by CAN/CSA B149.5 Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles.

Section 3 – Definitions

Section 3 of the Code provides definitions of terms used within the Code. A number of definitions were added or amended in the 2015 edition of the CAN/CSA B149.2 Propane Storage and Handling Code.

Aerosol Container (new)
A new definition for “Aerosol Container” was added which is to simplify parts of the Code and close the loophole created where restrictions are made on the manufacture, use or storage of TC 2P and TC 2Q specification aerosol containers. The same amendments are not carried over to include US DOT corresponding specification aerosol containers which are permitted by the TDG Regulations under specific conditions. New standards and specifications for aerosol containers under the TDG Regulations are planned.

A note added to the definition for aerosol containers states that pressure limits on aerosol containers in the TDG Regulations (1245 kPa at 55°C for 2Q and 1105kPa for 2P) exclude the use of 2P and 2Q containers for pure propane.

Connected For Use (new)
A new definition for “Connected For Use “was added to clarify whether or not cylinders that are properly connected to an appliance that is not running and which may or may not be turned on for use, are not in storage. Properly connected cylinders that remain connected for current, intermittent or future use, would not be subject to storage requirements.

Construction Site (new)
A new definition for “Construction Site” has been added to indicate that the handling of cylinders and propane apparatus in use or in storage at construction sites are subject to significantly differing situations.

Container
Definition of “container” was amended to remove reference to NGV. The term NGV (Natural Gas for Vehicle) is used many times in the B149.2, which is a code dedicated to propane.
NGV references are now located in the CAN/CSA B149.1 Natural Gas and Propane Installation Code. Also, the definition was modified to include the aerosol containers.

Container Refill Centre (Propane Service Station)
The definition for Container Refill Centre (propane service station) was amended to include “dispensing system” which is a new definition within the Code.

Dispensing System (new)
New definition “Dispensing System” and an amendment to the definition of “Kiosk” was created to clarify confusion within the code regarding exactly what a “dispenser” is. As a result, the word is used in various contexts throughout the code. It is proposed to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Filling Plant
The definition for “Filling Plant (bulk plant)” was amended to remove the words “and” & “or” so that the definition now states that such plants have bulk storage or container filling or vehicle transfer facilities on the premises.

The rationale provided stated it had recently come to the committee’s attention that there is a practice of transferring from rail cars to cargo liners, bulk trucks or other mobile storage vehicles, outside of a bulk plant. Presently there are no rules for how this is to be done in a safe manner. This proposed clause uses wording very similar to the accepted wording for truck-to-truck transfers since the two situations are somewhat analogous (see also revisions for 7.18.3).

Kiosk
New definition “Dispensing System” and an amendment to the definition of “Kiosk” to clarify confusion within the code regarding exactly what a “dispenser” is. As a result, the word is used in various contexts throughout the code. It is proposed to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Mass Gauge
The definition “Mass Gauge” was amended to remove the potential for the reader to conclude that there are no requirements for mass measurement gauges.

Propane Dispenser (new)
New definition for “Propane Dispenser” as part of a series of definition amendments to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Refuelling Station
The definition for “Refueling station” and “remote Dispensing Device” were deleted as they refer to natural gas installations, not propane. The definitions now exist in the CAN/CSA B149.1 Natural Gas and Propane Installation Code.

Tank
The definition for “Tank” was amended to remove reference to tanks used for NGV installations.

Tank Heater
The original definition for “Tank Heater” has been amended as well as a new definition to take into account indirect and direct gas-fired tank heaters.

Vapourizer
There are several types of vapourizers defined in the Code. Not all vapourizers are appliances as defined under the term “appliance” in B149.2 section 3. Electric vapourizers, for example, do not convert LP-Gas to useable energy. They use electricity to convert LP-Gas from the liquid phase to the vapour phase. Meanwhile, all direct-fired vaporizers are considered to be appliances by their very nature. The amendments add a definition to clarify the term “direct gas-fired tank heater” which is used in section 9 – Vaporizers.

Section 5 – General requirements for propane and propane equipment

Section 5 of the Code describes the general requirements for the storage and handling of propane and propane equipment. Changes to Section 5 in the 2015 edition affect the following sub-sections:

  • 5.2 Container filling
  • 5.10 Propane container restrictions

The following describes the specific parts within Section 5 which have changed within the 2015 edition of the Code.

Revision to Clause 5.2.3
This Clause is an exemption clause that exempts propane from being put into containers specifically designed for butane. The clause has been amended to provide the Transport Canada and CSGB Standards for cylinders that can be used for propane.

Revision to Clause 5.2.5
This clause was amended to clarify what standard a cylinder used for propane must meet for it to be used for anhydrous ammonia.

Revision to Clause 5.10
This clause originally restricted cylinders from being installed under any fire escape, stairway, or ramp used as a means of egress from a building. The clause has been amended to read “container” so the restriction applies to cylinders and tanks. As a result of this revision, Clause 6.5.13 was deleted.

Section 6 – Cylinder Systems

Section 6 of the Code describes the requirements for cylinder systems. Changes to Section 6 in the 2015 edition affect the following sub-sections:

  • 6.1 Requirements for cylinders
  • 6.2 Liquid level gauges on cylinders
  • 6.4 Purging and filling of cylinders
  • 6.5 Storage and use of cylinders at locations other than filling plants
  • 6.6 Transportation of cylinders
  • 6.8 Rooftop installation of cylinder systems

In addition, the following tables were amended in the 2015 edition:

  • Table 6.3 Cylinder storage clearances
  • Table 6.4 Storage of non-refillable cylinders in mercantile occupancies
  • Table 6.5 Storage of non-refillable cylinders in the back stock (warehouse) area of mercantile occupancies

Revision to Clause 6.1.1
This clause specified that cylinders must be manufactured, tested, inspected, and marked in accordance with both CAN/CSA B339 Cylinders, Spheres, and Tubes for the Transportation of Dangerous Goods code and the TDG Regulations. The clause was amended to remove the TDG Regulations requirement so that the CSA is the prescribed standard to which cylinders must be inspected and qualified. The rationale for this amendment was that when a new edition of CSA B339 is published, the TDG Regulations and this Code may find themselves referring to different editions of CSA B339 potentially leading to confusion.

Revision to Clause 6.1.2
This clause was amended to harmonize with US requirements. NFPA 58 -2008 states that cylinders with 4 lb. (1.8 kg) through 40 lb. (18 kg) propane capacity for vapour service shall be equipped or fitted with a listed overfill protection device; the current Canadian requirement starts at zero, not 4 lbs. (1.8 kg) as in the US.

Revision to Clause 6.1.5
This clause has been amended to remove the previous requirements for the 10-year cylinder inspection and requalification from the Code. The clause now states that refillable cylinders shall not be refilled if they are due for requalification as prescribed by requirements of the CSA B339.

In addition, the exemption for cylinders in excess of 240 lb (110 kg) water capacity with a protective dome cover not requiring PRV replacement was removed to be consistent with the requirements of B339. This means that all cylinders built to B339 standards must have the PRV replaced during the 10-year requalification period.

Revision to Clause 6.1.7
This clause was amended to require that cylinders have a pressure relief valve installed that meets the requirements of CAN/CSA B340 – Selection and Use of Cylinders, Spheres, Tubes, and Other Containers for the Transportation of Dangerous Goods, Class 2.

