BCSA Issues Bulletin on Propane Vapourizer Emergency Shutdown System Requirements

On August 14, the BC Safety Authority issued a Bulletin to address clearance requirements for emergency shutdown systems on tank systems connected to direct-fired vapourizers.  The amendments to the requirements ensure compliance in limited installations, such as at construction sites.

To read and download a copy of the bulletin, click on the “Read More” button below.

Read More

SaskPower Issues Revision for Emergency Shutdown Systems on Propane Vaourizers

Saskatchewan - SaskPower

In February 2017, SaskPower issued Bulletin 01-2017 amending the B149.2-15 code to address clearance requirements for emergency shutdown systems on tank systems connected to direct-fired vapourizers.  The amendments to the requirements ensure compliance in limited installations, such as at construction sites.

Read More

Alberta Issues Gas Safety Variance Related to Emergency Shutdown Systems at Construction Sites

Alberta LogoAlberta Standata Logo

This Gas Safety Variance addresses the limited space for proper installation and servicing of tanks, vapourizers and emergency shutdown systems at construction sites.  The variance specifically address the distance between direct-fired vapourizers and emergency shutdown system.

Read More

Alberta Municipal Affairs, Safety Services Issues Revision to Bulletin Related to Temporary Heat for Construction Sites

Alberta LogoAlberta Standata Logo

This is the 2nd revision to Bulletin G-08-01-B149.1/B149.2 which describes the requirements associated with the use of construction heaters and torches at construction sites. The revision addresses how changes to the 2015 edition of the B149.1 and B149.2 affect these requirements.

Read More

TSSA Issues New Requirements for Training Related to the Use of Construction Heaters (CH01 & CH02)

Ontario - TSSA Logo 01TSSA has issued new standards for what is to be included in training programs offered by Accredited Training Providers related to TSSA’s ROT categories CH-02 and CH-02.  This affects training programs related to the safe use of construction heaters.  Accredited Training Providers, including Fuels Learning Centre are required to update their materials to address the new requirements and submit to TSSA for approval.  Previous versions of training are not authorized for use after May 1, 2016 without TSSA approval.

Read More

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.

Knowledge

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.

Read More

Impacts of Regulatory Changes for Construction Heater Lessors

 

This article, related to the impact of propane regulatory changes to lessors of construction heating equipment, was initially prepared for distribution at the Ontario Chapter of the Canadian Rental Association’s 2015 annual meeting and trade show.

Introduction

Over the past several months, the Fuels Learning Centre has been pleased to provide information pertaining to changes to the regulations affecting the use of construction heaters and cylinder storage at construction sites. This information was printed in three recent Canadian Rental Association (CRA) Ontario newsletters. This article provides a summary of the propane regulatory changes that have been amended, added and deleted in the CAN/CSA B149.2 Propane Storage and Handling Code that affect the use and storage of propane cylinders and equipment at construction sites and industrial storage.

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

The 2015 editions of the Code is the completion of a 5-year code cycle that CSA uses to keep the Codes updated to address new technologies, new installation materials, and changing building environments.

Training Requirements

Provincial Regulations require the lessor of a construction heater to ensure that the lessee is instructed in the safe installation and use of the construction heater and its components and that persons who install propane cylinders and propane fired construction heaters and torches hold a recognized Record of Training (ROT) for the purpose.

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 tank truck and cargo liner drivers, cylinder truck operators and construction site operators, to have their employees trained on the new requirements rather than wait until such time that the person’s ROT is up for renewal.

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

Ontario Adopts Portions of 2015 Code

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

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 was October 1, 2014, which means training programs must reflect the latest regulatory requirements as of October 1, 2014, for Ontario and in other provinces later in 2015. Construction heater lessors should ensure their training providers have updated their programs to reflect the new requirements. The Fuels Learning Centre currently offers three programs related to the safe installation and operation of construction heaters and torches reflecting all the new regulatory requirements.

If training is required on both construction heaters and torches, then AV01 is the correct course to take.  If training is required only for construction heaters, then AV02 is the correct course while AV03 focuses on hand-held torches only.

New Definitions and Clauses

Construction Site
The new term defines a Construction Site as “a temporary worksite involving construction activities such as the erection, alteration, and dismantling or demolition of a building or equipment, re-roofing of a building, or digging”.  The term was added to identify that the handling of cylinders and propane apparatus in use or in storage at construction sites are subject to significantly differing situations.

Propane Cylinder Installation
Clause 5.10 originally restricted cylinders from being installed under any fire escape, stairway, or ramp used as a means of egress from a building.  The clause has been amended to read “container” so the restriction now applies to both cylinders and tanks.

