Incorporating B149 Code Changes Into Daily Operations

This article, related to incorporating B149 code changes into daily operations, first appeared in the 2015 Nov/Dec edition of Propane Canada Magazine.

My last few articles have provided information and discussed the ramifications of the regulatory impact the 2015 editions of the fuels and pressure vessels codes and provincial regulations will have on the propane industry. I like to believe that one of the purposes of these articles is to provide information on the regulatory regime as it develops so that company owners and users of the relevant code and regulations can be proactive rather than being reactive to new requirements.

This got me to thinking that it is great to provide this information but what does a person do with it once they have received it?  If the information ends with the reading of the article and no further steps are taken, then the regulatory impact will result in a non-compliant position subject to the legal means available for enforcement of the codes and regulations by the Authority Having Jurisdiction.


I learned long ago that knowledge, and the ability to translate that knowledge into workable solutions, is key to being proactive and keeping one step ahead of the game. I would, therefore, hope that my articles provide the trigger for readers to take the next steps.

Steps might include identifying areas requiring additional or new development of policies and procedures, as well as to identify training initiatives necessary for employees to continue to complete their tasks in an efficient, cost-effective, and safe manner.

Training Requirements

Training is very vital in any company or organization that aims at progressing. Training simply refers to the process of acquiring the essential skills required for a certain job. It targets specific goals, such as understanding a process or operating a certain machine or system.

It is common knowledge that a properly trained person becomes more informed about procedures for the various tasks he or she must complete and that the person’s confidence is also boosted by training and development. This confidence comes from the fact that the per-son is fully aware of his/her roles and responsibilities. It also helps the person to carry out the duties in a better way and even find new ideas to incorporate into the daily execution of duties.

Legalese Clauses

ComplianceRegulations are written in what I describe as “legalese” which means that the lay-man’s clause wording developed and accepted by the working Technical Committees is reviewed and possibly edited by lawyers to ensure that the clause requirement meets the minimum standard required for enforcement by the Authorities Having Jurisdiction. This sometimes ends up with the clause not being quite as clear or concise as it was when the technical committee first developed the clause and therefore makes it difficult for the worker in the field to feel comfortable interpreting the requirement.

This is where the policies, procedures, and training come into play by ensuring, whether a person is a technician, fuel delivery person or plant operator, that each person in that position gains similar skills and knowledge. This brings each position to a higher uniform level, making the workforce more reliable in completing the task correctly the first time.

More Than Having a New Code

When one understands the requirements for uniform regulatory knowledge, the legalese of the written clauses, and the need for new technical knowledge, the need for effective training becomes evident. The training of technicians, fuel delivery personnel and plant operators is just not as simple as giving those persons a copy of the latest code and provincial regulations.

Recap of 2015 Regulatory Impact

While there have been numerous changes within the 2015 code editions, there are three primary regulatory initiatives which will require propane company owners and users of the codes and regulations to develop and/or edit existing policies and procedures.  These changes will also require training of staff to ensure they can correctly complete the tasks required for the company to meet its regulatory compliance obligations for 2016 forward.

(1) Pressure Relief Valve (PRV) Change Out

As previously stated in my May/June 2015 article on this subject, it is my opinion that this requirement is most likely going to be the most challenging regulatory requirement the propane industry has faced in its history.  This single requirement will put a tremendous strain on the industry’s resources, people, equipment, and finances.

Even before there is any field activity on the replacement of PRVs it is essential the company have in place the necessary policies and procedures and trained staff to perform the actual field work.

The task of replacing PRVs is not as straightforward as it sounds and can be-come quite complicated and complex when you have to consider the logistics of:

  • keeping customers supplied with propane;
  • exchanging the customer’s propane tank (which could require evacuation of the product on-site);
  • dealing with tank components which may not operate as designed or are not available to evacuate the pro-pane from the tank;
  • transporting tanks from the plant to the customer site and then back to the plant;
  • evacuation of the propane from the tank at the plant; and finally
  • replacing the PRV.

This means that companies should already be diligently working on developing their policies and procedures, identifying relevant training programs, and scheduling the training of technicians, helpers, and bulk truck drivers as soon as possible.