New Clause 6.1.16
This clause clarifies requirements for storing cylinders.

New Clause 6.2.3
This clause was added to mirror the markings for a dip tube in CSA B339.

Revision to Clause 6.4.5
This clause was amended to clarify that Specification TC-39M and aerosol containers cannot be filled.

Revision to Clause 6.5.1.4
The clause deals with the number of aerosol containers and TC-39 non-refillable cylinders that can be stored in a dwelling. The clause was amended for correctness.

Revision to Clause 6.5.1.4
This clause was amended to remove maximum temperature to which a cylinder can be exposed. The temperature requirement is now located in new Clause 6.1.16.

Revision to Clause 6.5.1.14
This clause was amended to permit the storage of cylinders on roofs in accordance with Clause 6.5.3.9.

Revision to Clause 6.5.1.15
This clause was amended extensively to update guidelines for cage construction to reflect current acceptable practices and to provide clear minimum design criteria that allow innovation. The changes also ensure only well-ventilated cages are used. The present location of the affected clause is under 6.5.2 Cylinders stored outdoors for commercial or industrial use or sale; however, propane cylinders can be placed in cabinets or other containers on many other sites. Therefore in addition to providing guidance on how to properly construct just industrial and commercial cabinets, the clause will now have an effect on any storage cabinet housing propane. As a result of the amendments to Clause 6.5.1.15, Clause 6.5.2.4 was deleted from the Code.

New Clauses 6.5.2.7 and 6.5.2.7.2
These clauses have been added to address any confusion regarding the sighting and signage requirements for cylinder exchange equipment. Over the last ten years, there has been a rapid increase in the use of LP-gas cylinder exchange stations for consumer propane tanks. The next step of providing better accessibility to propane tanks was the introduction of automated exchange machines.

The code needed to address the requirements for automated exchange operations. The new requirements also address risks associated with the absence of the attendant so that automated operations can be conducted safely. The Clause wording is consistent with the National Fire Code proposals and NPGA dockets.

Revisions to Section 6.5.1
This section, which addresses cylinders not connected for use at construction sites has been extensively amended to clarify acceptable “outdoor” storage by identifying proper and safe storage options that reflect conditions on construction sites. It is based on the hazards rather than focusing on the location alone.

Revision to Clause 6.5.3.2
This clause has been amended to address specific requirements for cylinder storage on construction sites which also address worksite hazards.

New Clause 6.5.3.8
This new clause provides the requirements to be followed on construction sites when moving cylinders between floors and the storage of cylinders on roofs.

Revision to Clause 6.5.3
This clause has been amended to require that non-refillable cylinders be packaged in accordance with CSA B340 and marked in compliance with the provisions of the CSA B339.

Revision to Section 6.6
Transportation of cylinders has had a note added to the beginning of the Section stating that the transportation of propane falls under the TDG Regulations and that activity under the TDG Regulations must be satisfied when transporting cylinders.

Deletion of Clauses 6.6.2 through 6.6.7.
The requirements for protection of valves are prescribed in detail in Clause 4.2.2 of CSA B340-08. The clauses were deleted to avoid overlapping and potentially conflicting requirements.

Revision to Section 6.8
This section has been amended to have propane cylinders installed on the uppermost flat roof of a building. This amendment addresses cases where a housing building is in the shape of a stair, where the roof of one level is a terrace for the level above. Being on the roof of a typical building, in the case of a fire, no one has to cross the level where the cylinders are installed. This level of protection and isolation is lost in the case of a step-shaped building.

Revision to Table 6.3
The table was amended to delete the 20 lb. maximum cylinder size that may be stored at a cylinder exchange. The rationale provided is that due to a demand from RV customers, 30 lb. cylinders are being offered at exchange locations and that the safety concerns of 30 lb. cylinders are not different from those of 20 lb. cylinders. Maintaining the cabinet maximum capacity of 500 lb. (25 x 20 lb., or 16 x 30 lb., or combination thereof) maintains the same risk and requirements of a single full exchange cabinet.

Revisions to Tables 6.4 and 6.5
These tables were amended to clarify the volume of propane in non-refillable cylinders that can be stored in retail locations. The changes replace each phrase “net weight of cylinders” in tables 6.4 and 6.5 with “quantity of propane”.

Section 7 – Tank Systems, Filling Plants, and Refill Centres

Section 7 of the Code describes the requirements for tank systems, filling plant and refill centres. Changes to Section 7 in the 2015 edition affect the following sub-sections:

  • 7.1 General
  • 7.4 Excess-flow and back check valves
  • 7.8 Installation of underground tanks
  • 7.9 Discharge from tank relief valves
  • 7.10 Location of consumer tanks
  • 7.17 Container filling locations with provisions for container storage
  • 7.18 Filling plants served by rail
  • 7.19 Container refill centres
  • 7.20 Dispensing System
  • 7.22 Operations and Maintenance Procedures
  • In addition, Table 7.5 (Location of Tanks at Filling Plant and Container Refill Centres) was amended in the 2015 edition.

Revision to Clause 7.1.10
When the liquid connections of horizontal or vertical tanks are manifolded together, the tops of the tanks shall be at the same horizontal level. Tanks that have liquid interconnections shall be installed so that the maximum permitted filling level of each container is at the same elevation. Vertical containers used in liquid service shall not be manifolded to horizontal containers. Vertical containers of different dimensions shall not be manifolded together. This revision addresses the concern that when two horizontal tanks are connected together by a common liquid line there may be instances when the larger of the two tanks is overfilled when the top of these tanks are not at the same horizontal level.

New Clause 7.4.8
This clause requires that any line utilized for product flow must have a flow capacity greater than the rated flow of the excess flow valve protecting the line.

Revision to Clause 7.8.8
A note was added to the clause recognizing that non-metallic tubing installed between metallic piping and an underground tank is acceptable as a dielectric joint. When a non-metallic line is used (typically polyethylene tubing) between the first stage regulator at the tank and the second stage regulator attached to a building there is no function served in using a dielectric union or other isolating fitting, because the polyethylene tubing is non-conducting and serves the purpose of isolating the tank and its fittings from the metal components of the building.

Revision to Clause 7.8.12
This clause has been amended to provide clearances for underground propane tanks with a capacity of 2,000 USWG or less from the building, property line, other underground services, and tanks.

New Clause 7.8.18
This clause provides underground clearances for tanks greater than 2,000 USWG.

New Clause 7.9.3
This clause now permits the discharge of a safety relief valve and other vent devices or lines to be vented within the dome, housing or curb box on underground propane tanks with a capacity of 2,000 USWG or less.

Revision to Clause 7.10.2
This clause has been amended to allow manifolded tanks with a capacity less than 125 USWG (475 L). The aggregate capacity is not used when determining separation distance to an important building, a group of buildings, or line of adjoining property that can be built upon. The largest single container in the manifolded system is used to determine the clearances required in Table 7.4.

Revision to Clause 7.10.3
This clause has been amended to remove the word “aggregate” from the clause. This provides clarification around the clearances required for tanks manifolded together to make a system as allowed in 7.10.2. This addresses issues in metropolitan areas where the 10-foot clearance to property lines cannot be met. Currently, on a bank of four 123 USWG (454 L) tanks technicians are basing their tank sets on the aggregate capacity of over 125 USWG (475 L) up to and including 1000 USWG (3800 L).

