Category Archives: Knowledge Base Articles

Unvented Heaters in Poultry and Livestock Facilities

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Poultry and livestock facilities have to be designed so that the ventilation system provides sufficient fresh air to meet the needs of the propane or natural gas appliances, the animals housed in the facility and to create a healthy atmosphere within the structure.  This article, which first appeared in the Jul/Aug 2013 edition of Propane Canada magazine discussed the regulatory requirements for using unvented heaters in poultry and livestock facilities.

 

Introduction

A project that I recently completed involved the development of a position paper and proposed clauses to address the specific practice of installing and operating unvented heaters in poultry and livestock facilities.  The CAN/CSA-B149.1 Natural Gas & Propane Installation Code does not specifically address the use of unvented gas heaters in poultry or livestock facilities.

 

Unvented heaters in poultry and livestock facilities

The use of unvented gas heaters has been common practice for most of the farmers who raise poultry or livestock. Some livestock types are very temperature sensitive especially near their time of birth. In most parts of Canada, these animals require supplemental heat during this early period and this requirement decreases as they mature.

The different types of gas heaters used in barns include vented and unvented infrared tube heaters, unvented direct-fired box heaters, and unvented infrared brooder heaters. All of the heaters listed are certified to the CSA 2.20 Brooder standard.

Barn ventilation is essential in keeping carbon dioxide (CO2), moisture and ammonia created by the animals within acceptable parameters. The production of carbon monoxide (CO) is also dependent on adequate ventilation to provide sufficient air for complete combustion and prevention of recycling of the products of combustion.

Poultry and livestock facilities have to be designed so that the ventilation system provides sufficient fresh air to meet the needs of the propane or natural gas appliances, the animals housed in the facility and to create a healthy atmosphere within the structure.

The CSA-B149.1-10 Natural Gas and Propane Installation Code does include ventilation and interlock requirements for the installation of unvented appliances in structures in that:

  • unvented infrared heaters must be interlocked with a mechanical ventilation system;
  • appliances located in a large and adequately ventilated space may discharge the combustion products directly into the space, subject to the approval of the authority having jurisdiction; and
  • that unvented infrared heaters are interlocked with the ventilation system so that if the ventilation system reduces or shuts down the number of corresponding heaters will also shut down.

Poultry or livestock facilities that use unvented gas heaters can generally meet the Code requirements for ventilation. However, the facilities do not meet the interlock requirement with the ventilation system.

Brooder Heater - Unvented

Unvented infrared brooder-style heater with standing pilot.

It is common for infrared tube heaters to take outside air for combustion and vent their products of combustion to the interior of the barn in which they are installed.

Infrared Tube Heater - Unvented

Unvented infrared tube heater.

Natural and mechanical ventilation systems are utilized to control the atmosphere within the barn.  The ventilation systems are not interlocked with the gas appliances as per the Code.  Certain types of heaters, such as the infrared brooder heater or and the direct fired box heater with standing pilots are examples of the types of heaters that are not capable of being interlocked with the ventilation systems.

Direct Fired Box Heater - Unvented

Unvented direct-fired box heater.

Of the three different types of heaters, the infrared tube heaters or direct fired box heaters with spark ignition are the only ones capable of being interlocked to the ventilation system.

 

Ventilation

In order to provide an optimum environment for poultry and livestock to grow in, good ventilation is a key factor. The main elements in good ventilation are:

  • Fresh air provided at all times;
  • Distribute the fresh air homogeneously;
  • Constant monitoring of room temperatures;
  • Exhausting of the moisture created by the animals; and
  • Removal of gases and odors.

All ventilation systems work on the principle of heat balance.  This is, the heat produced by the animals must balance the heat lost through the building shell and the ventilation system to maintain a good environment for the poultry and livestock.  If there is a heat deficit (more heat lost than produced by the animals) the farmer will be required to provide supplemental heat to maintain the desired barn temperature for the animals.

The ventilation requirements of livestock buildings are the same for naturally or fan ventilated buildings.  These requirements are determined by the heat and moisture production of the animals living and growing in the facility.

If farmers do not maintain adequate ventilation, the animals will not perform as expected.  Poor air quality shows up very quickly as unfit livestock with reduced feed and water intake and less weight gain.  Livestock profit margins tend to be small and as such, farmers will strive to achieve maximum performance from their animals or birds from birth to market.  Good ventilation is one element towards achieving top performance.

Interior temperature set points which control the barn ventilation system vary depending on the type and age of the poultry or livestock housed.  This variability means that the interior temperature and airflow through the facility are closely monitored and controlled.

Mechanical ventilation systems use exhaust fans to remove stale, contaminated air from the barns.  This creates a slight negative pressure (vacuum) inside the barn that draws fresh air into the barn through strategically placed air intakes.  Air intakes are located to allow fresh air to mix with and dilute contaminants in the barn air.

In barns less than 40 feet wide, the air inlets are usually located on the opposite wall to the exhaust fans.  For barns wider than 40 feet, there can be inlets and exhaust fans on both sides of the building or they sometimes pull the fresh air from the attic and mount the fans on the sidewalls.