(2) Construction Site Cylinder Storage and Use

Cylinder Storage at Construction SitesThere are extensive new requirements that affect how propane cylinders are stored and used on construction sites.  As with the PRV change out, companies will be required to provide new/edited policies and procedures and additional training for cylinder delivery personnel.

Several provinces and territories automatically adopt the latest edition of the code once it is published. For example, the B149.2 Propane Storage and Handling Code was published by CSA in Au-gust 2015.  Provinces and territories that have not already adopted the 2015 code will be doing so in 2016.  This means that some delivery personnel delivering to construction sites for the 2015/2016 winter construction heating season must be trained in the new requirements. In addition, the company must have in place policies and procedures describing how the Company will deliver propane cylinders to the construction site.

(3) New Propane Facility Maintenance Requirements

The purpose of the new clauses in the code is to provide a minimum standard for the operation and maintenance of propane facilities and equipment. The new clauses apply to tank systems, filling plants, container refill centres and other facilities where liquid propane is piped to a vaporizer or process. Because there are many variables, it is not possible for the Code to prescribe a set of operation and maintenance procedures that will be adequate from the standpoint of safety in all cases without being burdensome and, in some cases, impractical. The proposed clauses establish a baseline or minimum standard.

The maintenance procedures are to cover testing, inspection, monitoring, and documenting of the equipment, its repair, and general upkeep.

There is also a requirement for persons who perform maintenance on facility propane systems to be trained in the hazards of the system and in the maintenance and testing procedures applicable to the facility.

Once again, this requirement is already in place in some provinces and territories and will be coming into force 2016 in those provinces and territories that do not automatically adopt the latest edition of the code.

These new requirements will require some companies to develop new policies and procedures with respect to maintenance of the propane facilities described and others to edit the policies and procedures to address the new requirements.  Also, the training component is new within the code and therefore will require the identification of relevant training programs and the scheduling of personnel to take the training.

In Conclusion

It is my hope that this article will be the catalyst for the reader to become proactive and to take the next necessary steps to ensure that his or her company develops the policies and procedures, identifies the training initiatives required, and schedules the training of staff to meet the new regulatory obligations.

The Fuels Learning Centre has developed an extensive training program covering all of the aspects listed above for evacuating propane tanks regardless of location and the change out of the PRV.  The course is currently being studied by several Authorities Having Jurisdiction across Canada for their review and comment, as is the process for all new courses related to regulated activities.  It is anticipated this course will be available for our Instructors to conduct training on or be-fore January 1, 2016.

Also, we have developed a new course to address the requirement for persons who perform maintenance on propane facility systems to be trained in the hazards of the system and in the maintenance and testing procedures applicable to the facility.  We expect this course to be available for our Instructors on or before January 1, 2016, as well.

Our training courses for cylinder delivery and installation of construction heaters already provide the 2015 code requirements your staff and customers will require in order to complete their duties and keep the company in compliance for the 2015/2016 winter construction heating season.

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PRV Change Out Challenges

This article, regarding PRV change out challenges, first appeared in the 2015 May/June edition of Propane Canada Magazine.

As a consultant, I often get asked by clients to look at the risk associated with performing certain tasks and to advise on what is the best way to complete those tasks. I was recently asked to look at the processes and training skills required for a company to successfully meet their regulatory obligation with respect to the replacement of pressure relief valves (PRVs) in consumer propane tanks.

My review of this subject has led me to the conclusion that this is most likely going to be the most challenging regulatory requirement the propane industry has faced in its history.  This single requirement will put a tremendous strain on the industry’s resources, people, equipment, and finances.

Now that the regulatory requirement is in place to change out the PRV, it is time for serious discussion on how this is actually going to be accomplished.

Three Basic Steps for PRV Replacement

When one talks about the replacement of a PRV in a propane tank, there are three basic steps:

  1. Disconnection of the propane system to which the tank is connected;
  2. Removal of all liquid and vapour propane so that the tank’s internal pressure is 0 psig; and
  3. Removal and replacement of the PRV.

These three steps sound fairly straight forward until one gets into the details of how this is going to occur.

Removing liquid propane from the tank is much easier said than done

The majority of consumer propane tanks are not equipped with an easy method of removing the propane liquid from the tank.  A limited number of tanks are equipped with a liquid withdrawal excess flow valve (Chek-Lok) mounted on top of the tank with a dip tube, or directly into the bottom of the tank that can be used to remove the liquid propane from the tank.  If the Chek-Lok does not work properly, then you are back to the situation of how to remove the liquid from the propane tank.