Revision to Clause 7.17.3
This clause has been amended to add the clarification that section 7.17.3 also applies to buildings housing vapourizers and that pressure relief discharges need to be located outside the building,

New Clause 7.18.3
This clause addresses the transfer of propane at a filling plant from a railcar to tank truck, tank trailer or cargo liner. The clause requires that Clauses 7.12 to 7.18 and 7.19.4 be met and that the approval of the authority having jurisdiction is needed. The clause addresses the issue of transferring from rail cars to cargo liners, bulk trucks or other mobile storage vehicles, outside of a bulk plant. The clause uses wording very similar to the accepted wording for truck-to-truck transfers since the two situations are somewhat analogous.

It should be noted that there could be confusion in terms of which authority has jurisdiction – the local Authority or Transport Canada since the unloading of railcars typically falls within the jurisdiction of Transport Canada.

New Clause 7.19.4.4
This clause permits the use of barriers other than those listed if it can be demonstrated that they provide an equivalent level of protection.

Revisions to Clause 7.20.2
This clause has been amended to permit additional methods to protect remote dispensing devices.

New Clauses 7:22 to 7:22.4.2
These new clauses prescribe operations and maintenance procedures. The purpose of the new clauses in the code is to provide a minimum standard for the operation and maintenance of propane facilities and equipment. The new clauses apply to tank systems, filling plants, container refill centres and other facilities where liquid propane is piped to a vapourizer or process.

Because there are many variables, it is not possible to prescribe a set of operation and maintenance procedures that will be adequate from the standpoint of safety in all cases, so the new clauses establish a baseline or minimum standard.

Revision to Table 7.5
This table has been expanded to provided distances for tanks up to 90,000 uswg. The rationale for this expansion is that with installations over 10,000 USWG, the local authorities use the table in the NFPA 58. This change is to provide the tool to the local authorities and to harmonize minimum distance requirements with NFPA 58.

Section 8 – Tank Trucks, Tank Trailers, and Cargo Liners

Section 8 of the Code describes the requirements for tank truck, tank trailer, and cargo liners. Several sub-sections and clauses have been deleted in the 2015 version of the code since the activities described fall under the jurisdiction of Transport Canada. The deleted sub-sections and clauses have been moved to the CAN/CSA B620 – Highway Tanks and TC Portable Tanks for the Transportation of Dangerous Goods code as follows:

  • 8.2 Tank equipment on tank trucks, tank trailers, and cargo liners
  • 8.3 Pumps and compressors on tank trucks and cargo liners
  • 8.4 Piping, tubing, hose, and fittings on tank trucks, tank trailers, and cargo
  • 8.6 Braking systems and chock blocks
  • 8.7 Exhaust systems
  • 8.9 Fire extinguishers
  • 8.10 Tank truck and cargo liner lettering
  • 8.11 Towing tank trailers
  • 8.12 Filling of tank trucks, tank trailers, and cargo liners

Changes to Section 8 in the 2015 edition of the Code affect the following sub-sections:

  • 8.1 General
  • 8.12 Filling of tank trucks, tank trailers, and cargo liners
  • 8.13 Operation of tank trucks, tank trailers, and cargo liners
  • 8.14 Parking vehicles used to transport propane
  • 8.18 Repair or servicing in repair garages

Revision to Clause 8.1.1
A note has been added to this clause to explain that the requirements for design, manufacture, repair, inspection, test, marking, selection, and use of tank trucks, tank trailers, cargo liners, and portable tanks for transporting propane are prescribed by the Transport Canada’s Transportation of Dangerous Goods Regulations.

Revision to Clause 8.12.3
This clause was amended to disallow truck to truck transfers unless it is an emergency or specifically approved by the AHJ. This amendment allows the Authority Having Jurisdiction to approve truck-to-transfers in certain geographic regions within Canada where truck to truck transfers are necessitated by the need to deliver propane under uniquely difficult circumstances such as:

  • Coastal and island delivery where barges are used to transport propane bulk trucks to customer sites. Bulk trucks are refilled without being removed from the barge.
  • Delivery of propane to wellheads where the rugged terrain prevents highway bulk trucks from traveling directly to the propane tank locations. Bulk trucks specifically designed to handle the terrain are refilled by highway bulk trucks.
  • Delivery to logging camps and asphalt plants within the interior at certain times of the year requires that truck to truck transfers take place between the highway bulk truck and bulk trucks designed to travel rough unassumed interior roads.

New Clause 8.12.4
This new clause allows the content of a rail car may be transferred to a tank truck, tank trailer or cargo liner other than at a filling plant when approved by the authority having jurisdiction.

It should be noted that the code refers to the provincial regulator, not Transport Canada, who actually has jurisdiction over this practice.

Deleted Clause 8.13.1
The clause was deleted since the requirements for the operation of highway tanks (tank trucks, tank trailers and cargo liners) are within the scope of the TDG Regulations and included in CSA B620, CSA B621 and CSA B622 for all highway tanks.

New Clause 8.14.7
This clause requires that a tank truck, tank trailer, or cargo liner used for storage comply with Clause 7. The new clause addresses safety issues associated with parking of vehicles carrying propane for longer periods of time.

Deleted Clause 8.18.3
This clause, which dealt with repair work performed on a tank or tank equipment of a tank truck or cargo liner was deleted since the repair work is governed by TDG Regulations.

Section 9 – Vapourizers

Section 9 of the Code describes the requirements for vapourizers. Changes to Section 9 in the 2015 edition affect the following sub-sections:

  • 9.1 General
  • 9.2 Indirect vaporizers
  • 9.4 Tank Heaters

New Clause 9.1.10
This clause requires that an emergency shutdown system must be installed in any tank system supplying propane to direct-fired vapourizers.

Revision to Clause 9.2.3
This clause has been amended to require the heating medium piping for an indirect vapourizer to be provided with backflow preventers and phase separators to prevent the flow of propane into such piping.

New Clause 9.2.5
This clause stipulates that if the heat source of an indirect-fired vapourizer is a source of ignition, is not certified for hazardous locations, and is located within 15 ft (4.5 m) of the vapourizer, the vapourizer and its heat source must be installed as a direct-fired vapourizer.

New Clauses 9.4 to 9.4.10
These clauses support the new definitions of vapourizers. These Clauses provide further constraints around tank heaters while also specifying the proper requirements for safe installation and use of acceptable types of tank heaters.

Section 10 – Propane as an Engine Fuel

Section 10 of the Code describes the requirements for propane as an engine fuel. A number of sub-sections and clauses were deleted in the 2015 edition of the code and moved to the CAN/CSA B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles. Deletions, including entire sub-sections, or specific clauses affect the following sub-sections:

  • 10.1 General
  • 10.2 Engine fuel containers
  • 10.3 Engine fuel piping, tubing, hose, and fittings
  • 10.4 Engine fuel container equipment
  • 10.5 Hydrostatic relief valves
  • 10.6 Engine fuel vaporizers (converters)
  • 10.7 Engine fuel regulators and valves

Section 11 – Installation of appliances, equipment, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles

Section 11 of the Code describes the requirements related to the installation of appliances, equipment, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles. Most of the sub-sections and clauses in this Section have been deleted in the 2015 version of the code. These sub-sections and clauses have been moved to either the CAN/CSA B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles code or CAN/CSA B149.1 – Natural Gas and Propane Installation Code.