Natural ventilation systems use movable side curtains with chimneys located in the center of the barn to create airflow.  The wind blowing at and across the facility will force fresh air into the building by means of the side curtains.  This will create a negative pressure across the top of each chimney to increase the draw out of the chimney opening.

In both types of systems, where hydro is available, circulating fans are used to distribute the air evenly throughout the barn creating a uniform temperature throughout the facility.

As previously stated the Code permits appliances located in a large and adequately ventilated space to discharge the combustion products directly into the space provided the maximum input of the appliances does not exceed 20Btuh/ft3 (0.2 kW/m3) of the space in which the appliance is located.  The facilities examined were able to meet this requirement.

The minimum ventilation rate requirement in the Code for infrared heaters calls for 300 CFM of air exchange for each 100,000 Btuh input or fraction thereof.

The majority of the facilities examined were able to meet or exceed these minimum requirements 95% of the time for poultry barns and 100% for swine barns.

 

Security

The control of disease is paramount to the animal’s well-being and as such the poultry and livestock facilities are not readily accessible by the general public.  Under normal operations, the only person accessing the facility several times daily is the barn operator whose responsibility is to monitor and adjust the interior atmosphere and temperature.

 

Conclusion

As one can see, the facilities have restricted access and while the facilities may not be capable of meeting all of the Code requirements for the installation of unvented gas heaters and interlocks, the barns, must be well ventilated to ensure survival and proper growth of the animals.

 

Regulatory Proposal

The proposed clauses were developed to address the specific requirements for the use of unvented gas heaters in poultry and livestock facilities by:

  1. Controlling animal-generated water vapour and ammonia, CO2 and CO levels through ventilation rates that can be achieved throughout the growing cycle.
  2. Requiring cleaning and maintenance of the heating systems as per the manufacturer’s operating instructions at the end of each growing cycle.

The B149.1 Technical Committee did not accept the proposed clauses put forward.  There were several comments with respect to amending the Code to address previous installations that were installed in non-compliance with the Code and that the Code is not considered a retroactive document.

That being said there are thousands of poultry and livestock facilities with unvented non-interlocked heaters installed.  The project showed there is almost always sufficient ventilation to meet the Code requirements that must be maintained to ensure the growth and survival of the animals.  The barns have restricted access and we could not find any incidents where carbon monoxide was an issue.

By amending the Code to specifically address the practices that have been in place for the past 50 years we are accepting a practical and proven safe method for heating and ventilating barns.

The Ontario Technical Standards & Safety Association (TSSA) have been an integral part of this project and will be amending the 2010 Code to include specific clauses put forth by the Ontario Turkey Farmers Working Group to address the installation and operation of unvented heaters in poultry and livestock facilities.

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Standard of Care

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This article, which first appeared in the May/June 2013 edition of Propane Canada magazine, discusses the basic standard of care your company is expected to achieve as it relates to the technical regulatory aspects of conducting business in the propane and fuel oil sectors.

Once an investigation into an incident is completed, I am often requested to provide an opinion as to whether or not an individual’s or company’s actions met the “industry’s standard of care”.  In this article, I focus on the issues of meeting the basic standard of care you are expected to achieve as it relates to the technical regulatory aspects of conducting business in the propane and fuel oil sectors.

As quite a few propane distributors also have a fuel oil delivery component, I have extended this article to include the fuel oil aspects as well. Companies that deliver and provide services in both fuel sectors should adopt the same level of regulatory compliance for both fuels.

Compliance

Introduction to Standard of Care

When I am asked to look at an individual or company from the standard of care perspective, the first thing I do is compare the company’s practices and employee actions to the acts, regulations, & codes and standards in place at the time of the incident.  I will also reference industry specific technical manuals, technical papers, manufacturer’s manuals/bulletins, and training and certification programs.

If a person takes training and/or a certification program and fails to apply the knowledge learned in the program, it can be interpreted that the person failed to meet the industry’s basic standard of care.

An example of the type of documents reviewed in conjunction with the regulations and codes during the development of a standard of care opinion would be two Canadian fuel oil technical manuals published in recent years.  The manuals describe recommended and well-established practices for the installation and maintaining oil burners, furnaces, boilers, water heaters, and heating oil tanks and piping.

The manuals establish the standard of care expected when conducting work in the areas identified.  There are no such manuals within the propane industry, so an equivalent review, in this case, would focus on the appliance and equipment manufacturer’s literature.

As you can see by the materials listed, the standard of care issue can go well beyond the regulation and code requirements that everyone is familiar with.  It is important that, in addition to the regulations and codes, that you are aware of and familiar with all industry training programs, technical manuals, and manufacturer’s literature which describe how certain tasks are to be performed or maintenance conducted.

 

Standard of Care – What Does it Mean?

Standard of care is the degree of prudence and caution required of an individual who is under a duty of care.  Certified fuel technicians, trained fuel delivery persons or persons who operate fuel storage facilities are, due to the nature of the product, expected to work under a “duty of care”.

