Transport Canada Proposed Changes to TDG Regulations to Harmonize With International Standards

Transport-Canada-Logo2Transport Canada has proposed changes to the TDG Regulations that will support harmonization of the regulations with international standards. Some of the proposed changes affecting the propane industry include:

  • Automatic adoption of reference codes (B339, B340, B62, B621);
  • Exemptions for some propane cylinders used to fuel hot air balloons;
  • Allowing of DOT cylinders to be filled in Canada; and
  • US recognition of TC Equivalency Permits.

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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.

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 - 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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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 (;
  • Alberta OHS Code;
  • Alberta OHS Explanation Guide;
  • BC OHS Regulation;
  • NFPA 58 LP Gas Code Handbook Clauses & 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.

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.”


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.


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.


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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Fire Prevention and Fire Control at Propane Bulk Plants

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.


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


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.


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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