This section will also be renamed to “Installation of equipment, and containers on highway vehicles, recreational vehicles, outdoor food service units, and wash-mobiles”. The remaining sub-sections and clauses will be renumbered in the 2015 edition of the code.

Annex M – Risk and Safety Management Plans (non-mandatory)

A new Annex has been added to the CAN/CSA B149.2 Propane Storage and Handling Code. Risk and Safety Management Plans (RSMPs) are formal plans used to manage the risk of incidents that could result in negative consequences to like and property. The Annex specifies the approach, the management components, and resources to be applied to the management of risk. There are four primary elements of Risk and Safety Management Plans:

  1. Hazard Analysis
  2. Risk Assessment
  3. Risk Mitigation & Control
  4. Emergency Response & Preparedness

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Changes in 2015 Version of B149.1 Natural Gas & Propane Installation Code

This article, related to changes in 2015 version of B149.1 Natural Gas & Propane Installation code first appeared in the March/April 2014 edition of Propane Canada magazine.  It was updated in October 2014.

In 2015, the Canadian Standards Association (CSA) will issue new versions of the B149 Codes scheduled for release by CSA in August 2015.  The 2015 Codes are meant to replace the current 2010 Codes in use.  For the propane technician working in the field, it can be a challenge to determine what has been deleted, added or amended, since the last Code was published.

This article provides a summary of the clauses that have been amended, added and deleted in the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

B149.1-10 CoverThe 2015 editions of the Codes are the completion of a 5-year code cycle that CSA uses to keep the Codes updated to address new technologies, new installation materials, and changing building environments.  The committees who update the codes also consider changes to improve the usability of the document.  Many of the amendments consolidate subjects so that a gas technician has to only look in one place for the requirements of a specific component.  For example, the requirements for appliance installation, regardless of where the appliance is being installed, home or RV, are now in the CAN/CSA B149.1 Natural Gas & Propane Installation Code instead of being split between this code and the CAN/CSA B149.2 Propane Storage & Handling Code.

The adoption of the 2015 Code is done by each province and territory separately with some Authorities Having Jurisdictions (AHJ) adopting the Codes immediately and others taking several years.  A person must use the most current Code adopted in their Province or Territory for new or upgrading propane installations.  In addition, each Province or Territory can, when adopting the Codes add, amend or delete clauses from the Code by way of their Code Adoption Document (CAD).

When inspecting installations one must use the Code in existence at the time the installation was installed as Codes are generally not retroactive.  It is important to remember that an existing propane installation is considered to be in compliance if it still meets the requirements of the Code at the time of installation.

It is, therefore, crucial that the gas technician not only has the latest edition of the Code and current provincial regulations but access to previous Codes for reference when inspecting existing installations.

The following is a summary of revisions included in the 2015 edition of the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

Section 2 – Reference Publications

Section 2 of the Code provides a listing of the supporting codes and publications referred to within the CAN/CSA B149.1 Natural Gas & Propane Installation Code.  The following provides information related to references that have been changed or added.

Acceptance of ANSI/LC-4/CSA6.32-2012 Standard
The code accepts the ANSI/LC-4/CSA6.32-2012 Press-Connect Metallic Fittings for Use in Fuel Gas Distribution Systems Standard to permit the use of press-connect metallic fittings for use on natural gas and propane systems.  The standard was originally developed for copper metallic press fittings but in 2012 the standard was revised to include other metallic materials (copper, carbon steel and stainless steel).

Section 3 – Definitions

Section 3 of the Code provides definitions of terms used within the Code.  A number of definitions were added or amended in the 2015 edition of the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

Boiler
An appliance intended to supply hot liquid or vapour for space-heating, processing, or power purposes and does not include appliances certified as water heaters.  The definition was changed to exclude appliances certified as water heaters.

Flue backflow preventer (new)
A system or device used in common venting of positive pressure appliances to prevent the exhaust flue from active appliances sharing the system from flowing back into the vent of dormant or idling appliance(s).  This definition recognizes check valve technology developed to prevent flue products backflow issues.

Gas Connector
Expansion of the definition of what is a “gas connector” to recognize the different types of appliance installations and connector applications;

  • Permanently installed appliances where the gas connector is designed not to be repeatedly moved or disconnected/connected to the piping system.
  • Movable appliances where the connector is designed for repeated movement and disconnects or reconnection.
  • Gas connectors for outdoor use.
  • Quick disconnect devices or gas convenience outlets.

Gas Convenience Outlet (new)
A permanently mounted certified hand-operated device that provides a means for connecting and disconnecting an appliance to the gas supply piping by way of a gas hose or gas connector.

Direct Gas-Fired Air Heaters (new)
The new definition recognizes that a direct gas-fired air heater may be capable of either ventilation mode, to off-set building heat loss; or process mode, intended for drying, baking or curing product; or both operating modes.

Pipe Wrap Tape (new)
Adhesive tape made of PVC or polyethylene material with a minimum thickness of 10 mil (0.25 mm), with an adhesive resistant to water. The definition explains what is considered to be acceptable wrap since field inspection continues to find unacceptable pipe wraps such as duct tape and thin, low-quality electrical tape being used in the applications addressed by the two subject clauses.

Quick-disconnect Device
The definition was expanded to address a disconnect device equipped with an automatic means to shut off the gas supply when the device is disconnected and is certified to ANSI Z21.41/CSA 6.9.

Section 4 – General

Section 4 of the Code describes the general requirements of propane and natural gas installations.  Changes to Section 4 in the 2015 edition affect the following sub-sections:

4.8 Mobile homes
4.9 Hazardous locations
4.24 Odorization of propane
4.25 Mobile homes and recreational vehicles

New Section 4.8 – Mobile homes
This Section was transferred from the CAN/CSA B149.2-10 Propane Storage and Handling Code.  It provides a single source for appliance and gas system installations regardless of installed location.

Revision to Clause 4.9.2
Recognizes engineered appliances that are used in hazardous locations that are not certified, but field approved.

New Clause 4.24.1
To address the odourization of natural gas from private natural gas wells where it is used for fuel purposes supplying an occupied building.

New Section 4.25 – Mobile homes and recreational vehicles
This Section was transferred from the CAN/CSA B149.2-10 Propane Storage & Handling Code.  It provides a single source for the installation of appliances regardless of their installed location.

Section 5 – Pressure Controls

Section 5 of the Code describes the requirements for pressure controls in natural gas and propane installations.  Changes to Section 5 in the 2015 edition affect the following sub-sections:

5.1 Gas system pressure
5.2 Pressure regulators

Clarification to Table 5.1
As currently written, the code suggests that it would be impossible to use natural gas in a building under construction.  To be consistent, a value for the natural gas was inserted in the last row of Table 5.1 – Pressure inside buildings.

New Clauses 5.2.2.5 and 5.2.2.6
Two clauses dealing with regulators installed on vehicles from CAN/CSA B149.2-10 Propane Storage & Handling Code have been transferred to this Code so that all requirements for regulator installation are in a single source regardless of installed location.