The requirements of the standard are closely dependent on the specific circumstances being discussed.  Whether the standard of care has been breached is dependent upon the actions of the person or company, the company’s policies, and procedures, and is usually looked at in terms of compliance.

Best Practice - LowRes - shutterstock_310757321Standard of care is often referred to as “industry standard of practice”, “best practices”, or “code of practice.”  Whatever name is used, they essentially have the same meaning and outcome – to have a program in place that provides a vehicle for the company to meet or exceed the regulatory regime under which it must operate and to monitor the level of compliance on an ongoing base.  The standard of care program provides the knowledge, policies, and procedures required by company personnel to meet everyday compliance requirements in the execution of their duties.

 

Benefits of Implementing a Standard of Care Program

Your customers, employees, and suppliers have a right to expect a level of regulatory compliance that keeps everyone safe and free from harm or injury.  A Standard of Care Program covers all aspects of the business with respect to:

  • hiring and training;
  • product acquisition and delivery;
  • equipment and appliance acquisition;
  • installation and servicing of equipment and appliances; and
  • maintenance of company and customer assets.

A well written and implemented Standard of Care Program can result in less government regulation; in other words, the industry regulates itself.  From the perspective of the Authority Having Jurisdiction (AHJ), there is an increased comfort factor on the operational aspects of the company.

This allows the AHJ to focus human and financial resources on chronic non-compliant companies.  The implementation of a documented Standard of Care Program can provide a model to approach the AHJ to forgo the requirements for formal timed and documented inspections and replace them with an ongoing quality assurance program.  This is the same concept under which the natural gas utilities operate.

While the tasks of putting together a Standard of Care Program can be daunting, the benefits greatly outweigh the resources required to develop, implement and monitor the program. It is much easier, satisfying and financially more profitable in the long run to operate the business well.

As Mike Holmes often says:  “Do it right the first time”.

By doing all things right the first time, you maximize the existing human, equipment and financial resources you have available.  Cutting corners and getting away with a non-compliance exposes the customer and employee to a possible unsafe condition that could be life-threatening and expose the company to litigation.

Do It Right the First Time 02

Companies can also see reduced worker compensation costs by a reduction in personal injuries through education, adherence to safe work practices and a healthier, more productive workforce.

Another very tangible benefit can be reduced insurance costs through fewer vehicle accidents and customer incidents.

The program can also provide a means of best operational practices to negotiate insurance premiums downward.  I have seen in the past where any savings derived from not complying with the regulatory regime have been quickly eaten up by legal fees, insurance rate increases, and, worst of all, customer confidence.

A company’s reputation is only as good as the last delivery, installation or service call. Customers who feel unsafe or experience a loss due to a company not adhering to the regulatory requirements or company incompetence will quickly create a negative reputation for that company.  We all know that a poor reputation affects the company’s very existence in the marketplace.

 

Basic Standard of Care Program

A Standard of Care Program can be infinite, dependent upon the corporate due diligence vision.  While it is feasible and possibly beneficial to exceed the basic compliance requirements, the corporation must be conscious that the level of compliance does not negatively impact the productivity and become a hindrance to conducting everyday business.

As with most things in life, it is best if a balance can be achieved between the level of compliance and the company’s need to conduct business safely, efficiently and in a financially beneficial manner.

I see the implementation of a Standard of Care Program as a multi-staged process where the program is developed and implemented in varying degrees.  The basic Standard of Care Program establishes the minimum required regulatory compliance and monitors the company’s level of compliance.

As you become more comfortable and meet the established compliance levels, specific areas of the company’s operation can be targeted to increase the compliance levels that can be shown to further benefit the customers, employees, and company.

I believe if a company can have a document that provides the vehicle for the company to meet the minimum regulatory requirements, as provided in the acts, regulations, codes and standards, along with a mechanism in place to document and improve the percentage level of compliance, that company has made a great leap forward over its competition.

You must remember that once the Standard of Care Program is put into place with compliance levels greater than the minimum regulatory requirements, the company will be held to that level of compliance.  Its failure to meet the level of compliance could result in the company being fined, prosecuted or sued with little or no way of defending itself.

Checked - LowRes - shutterstock_242884063It is, therefore, critical to the entire process that a monitoring program is put in place to continually provide feedback, identify problem areas and determine the compliance level the company is meeting.  It is a complete waste of time developing and implementing a Standard of Care Program without a monitoring component being put into place.

 

Development of a Standard of Care Program

For the plan to be successful, companies must make regulatory management a key objective in the company’s overall operational strategy.  Responsibility for the plan’s implementation and ongoing operation needs to be placed at a senior management level, with access to the CEO.

As mentioned previously, the task can be very daunting when you start to consider all the components that go into developing a Standard of Care Program.  My solution is the old saying: “How do you eat an elephant? One bite at a time”.

In my view, a reasonable approach is to identify all the technical and regulatory requirements your company must meet.  Then review each document to see how it impacts your company’s operation. Develop a running list of all the company’s offerings and activities.

Eventually, you need to create a roadmap which consolidates the technical and regulatory requirements with the company’s operational objectives, employee needs, and customer expectations.  The map provides the big picture overview you require to fully understand the components that will go into developing the plan and the direction to follow.

