Standard Operating Procedures

This article, related to the importance of organizations to have and maintain effective Standard Operating Procedures, first appeared in the 2016 May/Jun edition of Propane Canada Magazine.

Bill and I were quite surprised, when we received an inquiry at Fuels Learning Centre, from an established propane distributor, going through a government audit, inquiring if we had a “Standard Operating Procedure” (SOP) written for addressing what one must do with an overfilled propane cylinder.

The task of filling propane cylinders is a large part of the propane distribution network to the final user, the consumer, and one would have thought that this safety issue would have been addressed by having a written SOP in place.  While the company did not have a written SOP in place, to satisfy the auditor, I am sure that the propane cylinder fillers had been instructed and new how to deal with an overfilled propane cylinder.

While it would appear that the task of dealing with overfilled propane cylinders was being done, there was no written procedure to ensure that all of the regulatory and safety items are addressed, no established written procedure to which an employee can refer to, just word of mouth instructions.  As you know, based on the person’s own experience and work habits, verbal instructions are readily changed from person to person which can easily lead to poor dangerous work habits being perpetually put in place.

What is an SOP?

Standard Operating Procedure - LowRes - shutterstock_310757321A Standard Operating Procedure (SOP) is a compulsory instruction, a set of step-by-step specific procedure created to help workers carry out routine operations.  If deviations from this instruction are allowed, the conditions for these should be documented including who can give permission for this and what exactly the complete procedure will be.  The original should be maintained in a secure location while working copies should be authenticated with stamps and/or signatures of authorized persons.

Why do We Need an SOP?

Their purpose is to achieve efficiency, quality output and uniformity of performance while reducing miscommunication and failure to comply with industry regulations, provincial laws or even just your own standards for running your business.  Any document that is a “how to” falls into the category of procedures.

Best Practice - LowRes - shutterstock_310757321Ontario requires a Risk & Safety Management Plan (RSMP) for propane distribution centres and Environment Canada also requires an Emergency Response Plan for certain sized propane tank installations.  Other than these two requirements the Regulations, Standards and Codes do not specifically have a requirement for an SOP.  In these cases, the development of SOPs is a voluntary guideline that the company can identify as a best practice.  Organizations looking to become the best in their industry, demand SOPs as part of defining their standard of work.

SOPs Protect Workers

Workers who are following established SOPs have more confidence that their actions are supported by management, the underlying statutes or regulations, and that they are following industry best practices.  Using Standard Operating Procedures regularly leads to fewer corrective actions.  If there are legal ramifications to your work, then following your procedures reduces liabilities.

SOPs Protect Customers

Customers are entitled to dependable product or safe service delivery based on established and accepted measures, not on any one worker’s personal values, and not varying from one geographic area to another.

Good & Bad SOPs

The important task of writing policies and procedures rarely gets the respect it deserves. Most people recognize the need for having standard policies, but standard operating procedures often get viewed as a necessary evil.

Just because you have a written SOP does not mean that all is well.  Written SOPs can fall into two categories, “good” and “bad”.  It’s the bad procedures out there that are the problem – they give all procedures a bad name!

A poorly written SOP can create as much trouble as not having one at all and can, in fact, provide misleading information leading to an incident.  It is, therefore, not only good enough to have a written SOP but one that is correct, addresses all of the safety and regulatory issues and falls into the “good” category as listed below.

Good procedures and work instructions provide a way to communicate and apply consistent standards and practices within your organization.

GOOD Standard Operating Procedures:

  • save time and mistakes;
  • reduce training costs;
  • ensure consistent results;
  • empower the workforce;
  • get read and used; and
  • support quality goals.

But, BAD procedures can be as disastrous as no procedures at all!


BAD Standard Operating Procedures:

  • cause errors and frustration;
  • increase training costs;
  • waste time and money;
  • detract from quality goals; and
  • don’t get read or used.