Section 6 – Piping and tubing systems, gas hose, and fittings

 

Section 6 of the Code describes the requirements for piping and tubing systems, gas hose, and fittings in natural gas and propane installations. Changes to Section 6 in the 2015 edition affect the following sub-sections:

6.2 Material
6.9 Joints and connections
6.11 Appliance connections
6.15 Underground piping and tubing
6.16 Protection of piping and tubing
6.17 Identification of piping or tubing
6.18 Manual shut off valves
6.21 Gas connectors
6.27 Hoses

 

 

 

Revisions to Clause 6.2.2
To recognize fittings manufactured to ANSI-LC-CSA 6.32.

Revisions to Clauses 6.9.1 and 6.9.9
To recognize the use of press connection joints.

Revisions to Section 6.11
To clarify how an appliance is to be connected to the gas piping system; addresses the use of corrugated stainless steel tubing (CSST) systems and tubing system installations and recognizes the use of gas convenience outlets.

Revisions to Clauses 6.15.2 & 6.15.3
To recognize the use of press-connect fittings on underground piping and tubing systems.

New Clause 6.16.1
To address the contact of metallic gas piping with a pipe of a different material which can result in galvanic corrosion.

Revision to Clause 6.16.7
To add the definition of “pipe wrap tape”.

Revision to Clause 6.17.2
Clarifies that all piping/tubing needs to be identified; not just indoor piping/tubing systems at care, detention, occupancy, commercial, industrial, and assembly buildings.

Revision to Clause 6.18.1
Added wording to clarify that a manual shut-off valve must be certified for its intended purpose and rating.

New Clause 6.21.4
Permits the use of a gas connector certified to ANSI Z21.101/CSA8.5 for connecting ranges, refrigerators, and clothes dryers to the building piping.

New Section 6.27
Transfers clauses dealing with hoses transferred from CAN/CSA B149.2-10 Propane Storage & Handling Code to this Code to provide a single source for the installation of hoses.

Section 7 – Installation of specific types of appliances

Section 7 of the Code describes the requirements for specifics types of appliance installations. Changes to Section 7 in the 2015 edition affect the following sub-sections:

7.2 Generators, compressors/pressure boosters, stationary engines, and turbines
7.13 Central furnaces
7.18 Construction heaters and torches
7.19 Direct fired door air heaters
7.21 Non-recirculating direct gas-fired industrial air heaters (DFIAH)
7.22 Infrared heaters
7.26 Water heaters
7.27 Unit heaters

Revision to Clause 7.2.1.3
The clause related to venting and air supply excludes Clause 8.5.4 from the requirements to provide consistency of intent.

Revision to Clauses 7.2.4.2 & 7.2.4.3
This clause, related to stationary engines and turbines, recognizes ANSI Z21.21/CSA 6.5 C/I for safety shut-off valves and to permit the second safety shut-off valve to be installed upstream of the appliance zero governor type regulator.

Revision to Clause 7.13.1
Clarifies that a furnace must be installed on a firm level base.

Revision to 7.18.10
Changes the requirement to not leave a torch unattended to apply to both natural gas and propane.

Revisions to Section 7.19
The clause, related to direct-fired door air heaters, addresses the installation of refurbished used direct-fired door heaters that were originally certified to withdrawn Standard CGA 3.12 or CAN 1.3 12-78.  There is a used market for these heaters and they can still be functional, if well maintained, after 30 years.  Because of this used market, they will often be installed on renovations or new projects.

New Clause 7.21.1
This clause related to non-recirculating direct fired industrial air heaters was the result of editorially separating current clause 7.21.2 into two separate clauses and revise the numbering accordingly.

Revisions to renumbered Clause 7.21.8
Ensures that outside air dampers or closing louvers not certified as an integral part of the appliance are interlocked so that the main burners do not operate until the air dampers are fully open.

New to Section 7.22
Clauses were added to address the installation instructions for refurbished Direct Gas-Fired Process Air Heaters, which have not been manufactured since 2002.

Deleted Clause 7.26.4
The clause addressed minimum access clearance to the water heater burner. The present accessibility section and manufacturer’s instructions were deemed adequate.

Revisions to Clause 7.27.6
Changes address return air inlets in combo heating systems. The present clause was found to be confusing and was rewritten for clarification.

Section 8 – Venting systems and air supply for appliances

Section 8 of the Code describes the requirements for venting systems and air supply for appliance installations.  Changes to Section 8 in the 2015 edition affect the following sub-sections:

8.2 Air-supply determination for central-heating furnaces, boilers, and hot water heaters
8.3 Air supply openings and ducts
8.8 Air supply by mechanical means
8.10 Methods of venting appliances
8.14 Vent and chimney termination
8.16 Vents and chimneys serving two or more appliances
8.20 Size and height of interconnected vent connectors

Revision to Clause 8.2.4
Clarifies that an outdoor air supply to an enclosure can be sized using either table 8.3, for appliances having draft control devices; or table 8.4 for appliances not having draft control devices.

Revision to Clause 8.3.4
Ensures a combustion air supply device has air flow proving interlocked to the appliance(s) served and sufficient airflow is demonstrated.

Revision to Clause 8.8.2
The clause, related to air supply was found to be confusing and was rewritten for clarification.

Revision to Clauses 8.10.6, 8.14.13 & 8.20
Provides requirements for common venting of appliances with positive pressure venting. Check valve technology has been developed to prevent flue products backflow issues. This venting technology is currently permitted in Europe.

Revision to Section 8.16
For vents and chimneys serving two or more appliances, a note was added to explain differences between common venting of Category 1 & 11 appliances and Category 111 & 1V appliances.

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Why Employee Engagement Matters

This article, related to why employee engagement matters, first appeared in the Jan/Feb 2014 edition of Propane Canada magazine.

One of my favourite parts of facilitating a course entitled “Achieving Extraordinary Customer Relations” for a national propane retailer was when I asked participants to describe their worst and best customer service experiences. While the point of the exercise was to illustrate the negative impacts of poor customer service on the organization, the underlying reality is that high customer satisfaction cannot be achieved through interaction with disengaged employees.

I Love My JobAn ever increasing body of research continues to make the point that employee engagement has a direct impact on key business performance. For example, organizations with higher employee engagement benefit from higher staff retention rates, happier customers resulting in increased revenues and repeat business, improved safety rates, often above industry norms, and greater efficiency and productivity.

So what does the term “employee engagement” really mean?

When asked to describe an “engaged employee,” people will often describe enthusiastic people who can be counted on to roll up their sleeves when it matters, help other team members without being asked, take extraordinary steps to satisfy customers, accept new job challenges and tasks, and show flexibility in the face of changing workplace priorities. Every manager wants employees that can be described this way, yet this goal seems elusive. Study after study continues to show that on average, only around 30% of employees describe themselves as “engaged” or “highly engaged” and another 45% describe themselves as “partially engaged.” The majority of employees know how to keep doing competent or passable work to keep the paychecks coming in but are not really engaged in their work.

Two factors affecting Employee Engagement

So why are we seeing these disappointing engagement statistics in spite of well-intentioned efforts to engage employees? Two factors deserve attention.

First, many organizations are trying to improve employee engagement solely through organization-wide engagement surveys designed to assess engagement, identify successes, and point to areas for improvement. While these surveys certainly paint a broad picture of engagement, they are not as helpful when it comes to understanding and acting on the needs of unique individuals, which is essential to sustaining engagement. Surveys are best for identifying organization-wide issues and opportunities and their success is dependent on making visible changes based on results. Failing to respond to survey feedback can very easily increase skepticism and disengagement and amount to a missed opportunity.