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Bonding of the Gas System

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Since 2010, the B149.1 Natural Gas and Propane Installation code requires propane and natural gas systems to be bonded. This article, which first appeared in the Mar/Apr 2013 edition of Propane Canada magazine, discusses how bonding of the gas system is achieved and includes key definitions related to bonding.

Since writing the article entitled “The Need for Bonding of Corrugated Stainless Steel Tubing (CSST) Systems”, which first appeared in the Jan/Feb 2013 edition of Propane Canada magazine, I’ve had several requests for additional information explaining how one actually goes about bonding propane and natural gas systems.

When the 2010 CSA B149.1 Natural Gas and Propane Installation Code was published and adopted by provincial regulation, the bonding of propane and natural gas piping systems became a requirement of the Code.

Key Definitions

The following terms and definitions are commonly used to describe technical requirements:

Bonded (Bonding)
Connected to establish electrical continuity and conductivity.

Bonding Jumper
A reliable conductor to ensure the required electrical conductivity between metal parts required to be electrically connected.

Grounded (Grounding)
Connected (connecting) to ground or to a conductive body that extends the ground connection.

Grounding Electrode Conductor
A conductor used to connect the system grounded conductor or the appliance to a grounding electrode or to a point on the grounding electrode system.

Grounding Electrode System
Electrodes can be a metal rod/pipe/plate driven into the ground; the metal frame of a building; buried metal or copper water line into the building; a ground ring of copper wire; or a concrete encased foundation electrode.

Clause 4.7.3 of the Code requires that all interior metal gas piping that may become energized must be made electrically continuous and bonded in accordance with the requirements of the local electrical code or, in the absence of such, the Canadian Electrical Code, Part 1.

The 2012 Canadian Electrical Code Clause 10-400 (4) has the same wording as clause 4.7.3 in the CSA – B 149.1. Clause 6.14.6 of the Code does not permit propane and natural gas piping or tubing to be used for an electrical ground.  The clause states that an electric circuit cannot utilize piping or tubing in lieu of wiring, except for a low-voltage control circuit, ignition circuit, or electronic flame detection device circuit incorporated as part of an appliance.

The Canadian Electrical Code requires the house’s electrical system have a connection to earth to provide for its safe operation.  When other systems are connected to the electrical system and its grounding, those systems are “bonded” to the electrical ground.

Bonding is provided primarily to prevent a possible electric shock hazard for persons coming into contact with the gas piping and other metal objects that are connected to the grounding system, but which may be energized at a different level of electrical potential.

Gas piping can become energized by an electrical fault in the branch circuit of a gas appliance connected to the piping system.  Nearby lightning strikes can also result in an unbalanced voltage build-up and a resulting high electrical potential difference.

An electrical bond is an intentionally installed electrically conductive and continuous path from the gas piping to the grounding electrode system.  The systems that are bonded to the electrical system will have roughly the same electrical potential, so that if energized, they will all be energized at the same rate and at the same speed.  Thus, when the electrical system and the bonded systems are energized by an electrical fault or lightning, the possibility that the electrical energy will arc or jump from one system to the other is reduced because all those systems are at an equal electrical state.

A bonding wire from one metal component to another allows stray electricity to equalize through the wire so that one metal component will not have a greater voltage in it than another metal component, preventing arcing between the two metal components. However, if metal systems in the house are not bonded to the electrical ground, they will have a different electrical potential from other conductive systems in the house.

In the event those systems are energized by a high voltage event like lightning, then it is possible that the electricity being conducted and travelling on one metal system may come to a point where it is close to an adjacent metal system that offers a lower resistance or impedance path to ground.

It is possible that if the energy has enough voltage, it may jump over the air gap between the two adjacent metal systems, and use the second path to go to ground.  When the energy jumps that air gap, it generates an electrical arc that has a high voltage.

Photo #1 provides an example of grounding the house’s electrical system. The copper underground water service that runs from the water main in the street to the house acts as the in-situ grounding electrode.

Bonding Gas Systems 1

Photo #1 – 1) Underground water service line at entrance to house. 2) Bare grounding wire connecting electrical panel & water line. 3) Grounding clamp attached to water service line. 4) Water service shut-off valve. 5) Water meter.

Bonding is achieved by installing a wire of sufficient size from the bonded component to the electrical system ground.  Equipotential bonding is achieved when all metallic systems in a structure are bonded to the electrical system ground.

Minimum bond wire should be a number 6 AWG copper wire.  The bonding clamp must be attached such that metal to metal contact is achieved with the steel pipe component. Remove any paint or applied coating on the pipe surface beneath the clamp.

As discussed in my previous article on bonding of Corrugated Stainless Steel Tubing (CSST), the bonding clamps must be attached to the brass fitting, to a steel manifold or to a rigid pipe component attached to the CSST.  The corrugated stainless steel portion of the tubing system must not be used as the bonding attachment.