Using a Flare Stack

Flaring of PropaneOne method is to use a flare stack to burn off the propane within the tank.  Depending upon the quantity of liquid propane in the tank, this is quite a time-consuming process that does not lend itself to being conducted at the customer’s location.  Can you imagine flaring off a propane tank in the customer’s backyard?  The flare stack creates a large flame and a lot of noise; not the type of situation that would make the public feel safe in their own homes.  Also, you would have to notify the local fire department, who may want to attend, which is not a good scenario overall.

Using Tank Rollers

Another option for evacuating the tank, which has been brought to my attention is the use of tank rollers to roll the tank so that the vapour space now becomes the liquid space.  There is an adapter that can be connected to the fill valve to ex-tract the liquid propane by gravity from the tank to a pump to fill the new tank. This method requires the tank to be elevated so that the necessary fittings and connections can be completed.  Unfortunately, this practice also puts the PRV in the liquid space, so if the PRV does activate for any reason, the liquid will be released to the atmosphere creating a rather dangerous scenario.

TDG Requirements

1075 PlacardOne of the major hurdles is the Transportation of Dangerous Goods requirement which only allows consumer propane tanks to be transported with a maximum liquid volume of 5%.  This means that to transport a propane tank from a customer’s location to a location where the tank can be evacuated prior to PRV replacement, its volume must be less than 5%.  Update:  In 2016, Transport Canada issued an Equivalency Permit allowing members of the Canadian Propane Association to move tanks up to 500 USWG with more than 5% directly back to the propane bulk plant for evacuation under a number of conditions.  While helpful, the permit creates other issues related to the transport of the tank since it will have to be secured on proper cradles to prevent movement of the tank and damage to the feet.  Tanks larger than 500 USWG will still have to have the contents reduced to 5% or less of maximum capacity.

It’s also important to note that Alberta Transportation once had a permit which allowed movement of ASME tanks to be moved with more than 5% capacity within the oil-patch.  This permit was ultimately revoked due to flagrant misuse of the permit.  Incidents involving misuse of this permit may result in revocation of the Equivalency Permit.

One option is to allow the customer to use the propane in the tank so that the liquid level is below 5%. This approach is not a feasible way of reducing the pro-pane liquid volume to a point where the tank can be transported since the scheduling of the tank’s replacement will have to be carefully orchestrated so the customer does not run out of propane.  Trying to schedule 30,000 propane tank replacements on an annual basis under this process seems to me to be quite a daunting task.

Really, when one considers the options available: PRV replacement at the customer’s location or transportation of the tank to a central point, such as a bulk plant, replacement at the customer site does not seem feasible.  So in essence, the only logical option is to exchange the customer’s tank and transport the old tank back to a central location where the PRV can be replaced in a controlled environment.

The Magnitude of Meeting this Regulatory Obligation

Bulk Storage TanksThere are approximately 750,000 propane tanks in Canada, which means the industry will have to exchange 30,000 propane tanks on an annual basis.  Given that at best, one can expect to conduct this type of work during the 6 to 7 month period of April to October, this will require 4,285 tank exchanges per month.

These numbers are based on every PRV having a 25-year change out as required by regulation.  Unfortunately, the industry is faced with the problem of replacing PRVs which have currently been in service for 25 years or more, and playing catch-up to get to a position whereby the 4,285 tank exchanges per month can be completed.  I don’t think anyone has a handle on exactly how many propane tank exchanges will have to take place on an annual basis for the industry to become current with this regulatory requirement.  Every company will have a different schedule based on the age of tanks in operation.

The CSA B51-14 Boilers, Pressure Vessels and Pressure Piping Code requirement for the replacement of PRVs does not provide for a phase-in period to allow the industry to deal with the existing PRVs that are currently in service longer than the stipulated change out times.  This means that industry members will have to go to each provincial jurisdiction to work out a schedule of replacement so that PRVs in service beyond the change out times can be left in service until such time the industry can deal with them.  If some type of change out schedule is not put into place, then the moment that the CSA B51 code is adopted in the province any PRVs that are in service beyond the time limits specified in the code would be considered non-compliant.  The fuel supplier cannot supply propane to a non-compliant installation.