Writing an SOP

When writing an SOP, make sure to answer the following key questions:

  1. Who does what? (role or person responsible)
  2. Which tasks are to be completed? (what to do, how often and to which standard or criteria)?
  3. What is the outcome when they do it? (deliverables, measures, objective results, desired behaviours)
  4. Did you answer what needs to hap-pen, clearly?

Work Instructions

Work Instructions define the “how to” information to complete steps in a task mentioned inside an SOP.  Work Instructions are action-focused.  They may include a “list” of steps, a checklist, or pictures of dials, switches, or computer screen shots with annotations.  Make sure to label the information in a way that tells the user what to expect.  Pictures may speak a 1,000 words, but it’s the annotations that clarify the meaning.

Work Instructions focus on “how” typically, the person is to perform the task.  While Work Instructions usually assume the individual has the capability in the general area being addressed, SOPs and work instructions are NOT meant to be a substitute for training! Instead, they should be a companion to training and should reflect what is covered in the training.

Updating SOPs

Standard Operating Procedures are living documents that must be reviewed and updated on a regular basis.  Regular re-views should address:

  • changes to underlying standards, codes, regulations and interim orders from authorities having jurisdiction;
  • changes to equipment used to complete tasks;
  • changes to internal corporate policies and guidelines; and
  • changes to how supporting training courses deal with specific procedures.

Sample SOP

We have created an example of a typical SOP for handling overfilled propane cylinders by transferring the product into another propane cylinder.  Each company is responsible for writing the SOP to meet their specific requirements.  How overfilled propane cylinders are handled will depend on the dispensing location and the specific equipment available.


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TDG Training Requirements

This article, related to TDG Training Requirements, first appeared in the 2016 Mar/Apr edition of Propane Canada Magazine.

1075 PlacardThis article addresses some of the questions posed to us at Fuels Learning Centre with respect to the Transportation of Dangerous Goods (TDG) training requirements.  While the TDG training requirements have been in place for many years it does not hurt to occasionally review and discuss the TDG training needs of the propane industry.

TDG Training Basics

Part 6 of the Transportation of Dangerous Goods Regulations provides the regulatory requirements for training for persons who, handles, offers for transport or transports propane must be trained in those functions.  Transport Canada (TC) has published guidelines that are intend-ed to help employers determine which employees should be trained and what should be included in the training.

How to train employees is not mentioned in the regulations.  Training may be done through a combination of formal “in-class” training, on-the-job training, and extensive work experience. It is up to the employer to decide.

Training Certificate

The employer must provide an employee with a Training Certificate as proof of training indicating the specific training an individual has received.  Self-employed individuals must also determine if they are adequately trained and issue them-selves a training certificate.

I would encourage employers and those who are self-employed to visit the TC website to ensure that you are complying with all of the training requirements.

No Requirement for Training if Under Direct Supervision

The TDG Regulations do not require a person to be trained to handle, offer for transport, and transport propane as long as they are doing so under the direct supervision of a trained person.

The key to understanding this requirement is the words “direct supervision”.  Neither the TDG Act nor Regulations define “direct supervision”.  In cases as this where the regulatory requirements do not define a term we look for other published definitions.

For example, Ontario Regulation 215/01 Fuel Industry Certificates defines “Direct Supervision” to mean “the supervision provided by a supervising certificate holder who is on site in close proximity to a trainee and is available to assist and supervise the trainee”.

Another definition is provided by a Legal Definitions website, which states; “Direct Supervision generally means to be physically present, or within an immediate distance, such as on the same floor, and available to respond to the needs of something or someone”.

As you can see the industry best practice, in this case, is to ensure that the person providing the direct supervision is present or in close proximity to the person under supervision.

One thing to remember is that if you are providing “Direct Supervision” to a person, you are responsible and accountable for that person’s actions.  If there is an incident and it is shown that the person under your direct supervision was not properly supervised, you were away from the transfer facility or not in the cab of the truck, you can and will be the one held responsible.  It is therefore in the supervisors and the employee’s best interest that the employee is properly trained and is the holder of a Training Certificate.