Connected for Use
Means a propane container that is properly connected to an approved appliance in accordance with the provisions of this code.  The rationale behind adding this new term relates to disputes which have occurred in the field over whether or not cylinders that are properly connected to an appliance that is not running, and which may or may not be turned on for use, are in storage and therefore subject to the requirements for storing cylinders.  Properly connected cylinders that remain connected for use, intermittent use, or future use, should not be subject to storage requirements.

New Clause 6.1.16
Cylinders in storage or connected for use, cylinder-regulating equipment, or a cylinder manifold, shall not be exposed to temperatures in excess of 125 degrees Fahrenheit or  50 degrees Celsius.  This clause was added to limit the temperatures to which propane cylinders, regulating equipment or cylinder manifolds can be exposed.

Use of OPDs

OPD Valve on CylindersClause 6.1.2 was amended to harmonize with US requirements. NFPA 58-2008 states that cylinders with 4 lb. (1.8 kg) through 40 lb. (18 kg) propane capacity for vapour service shall be equipped or fitted with a listed overfill protection device; the current Canadian requirement starts at zero, not 4 lbs. (1.8 kg) as in the US.  The Clause now states that except for (a) cylinders used in industrial truck service; and (b) cylinders identified and used for industrial welding and cutting gases, refillable vapour service cylinders manufactured after January 1, 2008 with a capacity of 4 lbs (1.8 kg) through 40 lb (18.2 kg shall be equipped with an overfill prevention device (OPD) in compliance with UL 2227.

Propane TorchOperators of propane torches must be aware of this requirement to ensure the cylinders to which they are connecting hand-held torches are equipped with an OPD valve unless the cylinder was manufactured before 2008.  It’s important to note that when cylinders are requalified, an OPD valve will be installed, therefore, the only cylinders that may not have an OPD valve were those manufactured between November 2004 and January 2008.

Cylinder Requalification

Propane cylinders must be visually inspected and requalified once every 10 years starting with the date of manufacture.  Clause 6.1.5 has been amended to remove the previous requirements for the 10-year cylinder inspection and requalification from the Code.  The clause now states that refillable cylinders shall not be refilled if they are due for requalification as prescribed by requirements of the CSA Standard B339 Cylinders, Spheres & Tubes for the Transportation of Dangerous Goods.

Users of propane cylinders at the construction site should be aware that a cylinder cannot be refilled if the requalification is past-due.

Single-trip Type Propane Cylinders

Clause 6.4.5 has been amended to clarify that Specification TC-39M and aerosol containers cannot be refilled.  In addition, Clause 6.5.1.4, which deals with the number of aerosol containers and TC-39 non-refillable cylinders which may be stored in a dwelling, was amended for correctness.

Single-trip small capacity propane cylinders are often used on the construction site and the site manager should be aware of the storage requirements and that these cylinders cannot be refilled.

Addition to Scope

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

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

Increase in Cylinder Size at Exchange Locations

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

Cylinder Storage Cages

To reflect current acceptable practices and to provide clear minimum design criteria that allow innovation, Clause 6.5.1.15 has been amended so that when cylinders are enclosed in a cabinet, cage, or other means not covered under clause 6.5.2.7 or 6.5.10, the confinement means shall:

  • be supplied with a top cover;
  • be made of noncombustible material and be structurally sound with no openings greater than 4 square inches (25.8 cm²);
  • have at least two sides constructed to provide equal ventilation through openings at the top and bottom of the side providing, as a minimum, the equivalent total opening of 15% open area on each side panel;
  • not restrict the dispersion of any fuel gas leak to ensure it is well ventilated;
  • have its base on a firm level footing in an upright position; and,
  • not be located against other objects, or have objects attached that restrict ventilation.

Storage of Cylinders & Sources of Ignition

To clarify requirements for storing cylinders Clause 6.5.1.5 has been amended to require that any cylinder in storage shall not be exposed to an open flame or other sources of ignition, and shall be protected from tampering or damage by fencing or equivalent means.

Cylinders Stored at Construction Sites

Clause 6.5.3.1.2 has been amended to clarify the storage requirements, the clause indicates that a stored cylinder shall be located in an area that complies with the requirements of 6.5.3.2., and the storage area shall be outdoors.

  • When the conditions of this clause are met, a storage area utilizing a structure with overhead protection, walls, or both, meets the intent of outdoor storage.
    • The structure is designed to be enclosed by no more than two solid walls on the level the cylinder(s) are stored;
    • The cylinders are located within 25 ft. (7.6 m) of an open area of the perimeter opening;
    • When a wall of the structure is a part a building, that building must be under construction, repair, improvement, and there must be no inhabited dwelling units or inhabited sections of that building;
    • There are no openings through which gas may travel to a lower elevation, such as an open stairway on the floor on which the cylinders are located; and
    • There are no wall openings through which gasses could travel into another structure or building.
  • Cylinders may be stored in a cabinet that meets clause 6.5.2.4, in the storage area.
  • A storage area may be on a roof of a structure or building provided the conditions of clause 6.5.3.9 are met.
Cylinder Storage at Construction Sites

Portable fencing used to house stored propane cylinders at a construction site.