Training Requirements

In looking at the certification and Records of Training (ROTs) required to change out a PRV in a propane tank, one must consider working with both liquid and vapour propane, which can require separate training certification.  The specific level of Propane Fitters Certificate required will be dependent upon the provincial requirements.  Provinces have different descriptions for the levels of Propane Fitters Certificates and what the certif-cate holder may do.  However, when handling liquid propane, a certified pro-pane fitter must also have a liquid propane (LP) endorsement attached to the certificate.

The training and certification required to replace a PRV will be dependent upon how the propane is to be removed from the tank.  There are two ways that the propane liquid and vapour can be re-moved from the tank:

  1. Allow the customer to use up as much propane liquid as possible so there is only a small percentage of liquid propane left in the tank;
  2. Transfer the propane into a new tank brought to the site for the purpose, then transport the customer’s old tank back to a central location for PRV replacement.

Remember, you cannot legally release propane to the atmosphere unless it is done as part of the transfer process i.e. through the fixed liquid level gauge.

If the customer’s propane tank is to be brought down to 5% or less liquid volume to permit it to be transported back to a central location and a replacement tank installed, it will require the person(s) to have the following certificates and ROTs:

  • Transportation of Dangerous Goods (TDG) training in order to transport propane tanks to and from the customer’s location;
  • ROT for the operation of a boom or crane truck for loading and unloading the tanks;
  • A Propane Fitters Certificate to shut down the propane vapour system and appliances, disconnect the pro-pane tank from the system; reconnect and reactivate at the end of the propane transfer process.
  • A Propane Fitters Certificate with a Liquid Propane endorsement to transfer liquid propane from the existing customer’s tank to the new tank; and
  • If the liquid propane is transferred from the customer’s tank directly to a propane tank truck then a person with an ROT to operate the tank truck and conduct the liquid pro-pane transfer would also be required.

Once the customer’s propane tank is back at a central location for the PRV to be replaced it will require the removal of the remaining liquid and vapour propane in the tank so that the tank’s interior pressure is 0 psig.  Again in most jurisdictions, this will require the services of a certified propane fitter with an LP endorsement.  Some jurisdictions will permit a person holding an ROT for the operation of a propane plant to transfer the liquid and vapour propane out of the tank.

Update on Training

Since this article was first published in Propane Canada magazine, the Fuels Learning Centre has developed a comprehensive training course covering all the aspects of evacuating propane from the tank and how to operate the equipment required to conduct the evacuation.  Regardless of where the evacuation occurs (customer site or at the propane bulk plant), our Evacuating Propane From Consumer Storage Tanks (SO03) course provides all the necessary instruction for employees involved in the process.

Purging the Propane Tank

Another issue for discussion is that by removing the PRV from a propane tank you are exposing the interior of that tank to the atmosphere.  The regulations currently in place stipulate that if the interior of a propane container is exposed to the atmosphere, then it must be purged.  The regulations do not stipulate any period of time, so in essence, once the PRV is replaced, the tank should be purged.

To address this issue, testing is required to determine that if air does enter the tank during the PRV replacement, will the limited quantity have any effect on the operation of appliances connected to the tank.

Achieving Compliance Will be a Strain on Resources

In addition to staffing being a major concern, I also see challenges regarding the acquisition of equipment required to simply change out a PRV.  This includes the purchase of replacement PRVs and careful scheduling of crane trucks, tank trucks, tank moving equipment, compressors, pumps and flare stacks.

In conclusion, this single regulatory requirement has a tremendous mushrooming effect in that there will be mandated up to 30,000 more propane transfers and approximately 60,000 more propane tank transports down our highways on an annual basis.  The industry’s actual experience of PRV failure is nonexistent, with only one reused PRV failure in 25 years as we discussed in our Knowledge Base article entitled “History of PRV Service in Canada“.  One must question the increased risk of additional transfers and transports versus actual experience.

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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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Documenting Compliant Propane Installations

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

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

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

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

Using Approved Appliances

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

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

Approval Labels from Recognized Testing Organizations

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

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

CSA SymbolIntertek logoUL Certified

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

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

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

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

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

Use a Checklist as Part of Documentation

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

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

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

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

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

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

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Standard of Care

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.


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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