Bonding Gas Systems 2

Photo #2 – 1) Bare bonding wire. 2) Steel propane/natural gas piping. 3) Copper wire line to water heater. 4) Bonding clamps.

Photo #2 above, shows the bonding wire attached to the steel gas piping and the copper cold water line feeding the water heater.  The bonding connection is by mechanical clamps. UL-467-approved bonding clamps can be used.

Under no circumstances is any underground natural gas utility service line or the underground supply line from a propane storage tank to be used as a grounding electrode because grounding electrodes are intended to carry large currents.

This can expose the piping to the possibility of sparking which can create a hazardous condition if the service piping is undergoing any type of maintenance.

 

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Bonding of CSST Systems

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Corrugated Stainless Steel Tubing (CSST) has become a popular material for gas installations.  This article, which first appeared in the January/February 2013 edition of Propane Canada magazine, discusses the importance of bonding (CSST) systems to avoid electrical arcing which could perforate the tubing.

I have recently been retained to investigate two incidents where it is believed that unbounded Corrugated Stainless Steel Tubing (CSST) has been subjected to electrical arcing, resulting in the wall of the CSST being perforated. The leaking propane was ignited by the electric arc that perforated the tubing wall. The resulting fires caused extensive damage to the structures in which they were installed. I would, therefore, like to take the opportunity in this article to raise awareness of the need for bonding of CSST gas systems.

The material requirements for tubing first listed CSST in the 2005 edition of the CSA/BI49.1 Natural Gas and Propane Installation Code. The previous codes and editions contained a clause that permitted the use of materials not specified in the Code if they conformed to a nationally recognized standard or to a test report of a nationally recognized certification organization. Information on file indicates that CSST has been installed in Canada since at least 1998. This was prior to the bonding requirements being put into the manufacturer’s installation instructions and training programs.

Each manufacturer of CSST requires that a certified propane technician take an installation training program, which is required as part of ANSI LC 1-2013 / CSA 6.26-2013, Fuel Gas Piping Systems Using Corrugated Stainless Steel Tubing. The training courses are to ensure that only qualified propane technicians install CSST. The training requirement will also prevent CSST from being available at home improvement stores.

What is CSST?

In Canada, CSST is certified by ANSI LC 1-2013 / CSA 6.26-2013, Fuel Gas Piping Systems Using Corrugated Stainless Steel Tubing. CSST consists of stainless steel corrugated tubing that may or may not be sheathed by a polymer conformal coating.  Each manufacturer appears to have developed their own system for achieving couplings/connections.

CSSTThe flexible tubing comes in 100-foot rolls that can be cut to length, and be bent and conformed by hand, allowing for quick and easy installation with a limited number of connections.  Simple economics have contributed to CSST popularity since its introduction in 1997; the product is less expensive and requires far less time and skill to install.  CSST tubing cuts easily with a standard tube cutter and requires no threading or welding, and no special tools to seal the fittings. The CSST gas line also weighs far less than rigid gas pipe and is less bulky to store, transport, and handle. During the installation process, the flexible CSST product can make turns without the need for installing threaded and sealed pipe elbows.

The CSST gas line is extremely thin, with walls typically around 0.008″ in thickness. Black iron gas pipe is typically 0.12″ thick, making the walls of black iron pipe 15 times thicker than the walls of CSST tubing. Conversely, the amount of electrical energy needed to perforate the wall of traditional black iron pipe is about 15 times more than the energy needed to perforate the much thinner walls of CSST tubing.

Electrical Arcing on CSST

The thin wall thickness, required to permit easy routing of the tubing, has resulted in a material that is easily punched through by electrical arcing. Once the tubing has been perforated, it is possible for the escaping gas to be ignited by the arcing process or by adjacent open flames.

One manufacturer’s installation instructions state that although the tubing provides significant advantages over more rigid gas delivery systems, its wall dimensions may make it more likely than steel pipe to be punctured by a nail or other sharp objects, or damaged by other extraordinary forces such as a lightning strike.

CSST-damagedIt is well known that lightning is a highly destructive force. Therefore, the user must ensure that the system is properly bonded and grounded. In order to maximize protection of the entire structure from lightning damage, the user should consider installation of a lightning protection system.

The installation instructions go on to require that the gas tubing system be bonded to the electrical earth grounding system of the structure through the use of a bonding clamp and wire.

The section further states that “proper grounding and bonding may reduce the risk of damage and fire from lightning strikes. Even a nearby lightning strike that does not strike a structure directly can cause systems in the structure to become energized. If the systems are not properly bonded, the difference in potential between the systems may cause the charge to arc to another system. Arcing can cause damage to C55T. Correct bonding and grounding should reduce the risk of arcing and related damage”.

One other possible cause of electrical arcing perforating the CSST is a failure of the structure’s electrical system, resulting in the wiring’s protective coating being damaged, exposing the bare wires to the CSST.

In this type of scenario, the resulting ignited propane leak would not be the primary or secondary cause of the structural damage but a third result of the fire origin. The fire origin could have been started by the electrical wiring or a source that resulted in the fire origin compromising the electrical wiring system within the building.