Beyond relying too heavily on a single tactic (i.e. surveys), another important factor contributing to less-than-desired engagement is arguably what is taking place (or not taking place) between employees and their managers.

Let me explain the second factor.  Something important to remember is that engagement is a personal choice, based on criteria defined by each individual employee. No two employees have the same needs or motivators, so it is important to identify what motivates each employee individually.  This can only be achieved through direct and deliberate conversations and collaboration between the employee and his or her immediate manager.

In many organizations, especially small and medium-sized ones, managers are often not supported in carrying out the conversations and collaboration that can foster engagement.  Managers certainly try to engage their employees, with varying degrees of success, but without the needed skills or tools, their efforts often fall short of the mark.  Fortunately, there are a number of tools and training programs available to assist managers in acquiring these skills. If you look at your own organization, to what extent do such conversations and collaboration take place, and how effective are they?  As we are seeing (and if this is any comfort), the propane industry is not unique in its need to address skills gaps and an aging workforce.

Tools to help to achieve increased engagement

So how can organizations achieve greater employee engagement overall?  Further, if identifying an employee’s unique motivators, aspirations and concerns and providing ongoing assistance in achieving the employee’s goals is essential for engaging employees and these are skills that many managers lack, what can the organization do?

Very simply, I am advocating a balanced approach – one that combines the macro and the micro: Organization-wide surveys provide good value and should be combined with greater attention and support to employee-manager collaboration, which has a great impact on individual engagement.  To go the distance in engaging your employees you need both the macro and the micro.  A one-sided approach emphasizing surveys won’t fully achieve your goals.

Fortunately, there are some excellent tools available to assist managers to strengthen employee-manager collaboration and increase employee engagement at the individual level.  These provide managers with the skills they require to understand and act upon the individual needs of their employees.  By creating the environment where employees choose to be and remain fully engaged you are also setting up your organization to be an employer of choice among desirable candidates who may be considering many employment options.

When I think back to the days I was facilitating customer service workshops, I heard a number of great stories involving customer service nightmares and horrible bosses and we shared a lot of laughter.  However, when the conversation shifted to describing great customer service experiences, many of the participants observed, in their own way, the commonality of great customer service experiences – fully engaged employees.

Everybody has the capacity to be fully engaged.  The challenge is to create the environment where employees make the choice to be and remain engaged.  More attention to individual employees and their unique needs is a great start if your goal is to create a more engaged workforce.

 

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Responding to Carbon Monoxide Calls

This article is a compilation of two articles which first appeared in the 2013 Nov/Dec and 2014 Jan/Feb editions of Propane Canada Magazine and provides guidelines related to responding to carbon monoxide calls.

CO Warning SignWith the onset of fall and winter, heating systems will be reactivated after a summer of disuse. It is the season where, as a gas service technician your knowledge
and skills will be called upon to keep people warm and safe. There are two calls that should cause a heightened response: Gas leak and carbon monoxide (CO). Your company and employees response can save lives and reduce injuries caused by CO poisoning.  Your company’s emergency response procedures for CO incidents are most effective when you coordinate with fire services, ambulance, and police.

It is important that you establish a “Safe Entry Procedure” for when you are going to enter a building where there is a reported CO incident. CO calls can be made when a CO alarm has sounded or when the occupants suspect a possible CO exposure due to illness or strange odours. A CO alarm should never be ignored.

Immediate evacuation is necessary when a CO alarm sounds. CO alarms are designed to alarm at exposure levels below the level at which people exhibit symptoms of CO poisoning. This gives the occupants time to take action to protect themselves. That being said, CO levels can escalate quickly, in which case the CO alarm is responding to a high level of CO in the atmosphere. CO alarms should not activate below 30 ppm.

carbon-monoxide-gas-safety

There have been instances where CO alarms have sounded and neither a CO elevation nor a source could be identified. Over the years, changes have been introduced into standards for CO detectors to reduce the number of unexplained occurrences.

If a CO alarm is manufactured prior to October 1, 1998, and a CO elevation or CO source cannot be located, the resident should be advised to purchase a new alarm. CO alarms also have a service life marked on them and should be replaced when the end of the service life is reached.

A new CO alarm should meet one of the following standards:

  • CSA 6-19-10, 2001;
  • UL 2034, Second Edition 1998; or
  • IAS 6-96 Second Edition, June 1, 1998.

Professional CO detection equipment in the hands of a trained gas technician is essential for attending CO calls and finding the source of elevated CO readings in a building’s atmosphere.  Use, maintenance and periodic calibration procedures should be established. Manufacturers of CO detection equipment generally provide recommendations and instructions for maintenance and recalibration.

It is important that the CO detector a gas service technician is using is within the calibration time frame.  Most CO detectors require recalibration once every 12 months.

The calibration period can be shortened depending on use, stored environment, handling and how transported in the service vehicle. This is the type of instrument you do not want bouncing around in your service vehicle.

Finding the reason for the CO alarm can be time-consuming and difficult, especially if the elevated levels are the result of transient conditions such as downdrafts from exhaust vents and chimneys, CO infiltration from outdoor equipment operating near open windows or doors, etc.

The responding service technician must have a basic level of knowledge about carbon monoxide:

  • How it is generated;
  • How it can become abnormally elevated;
  • How it is distributed through a home; and
  • What the exposure symptoms are.

The first level of response is the person taking the call.  It is important that that person has a procedure to instruct the customer on what actions they should take to protect human life and then property.  If you use a third-party call service be sure to supply them with your company’s response procedures for a leak or CO call.

The following is a possible response scenario that the person receiving the CO call could follow.  Each company should develop their own response procedures based on how service calls are received and how the response is to be delivered.

When developing procedures, the amount of time a response will take must be considered.  For example, it may be quicker to contact the local fire service or HVAC contractor rather than wait for your service technician to arrive.

CO Incident Guidelines for Dispatchers

Obtain caller’s name, address and telephone number.  Ask if anyone is unconscious, nauseous, lightheaded, having headaches or chest pains.

If the answer is “YES”, then complete the following steps :

  1. Send ambulance and fire services;
  2. Send trained service technician equipped with a professional CO detector;
  3. Advise caller and all other residents to go outside or to a neighbour’s home immediately. DO NOT TAKE TIME TO VENTILATE THE HOME, UNLESS SOMEONE IS UNCONSCIOUS OR CANNOT LEAVE;
  4. Advise residents that once they are outside they should not re-enter the home until response personnel have inspected conditions in the structure and have determined that it is safe to return;
  5. In extreme weather conditions and when neighbours are far away, advise residents that they can shelter indoors by staying in one room with a door or window open to the outside.  There should be no vehicles running in the garage or any fuel burning appliances operating in the room where the residents seek shelter;
  6. Advise the caller to open all windows in the room and close any doors that go to other parts of the house. If there is an exhaust fan in the room, turn it on to help bring in fresh air more quickly.

 

If the answer is “NO“, then complete the following steps:

  1. Ask if a CO alarm is sounding.  If yes or don’t know, follow procedures listed under “YES”.
  2. If the answer is “NO” to the alarm sounding, record caller’s reason to suspect CO incident and determine if CO investigation is needed.  If so, then follow the procedures provided by your company.

 

CO Incident Reporting Form

A Carbon Monoxide Incident Report Form is essential in providing a structured approach to help you identify the cause of the call for help and to assess when it is safe for a resident to re-enter the home. The form should list the CO levels and what action is required to be taken. The form should also capture all the readings taken.