These amendments clarify acceptable “outdoor” storage by identifying proper and safe storage options that reflect conditions on construction sites, and is based on the hazards (gas accumulation, vehicular traffic, hoisting, etc.), rather than focusing on the location alone.

Presently, rules from various parts of the Standard that were not intended to address construction activities are being referenced to regulate construction activities.  Even with changes to the 2010 version, it is a struggle to understand which sections of the B149.2 are likely to be applied on construction sites by an inspector.

The result is confusion for workers and trainers on what constitutes compliance, inconsistency in enforcement, and disagreement on the job site over safety.

Clause 6.5.3.2 has also been amended to clarify storage of propane cylinders at construction sites and requires that cylinders in storage shall;

  • be stored in an area that:
    • provides protection from tampering;
    • is free from vehicular or mobile equipment travel, or protected by barriers or the equivalent;
    • has “NO SMOKING” signs which are prominently displayed. These signs shall be in accordance with Clause 7.12.3; and
    • meets the requirements of table 6.3.
  • be placed such that the relief valve on any cylinder is not less than 3 ft. (1m) horizontally from any building opening that is below the level of the relief valve discharge;
  • be placed such that the relief valve discharge is not less than 10 ft. (3 m) on the horizontal plane from the air intake of any appliance or air-moving equipment;
  • be stored in an area that meets clause 6.5.1 and 6.5.3.9.

The rationale behind these amendments is that construction sites occur under a variety of wide-ranging circumstances.  Storage requirements that are intended for industrial settings are too limiting and expose cylinders to hazards associated with construction activities. Cylinder storage on construction sites requires reasonable objectives which also address the worksite hazards.

Movement of Propane Cylinders

Clause 6.5.3.8 has been amended to address the movement of propane cylinders around the construction site and indicates that moving a propane cylinder from one level to another level or the roof of a building may be done using:

  • a freight, service elevator, or construction hoist; or,
  • if by public passenger elevator or escalator, only the person(s) involved with the cylinder shall be in the elevator or on the escalator.

Cylinder Moving Cart 01When moving a propane cylinder to or from the roof or one level to another of a building, each cylinder valve outlet shall be closed, plugged and the valve protective cap or collar in place.

Storage of Propane Cylinders on Roofs

New clause 6.5.1.14 permits propane cylinders to be stored on roofs.  Cylinders to be stored on roofs must meet certain conditions.  The clause directs the reader to a specific clause 6.5.3.9 that details the conditions under which a cylinder may be stored on the roof of a structure under construction.  The Clause indicates that a cylinder which contains propane liquid or vapour shall not be stored on the roof of a building unless it is stored in accordance with clause 6.5.3.9, or connected for use in accordance with clause 6.8.

New clause 6.5.3.9 – Cylinders on Building Rooftops states that cylinders on building rooftops shall comply with the following:

  • A propane cylinder shall not be on the roof of a building unless the cylinder is to be connected for work undertaken on the roof during the current or the immediately following work shift.
  • Cylinders not in use shall be stored in accordance with provisions of clause 6.5.3.2 and the following shall additionally be met:
    • the cylinder(s) weight shall not exceed the net load capacity of the roofing structure as specified by the building owner or management;
    • the storage area shall be at least 10 ft. (3m) from the building edge or a change in elevation of more than 3 feet (1m);
    • cylinders shall be secured to maintain the cylinder in its proper storage position during inclement weather; and
    • all cylinders shall be removed upon completion of the work.
  • Cylinders properly connected in an approved manner to the appliance it serves shall be adequately secured from inclement weather.
  • No more than 1,000 lb. (450 kg) of propane in total capacity shall be stored on the roof.

These amendments provide the following benefits.

  • Retains the original intent of the 2000 change regarding cylinder storage on rooftops for permanent appliance installations – limiting rooftop cylinder storage on permanent installations.
  • Provides clear guidance around cylinder use and storage on rooftops for roofers.
  • Provides for storage of cylinders on the roof to reduce the number of times cylinders are hoisted, lowered, and manhandled, and the hazards associated with moving cylinders, and to address storage security.
  • Limits roof top storage to a practical number of cylinders.
  • Adds additional protection for firefighters with a new requirement to post signs at occupied buildings.

 

View PDF