When installing CSST, care should be taken to maintain as much separation as possible from other electrically conductive systems in the structure. With respect to determining which electrical source actually caused the perforations in the CSST, the author of a recent article wrote: “We must state, however, that in our opinion, the perforated gas line can normally stand on its own in terms of evidentiary value; we know of no other phenomenon that would create a clean arced hole other than lightning. If a copper wire arced to the stainless steel tubing, there should be copper remnants found. Likewise, the melting point of stainless steel will not be reached in most fires.”

Electrical Bonding and Grounding

The house’s electrical system must have a connection to earth to provide for its safe operation.  When other systems are connected to the electrical system and its grounding, those systems are “bonded” to the electrical ground.

Bonding is achieved by installing a wire of sufficient size from the bonded component to the electrical system ground.  Equipotential bonding is achieved when all metallic systems in a structure are bonded to the electrical system ground.  The systems that are bonded to the electrical system will have roughly the same electrical potential, so, if energized, they will all be energized at the same rate and at the same speed.

Thus, when the electrical system and the bonded systems are energized by lightning, the possibility that the lightning energy will arc or jump from one system to the other is reduced because all of those systems are at an equal electrical state.

A bonding wire from one metal component to another allows stray electricity to equalize through the wire so that one metal component will not have a greater voltage in it than another metal component, preventing arcing between the two metal components.

However, if metal systems in the house are not bonded to the electrical ground, they will have a different electrical potential from other conductive systems in the house.  In the event those systems are energized by a high voltage event, like lightning, then it is possible that the electricity being conducted and traveling on one metal system may come to a point where it is close to an adjacent metal system that offers a lower resistance or impedance path to ground.

It is possible that if the energy has enough voltage, it may jump over the air gap between the two adjacent metal systems, and use the second path to go to ground.  When the energy jumps that air gap, it generates an electrical arc that has a high voltage.

CSST bonding requirements provide an effective electrically continuous path in an effort to conduct stray voltage/current safely to the ground.  The bonding point must be in close proximity to the electrical panel as practical.  The wire gauge for this bond must be sized, at a minimum, for the full amperage available through the electric service.

For attachment to the CSST, bonding clamps must be attached to the brass fitting, to a steel manifold or to a rigid pipe component attached to the CSST.  The corrugated stainless steel portion of the tubing system must not be used as the bonding attachment. CSST or other gas piping system components must not be used as a grounding electrode or as a grounding path for appliances or electrical systems.

One manufacturer, Omegaflex, has developed a CSST product called “Counterstrike”, which is specifically designed to dissipate the energy from electrical arcing by enclosing the flexible tubing with a proprietary jacket (black in colour), made from a material which is both thicker and conductive.

The product is designed to spread the electrical energy over the entire length of the run, allowing it to dissipate rather than concentrate at anyone point on the CSST.  In theory, at least, this should reduce the potential for breaching of the gas line during instances where the CSST is energized by an electrical source.  Counterstrike’s installation instructions still require bonding to a ground.

In conclusion, it is imperative to read and follow the manufacturer’s installation instructions to make sure you are installing the CSST properly and that you have followed the manufacturer’s installation instructions to reduce the likelihood of electric arcing damaging the CSST.

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Fire Prevention and Fire Control at Propane Bulk Plants

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Fire prevention and control is key to minimizing risk at the bulk propane storage plant.  This article, which first appeared in the Nov/Dec 2012 edition of Propane Canada magazine discusses the various aspects of fire control and prevention that should be considered.

A client recently asked me, as part of their internal due diligence, to verify that appropriate fire prevention and fire controls were in place and operational at one of their propane bulk plants.  The audit looked at the physical aspects of fire prevention and control as well as related policies and procedures.  The following discusses the items that were addressed in the audit.

Site Security

Site security is the main factor in preventing unauthorized persons from entering the actual propane bulk tank storage yard.  Unauthorized persons may unwittingly provide a source of ignition by either smoking or in the type of clothing they wear.  Nylon outer clothing, shirts, jacket or pants can build up static electricity which can arc with sufficient energy to ignite propane vapours.

The yard must have a controlled entry point.  Gates are used to provide the controlled entry point and fencing around the perimeter of the yard provides the security.  Signage at the entrance to the fenced yard warns unauthorized persons not to enter.  Gates to the propane bulk tank storage yard must be closed and locked when the plant is not in use.

visitors-must-sign-log-sign-s-6763A visitors log is a good way to record who and when a non-employee enters the yards.  Do not let visitors enter the yard unless escorted by an employee at all times. The escorting of non-employees ensures that the visitor does not inadvertently wander into yard traffic areas or propane transfer areas without the benefits of the proper clothing and that the visitor can be led to the evacuation meeting place should an emergency occur.  These rules should apply to the general public as well as municipal, provincial or federal employees attending the facility as part of their work.

It is also important to control the vehicles entering the fenced yard.  Only allow essential vehicles to enter the fenced yard.  Do not permit customer vehicles or employee vehicles to enter or park in the yard area.  Provide parking spaces for customers and employees outside the fenced yard.  Bulk trucks and cargo liners which are stationed out of the facility must, when parked, be within the fenced yard area.