The following are areas that a CO incident reporting form should address:

  • Determine the level of care needed by household members;
  • Identify potential sources of elevated CO in the home and attached garage;
  • Take and record indoor CO measurements;
  • Evaluate information;
  • Complete the investigation; and
  • Advise and follow up.

 

Investigation Process

During the investigation process, residents should be evacuated from the home.  After the investigation is complete, it is time to assess the information you have and in conjunction with fire services.  If they responded, provide advice to the residents, including whether they can safely re-enter their home. The final decision on re-entry may need to be made by someone other than the first responder.

The CO levels you measured in various rooms of the building should be taken in the centre of the room in ambient air, making sure that you are about 5 feet away from any appliance. Based on those measurements and your evaluation of the information you gathered in your investigation, identify any areas of the structure with measured CO levels of:

  1. 70 ppm or higher;
  2. Between 30 ppm and 70 ppm; or
  3. Less than 30 ppm.

These levels are benchmarks used to provide guidelines for giving advice to residents.
These following Benchmark Guidelines were sourced from a document published by the U.S. Consumer Product Safety Commission.  I expanded the advice to be given and actions to be taken to include provincial regulatory requirements.  Your company may have different benchmarks with specific actions that you are to follow.

When CO Levels are 70 ppm or higher

The following steps provide action guidelines when carbon monoxide levels are 70 ppm or higher:

  1. If the source of CO appears to be a vehicle or a lawnmower or generator in a garage then:
    1. Turn off the engine if it is still operating; and
    2. Advise the residents that an engine should not be left idling in an attached garage, even if the garage door is open.
  2. If the source of CO appears to be a permanently installed appliance then:
    1. Turn off the appliance;
    2. Shut off the fuel supply to the appliance – tag the appliance in accordance with your company and provincial requirements;
    3. If an independent contractor verbally, and in writing notifies the fuel supplier in accordance with your company and provincial requirements; and
    4. Advise the residents in writing (use your work order to document) that the appliance is creating large amounts of CO and must not be reactivated until the reason for the high CO levels has been identified and corrected by a certified propane technician.
      1. Note: The appliance may not need repair or replacement. It is possible that exhaust fans or other large air moving appliances are creating a situation in the home that may need attention. House depressurization is a complex and sometimes difficult situation to recreate and is beyond the skill sets of a propane technician.
      2. If you suspect that building depressurization is causing a problem then advise the customer to arrange for a depressurization test to be performed on the home. There are companies that specialize in doing this type of testing and can assist the customer in overcoming the depressurization problem.
      3. Provincial Authorities Having Jurisdiction (AHJ) have guidelines as to when you are required to report a CO incident to them. These guidelines should form a part of your company’s reporting and documentation procedures when responding to a CO call.
  3. If the source of CO appears to be a portable appliance or misuse of an appliance then:
    1. Turn off the appliance;
    2. Unvented gas appliances, such as infrared camp heaters, barbecues, etc., are not permitted for use indoors.
    3. The most common, especially during power outages, are gas range top burners and oven for heat; and
    4. Educate the user about the dangers of CO and the proper use of appliances.
  4. If you cannot find an apparent source of elevated levels of CO then follow your AHJ guidelines and your company’s policy. Advise the residents to follow up with a company that specializes in building depressurization, etc.
  5. In co-operation with fire services advise the residents that they can return home after it is cleared of CO. When your equipment shows levels of CO below 30 ppm residents can return home. If your equipment shows a CO level below 30 ppm, and if a household CO alarm is still sounding, then advise the consumers to remove and replace it as soon as possible.
  6. Advise the residents to have their gas burning appliances inspected immediately and maintained once a year by a certified gas technician.
  7. Advise residents to use a CO alarm manufactured to the current standard issued by the Canadian Standards Association (CSA), Underwriters Laboratories Inc. (UL) or International Approval Services (IAS).
  8. Advise the residents to call again if their CO alarm sounds, particularly if they have followed the above recommendations.

 

CO levels between 30 ppm and 70 ppm

In certain cases to address the possible cause of carbon monoxide, the following suggested actions and advice mirror those listed in the CO levels 70 ppm or higher:

  1. If the source of CO appears to be a vehicle or a lawnmower or generator in a garage then:
    1. Turn off the engine if it is still operating; and
    2. Advise the residents that an engine should not be left: idling in an attached garage, even if the garage door is open.
  2. If the source of CO appears to be a permanently installed appliance then:
    1. If you cannot rectify an issue with the appliance, turn off the appliance, shut off the fuel supply to the appliance – tag the appliance in accordance with your company and provincial requirements;
    2. If an independent contractor verbally and in writing notifies the fuel supplier in accordance with your company and provincial requirements; and
    3. Advise the residents in writing (use your work order to document) that the appliance is creating potentially dangerous levels of CO and must not be reactivated until the reason for the CO levels has been identified and corrected by a certified gas technician.
  3. If the source of CO appears to be a portable appliance or misuse of an appliance then:
    1. Turn off the appliance;
    2. Unvented gas appliances, such as infrared camp heaters, barbecues, etc., are not permitted for use indoors;
    3. The use of an approved appliance for a purpose other than its intended use and approval is not permitted.
    4. The most common, especially during power outages, are gas range top burners and oven for heat; and
    5. Educate the user about the dangers of CO and the proper use of appliances.
  4. Advise the residents to follow up with a company that specializes in building depressurization, etc.
  5. In co-operation with fire services advise the residents that they can return home after it is cleared of CO. When your equipment shows levels of co below 30 ppm, residents can return home. If your equipment shows a CO level below 30 ppm, and if a household CO alarm is still sounding, then advise the consumers to remove and replace it as soon as possible.
  6. Advise the residents to have their gas burning appliances inspected immediately and maintained once a year by a certified gas technician.
  7. Advise residents to use a co alarm manufactured to the current standard issued by the Canadian Standards Association (CSA), Underwriters Laboratories Inc. (UL) or International Approval Services (lAS).
  8. Advise the residents to call again if their CO alarm sounds, particularly if they have followed the above recommendations.

 

CO levels less than 30 ppm

Advise residents that you did not find high levels of carbon monoxide.  If the call was the result of a sounding CO alarm, advise the residents to review the manufacturer’s instructions about a sounding co alarm and contact the manufacturer if necessary.  If the alarm was manufactured before October 1, 1998, advise the residents to purchase a new alarm meeting the standards published by CSA, UL or IAS.

  • Advise the residents that CO alarms have a limited life and that their alarm may need to be replaced.
  • Advise the residents never to ignore a sounding co alarm and to call again if the alarm activates.

 

Benchmark CO Levels

Varying levels of carbon monoxide exposure may cause varying health effects, including levels that are not likely to cause adverse health effects in healthy adults, higher exposure levels that can be potentially life threatening and levels so high as to cause death.

The effects of CO exposure depend on the length of time that a person has been exposed to CO, how high the CO concentration is, how physically active the person is at the time of exposure and the person’s general health.

When a person breathes in CO it combines with oxygen in the blood to form poisonous carboxyhemoglobin (COHb).  The amount of COHb in a person’s blood is expressed as a percent. For example, a person exposed to CO might be described as having 8% COHb. Heavy smokers may have baseline levels of 10% COHb. A 10% COHb level is a reference value that is widely regarded by physicians as confirmation of CO poisoning, even when there are no symptoms. When used as an upper limit, it is recognized as protecting healthy adults against the harmful effects of CO.