Tank Protection

To prevent the release of propane from a damaged propane container or piping system, propane bulk storage tanks, as well as transient tanks and cylinders, must be protected from physical damage by either their location or barriers such as concrete filled posts, steel guard rails, and post or New Jersey concrete turnpike barriers.

Signage

No smoking signs, turn off ignition signs, and UN1075 placards, as well as the company name and logo, stenciled on the propane bulk storage tanks, bulk trucks and cargo liners can act as a constant warning as to the product stored and transferred at the plant.

Dispenser Warning Signs 01 - Original

Training

A key component of fire prevention is training.  Trained and certified personnel must only be allowed to drive bulk trucks/cargo liners, load and unload and to operate the facility.  Ensure that employees have the correct training and level of certification before allowing them to perform any functions within the plant.

Clothing

It is essential that persons working within the propane bulk storage yard wear the appropriate clothing.  Clothing can be cotton or blends of material as long as it does not build up a static electric charge.

Control of Ignition Sources

When looking at controlling ignition sources one must consider the installation of the bulk storage tanks, ongoing maintenance of the grounds and components, leak control and propane released during the transfer process.  Ignition sources are controlled within a propane bulk plant by incorporating employee training, wearing appropriate clothing, and by:

  1. Ensuring that distances listed in the Code are initially provided and maintained from tanks and points of transfer, property lines and buildings.
  2. Ensuring the area around and under the bulk storage tanks gravel or asphalt are free of vegetation or material storage.
  3. Having all electrical components rated explosion proof Class 1, Group D.
  4. Using hose end valves at unloading and loading bulkheads which are designed for limited liquid propane release on disconnect.
  5. Equipping Liquid and vapour openings in all tanks with Internal Safety Control Valves (ISC) that are closed when the plant is not in operation.
  6. Unloading of cargo liners and loading of bulk trucks is through bulkheads equipped with Emergency Shut-off Valves and back check valves.
  7. Having a grounding system in place at all unloading and loading bulkheads to prevent the buildup of static electricity.
  8. Using CSA certified hose assemblies used to transfer propane in and out of the plant which are inspected and tested annually in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.
  9. Permitting only cargo liner tanks and bulk truck tanks which are built, inspected and tested in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.

Fire Control

Fire control relies on the physical plant design, components, and internal and external resources. The following is a list of items that one would expect to be in place to control a fire within a propane plant.

  • Nitrogen or air activated valves with emergency shutdown stations located around the plant. As a minimum, shut down stations would be at each loading and unloading bulkhead and a safe area outside of the fenced yard.
  • Air actuated Internal Safety Control Valves (ISC) and Emergency Shut-off Valves (ESV) which close on loss of nitrogen or air pressure. Nitrogen or air pressure is supplied by plastic tubing that melts if exposed to temperatures generated by fire or radiant heat causing a loss of air pressure within the system resulting in the automatic closure of all ISC and ESV valves.
  • Plants equipped with cable operators which have fusible links that melt if exposed to temperatures generated by fire or radiant heat causing the cable to separate which allows the ISC or ESV to close
  • Hand-held fire extinguishers must be placed strategically around the facility to help control possible fire situations. Fire extinguishers must also be inspected and tagged annually by a company that specializes in maintaining fire extinguishers. Part of the monthly plant inspection must provide for fire extinguisher inspection to ensure the fire extinguisher is actually in place and properly charged.
  • Since the local fire department (which may be a volunteer force) responds to calls at the facility, it is important to meet with the fire services and obtain a listing of the equipment that can be used to respond to a fire at your facility. This is also an opportune time to have the fire services visit the site.
  • Sufficient space maintained in the yard to maneuver fire trucks for position to fight fires.
  • Provincial or local fire services may also request additional fire suppression systems to be installed with a dedicated water supply to cool tanks and provide protection for emergency response personnel.
  • It is a prudent exercise to look at the fire prevention and fire control systems and processes at your propane bulk storage plant on an annual basis to ensure that the correct policies and procedures are in place, all components are maintained and operate as required and that employees know what to do in the case of an incident.

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Third-Party Contractors

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Many propane retailers rely on third-party contractors to conduct work on their behalf. This article, which first appeared in the May/Jun 2012 of Propane Canada Magazine, discusses what you can do to minimize risk and liability arising from the actions of your third-party contractors.

In previous articles I have written about policies and procedures, preparing for emergencies, installer responsibilities, and installing approved appliances and equipment. In this third article for 2012, I will continue the due diligence theme of how a company can meet its regulatory obligations while using independent third party contractors and possibly avoid being caught up in litigation due to an incident.

Many fuel distributors use third-party persons (independent contractors) to deliver propane or fuel oil to their bulk plants, deliver cylinders to cylinder exchange cages, and install propane and fuel oil appliances and equipment.  The question I am asked is “As a fuel distributor what are my regulatory obligations with respect to using third-parties to perform services on behalf of my company?”  While you can have contractual arrangements which define the business relationship it is important to understand that when it comes to third parties conducting operations on your property and doing installations on your behalf, you also have obligations to ensure that the technical work is being done in accordance with the Acts, Regulations, and Codes.

Certification

shutterstock_392416306Provincial regulations require that persons operating cargo liners and installing fuel oil and propane appliances and equipment must be certified to perform those functions. The certification can be a provincially issued certificate or a Record of Training (ROT) recognized by the Authority Having Jurisdiction such as the Fuels Learning Centre.  Your due diligence as a fuel distributor is to ensure that all third parties performing work for you are certified for the work to be performed.

This means that you should have a copy of each person’s certificate or ROT on file so you can verify that they are certified and that the certification is for the degree of work for which you are retaining their services. The verification of certification will be an ongoing request as certificates and ROTs have expiry dates and the file must contain the currently valid certificate or ROT.

Licensed Contractor

For third-party contractors doing fuel oil and propane appliance and equipment installation, the next file should include any provincially required registered contractor licenses indicating the contractor is licensed to act as a contractor in your province. Again, contractor licenses have an expiry date and the file must be kept up to date with the current license.

Operations on your site by third-party contractors

Cargo liners and tank trucks delivering fuel oil or propane must be constructed and maintained in accordance with Transportation of Dangerous Goods Regulations (TDG). Some provinces conduct separate inspections and actually issue a license to transport. The TDG regulations require that propane cargo liner tanks undergo an annual leakage test and a 5-year inspection. If you receive fuel oil or propane from a third-party, independent contractor then as part of your due diligence process you should be asking for copies of inspection certificates for the cargo liners and tank trucks that deliver fuel to your site. Retain the inspection certificates in a file. This will also be an ongoing process as the file should contain the most current inspections.  It is not in your company’s best interest to allow equipment on your bulk plant site that is not well maintained and or does not meet current regulatory requirements.  Failure to ensure this opens the door to potentially being implicated in an incident that may not be your fault.

If you lease a portion of your bulk plant property for other third-party activity such as cargo liner parking, installation contractor or cylinder exchange storage, past experience has shown that it is best to physically separate the third party from your bulk plant activity. Ensure that the third party is independently licensed to operate, not connected to your license to operate a bulk plant. It is important that you have an understanding of the activities conducted by third parties on your property.

With respect to cargo liner and tank truck parking, and cylinder storage, arrange with your tenant to walk around on a regular basis to make sure what you have agreed to is actually occurring and to take care of any potential issues such as quantities stored, storage configuration, fire service access etc.  Also, the third-party staff working at your site should be included in your emergency evacuation plan. Keep a file of your visits and any activity conducted as a result of those visits.

Audits

warranty-iconSome provincial jurisdictions perform appliance and equipment installation contractor audits to ensure the contractor is certified and is doing the work in accordance with the Act, regulations, and codes. However, a reasonable due diligence process on your part is to conduct and document your own audits on work performed by independent contractors working on behalf of your company.

The audit process does not have to be onerous in nature in that you can audit a small percentage of the installations. If you find issues of non-compliance then you may have to increase the number of audits to provide a comfort factor that the installations are being done correctly. Use the inspection forms you would normally use for supplying propane to a new customer as your audit guide. Retain a copy of the documented audit in your independent contractor audit file. I find if you keep these files separate from the customer file it is much easier to locate the audit documents if an issue arises.

Company Policies and Procedures

When a third party contractor is performing work on behalf of your company, it is critical they follow your company’s policies & procedures. This ensures that the contractor and you are both working from the same set of guidelines and that regardless of whether it is your direct employee or an independent contractor the interaction with your customer and the work performed is consistent and meets your company’s standard of care. Again, as part of your due diligence process, provide a copy of the company’s policies and procedures manual to the contractor and obtain a signature from each individual working for the contractor stating that they have read the manual and agree to abide by the manual’s requirements.

Policy and Procedures 01 - LowRes - shutterstock_310886999

Training

Responsibility 01 - LowRes - shutterstock_293155331A certificate or ROT indicates that a person has reached a certain skill level. There are jobs which require immediate additional training for the person to complete the task safely and efficiently.  For example, once a cargo liner driver receives a ROT to indicate they have taken the training and successfully passed the examination to operate a cargo liner there is a need for site specific training prior to that person making a delivery to the site.

Third party cargo liner deliveries can occur outside of regular business hours where the driver is the only person at the site. Therefore, it is imperative that the driver not only fully understand how to safely unload at the plant, but what emergency response procedures are to be carried out by the driver if an incident occurs. This type of training should also be documented and retained on file.

Another type of training beyond the certificate or ROT is specific manufacturer’s training. If your company is involved in manufacturer training, offer the training to your third-party contractor as well. Document and retain all training activities.

Conclusion

In conclusion when working with third-party contractors make sure the company is registered to conduct the business, the employees are certified and have received any additional training to perform the tasks for which they have been retained, provide your company’s policies & procedures, perform some type of audit to ensure that the work is being performed in accordance with the Act, regulations, and codes and, finally, ensure you properly document the terms and qualifications of your third-party contractors.

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