This benchmark is built into industry standards for CO alarms, which must sound at exposures predicted to reach 10% COHb in healthy exercising individuals. This will occur at the following concentrations:

  • 70 ppm CO for slightly more than 3 hours;
  • 150 ppm for 50 minutes; and
  • 400 ppm for approximately 15 minutes.

CO Description70 ppm is the lowest level that can cause COHb to exceed 10%.  At these same exposures, less active individuals will have less than 10% COHb.  At levels less than 30 ppm, it is unlikely that adverse health effects will occur in healthy adults. This is the second benchmark level in industry standard CO alarms – they cannot sound at less than 30 ppm or less. This helps to prevent false or nuisance alarms when co levels may temporarily spike due to outdoor air inversion or when an appliance is first turned on.

In conclusion, as previously mentioned, the benchmark levels used in this article are suggested guidelines based on a document published by the United States Consumer Product Safety Commission.

You may already be using Standard Operating Procedures (SOPs) that use different CO ppm levels as a benchmark. If your SOPs work well for your needs and resources, and if the benchmark levels of those SOPs based on your experience and that of medical personnel in your community adequately provide for the safety of residents, then you may want to continue using those SOPs.

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Incident Management

If you store, transport or deliver fuels or install or service fuel-burning equipment, chances are, your company will be involved in an incident of some type.  Learn how you can benefit from the creation of an Incident Management Team in this article, which first appeared in the Sep/Oct 2013 edition of Propane Canada magazine.

 

Managing Incidents

Incident Management 01Over the years of investigating fires, explosions, fuel escapes and personal injury incidents in the propane, natural gas and fuel oil industries, I have seen, on many occasions, where the mismanagement of the incident by the fuel supplier has resulted in the fuel supplier being sued.  If the incident had been managed correctly the lawsuit could have been avoided.

Obviously, the best way to manage incidents is not to have any in the first place.  However, mechanical equipment will eventually fail and the human error factor is always present.  If you store, transport or deliver a fuel, and/or install or service fuel burning equipment, then the chances are that at some point in time, your company will be involved in an incident of some type.

Ignoring an incident and leaving it to others, such as the local fire services or government investigators to determine if your company is or is not involved, is the worst possible position you can take.  Doing nothing is not an option if you wish to stave off potential lawsuits that can affect your bottom line through deductible payouts, increased insurance premiums, and poor community reputation.

Even when you are convinced upfront that your company has no involvement, past experience has shown that by aggressively responding to and managing incidents you can significantly reduce your exposure and costs.

 

Benefits of Managing Incidents Correctly

Many years ago, a client of mine established a team and procedures for handling incidents with very positive results.  I was fortunate to be a member of the team as an independent investigator.  We had many successes in proving that our client had no responsibility for the incidents, saving a considerable amount of money in deductible payouts and legal fees, etc.

In one case, a heavy equipment repair and storage garage containing several expensive pieces of earth-moving equipment burned to the ground.  The fire department investigator concluded that the fire had started in the wall behind a sealed combustion propane heater and that the heater must have been installed incorrectly.

The heater had been installed by my client several years prior to the incident.  The heater had been removed from the scene by the local fire department and retained as evidence.  During our examination of the heater, we removed the outer casing and noticed a green substance had melted on the heat exchanger.

At the site, we had found melted and partially melted one-litre green plastic containers of motor oil.  With this evidence, interviews were conducted with the people working in the garage, and it was soon discovered that a common practice was to place the plastic containers of motor oil on the propane heater’s top grill to heat the oil to make it easier to pour.
We finally learned that a plastic container of motor oil had been placed on the heater when the employees went to a local restaurant for coffee.  The structure was on fire when they returned to the garage.

The original cause of the accident was changed to reflect what our investigation had determined, which exonerated my client of any wrongdoing.

In a second incident, a propane kitchen range, installed by my client, was blamed by the local fire services for a fire that caused extensive damage to a home.   Fortunately, we arrived at the scene prior to any evidence being disturbed.  Our investigation at the scene determined that one of the top burner valves was in the high position and that a frying pan was sitting on that burner.  After interviewing the homeowner, we learned that just prior to going to church that morning he had cooked bacon, eggs, and home fries for breakfast.

While the cast-iron frying pan was undamaged and all the grease in the pan consumed, fire patterns indicated that the fire had spread from the frying pan to the kitchen cabinets above the range, not from the wall behind the range as originally thought by the fire department investigator.  The homeowner had forgotten to turn off the burner when he finished cooking breakfast.

Again, the original cause was changed to reflect what we had determined and our client was exonerated of any wrongdoing.

 

Incident Management Team

The management of an incident should use a team approach, which may or may not be dependent upon the severity of the incident, and include your insurer, adjuster, lawyer, company incident manager, internal company investigator, and possibly, an outside independent technical investigator.

The team should be established prior to any incidents taking place; since there is no time to put together a team if and when an incident occurs.  Each team member must be aware of his/her responsibilities.

The incident has most likely been reported to fire services, police, etc. by the time you become aware that an incident has occurred.

Incident Manager
The internal company person who is notified of the incident, determines the severity of the incident and activates the appropriate team members, notifies senior management, insurer and enforcing authority (legal obligations). Other responsibilities include:

  • In accordance with company policy, provides information such as customer files, staff qualifications, work orders, etc. as requested by enforcing authority investigators; and
  • Continually monitors the investigation as it progress, receives and reviews reports from the technical investigator and adjuster, reports to senior management and adds or removes team members as the response requires.

Legal Services
I have several clients where the incident manager is either a part of the in-house legal team or a member of the corporation’s external law firm.  It’s up to management of the company to determine at what stage of the investigation legal services become involved.

Having a lawyer involved in the first stages to help guide the investigation can be a great benefit down the road as he/she will know what information, from a legal point, must be determined, what information is to be kept privileged and what information can be shared.

Technical Investigator
Attends the scene and tries to become part of the investigation team where fire services or government investigators are involved. The Technical Investigator can act as the liaison between government investigators and the company, and keep abreast of the government investigation.

The Investigator
Conducts his/her independent investigation following practices as described in NFPA 921 Guide for Fire & Explosion Investigations.  The Investigator acts as an expert witness and supports the legal team during mediation, examinations for discovery and trial.

Administrator
Each team needs an administrator who is familiar with the company’s filing system and record-keeping policies.  The administrator is key in keeping track of customer and employee files that may be requested and provided to adjusters/government investigators and company investigator.  The administrator photocopies files for distribution and retains the originals.

Insurer/Adjuster
Liaison with other insurance adjusters obtains permission for company investigator to enter the scene, interviews witnesses and company staff who may be involved.  Provides reports to the insurer, and provides information to the technical investigator and incident manager.

Media Spokesperson
This person may be the incident manager, legal services member or a separate individual assigned to this task. The Media Spokesperson responds to calls from the media.

 

In conclusion, having an incident team in place enables you to manage an incident in the best interests of the company.  Attending incident scenes and activating the team may absolve your company of any wrongdoing.  However, it may be determined that your company does have some liability exposure.  If so, you now know what that liability is and can move forward managing the liability to reduce the financial impact to your company.

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