Training Organizations

While the TDG Directorate maintains a listing of organizations which provide dangerous goods training, the Directorate does not examine or certify any of the courses offered and the listing of organizations does not imply endorsement or approval of the training offered by Transport Canada.

Focused Training

Some employees may only need training in the aspects of the regulations that are directly related to their work.  If a tank truck, cargo liner or cylinder delivery vehicle is loaded by a plant person, then that plant person may only need specific training in relation to the offering for transport and handling of propane.  Conversely, a driver who drives the truck will require training in transporting and for unloading, handling.  In this situation, it is the employers’ responsibility to deter-mine what constitutes adequate training for their employees.

To make it simpler for employers to determine what TDG training an employee requires, Fuels Learning Centre embeds the necessary TDG training requirement in our cylinder/automobile filling, tank truck, cargo liner and cylinder delivery training modules so there is no need for persons performing those functions to take an additional TDG training program and no guess work on the part of the employer on whether the employee received the correct training.

An employer can feel comfortable that the employee has received the correct TDG training and issue a TDG Training Certificate to each student who successfully passes the training module.  Also by embedding the necessary TDG training within the training modules saves time and money.

Handlers, Offerers, and Transporters of Propane

Regulations stipulate that no person shall import, offer for transport, handle or transport propane unless the person complies with all safety and security requirements, the propane is accompanied by the required documentation, and that the means of containment and transport vehicle used comply with all safety standards and display all safety marks required by regulation.

The responsibility for compliance falls on multiple parties, although there are three primary categories of people who work with propane depending on their specific job functions.

Handlers of Propane
Handling refers to loading and unloading propane into a means of containment for the purpose of transporting it or storing the propane in the course of transportation.  Therefore, handlers of propane are individuals who transfer propane from one container to another, handle pro-pane containers and operate bulk delivery vehicles.  This would include, but is not limited to:

  • workers who fill propane cylinders and auto propane tanks at refilling centres;
  • bulk truck drivers who fill their bulk trucks from the refinery or storage and deliver propane to end-use customers; and
  • refinery workers who load propane into rail cars for shipment.


Offerer of Propane for Transport
The person who offers for transport is the person who, for propane not in transport, selects or allows the selection of a carrier to transport the propane, to prepare or allow the preparation of the propane so that a carrier can take possession of the propane for transport or to allow a carrier to take possession of the propane in transport.  The offerer of propane is also referred to as the consignor.
The offerer of propane is generally a corporate entity.  Outside of handling and transporting propane shipments, the offerer carries primary responsibilities for the classification of propane, appro-priate documentation and emergency and security planning.  Some of the individuals who are responsible for these primary responsibilities include:

  • Individuals who classify propane and provide proof of classification;
  • Individuals who obtain or prepare Safety Data Sheets for distribution to carriers and receivers of propane shipments;
  • Individuals who select a carrier of propane shipments; and
  • Individuals who bill customers for the shipment of propane.

Transporters (Carriers)
This refers to individuals who are in possession of propane while it is in transport.  This would include, but is not limited to:

  • Road transport companies;
  • Rail transport companies
  • Propane retailers;
  • Bulk truck drivers; and
  • Operators of other vehicles carrying propane such as cylinder trucks and crane trucks.

Cargo Liner

Some individuals may fall into more than one of the above three categories and the level of training they require to meet the regulatory requirements depends on the scope of their individual jobs.

Specific TDG Training Requirements

Base Content for All TDG Training
The following items must be included in TDG training and serve as the “base” for TDG training:

  1. Definition of the nine classes of dangerous goods and their associated hazards;
  2. Shipping names, classes, UN numbers and packing groups for the dangerous goods that are normally encountered on the job;
  3. Safety marks such as labels and placards that are used to identify the different classes of dangerous goods that are normally encountered on the job;
  4. Knowledge of the information that must be on a shipping document;
  5. The requirements regarding mixed loads and the need for segregation of incompatible dangerous goods;
  6. The proper selection and use of means of containment for the dangerous goods;
  7. What to do if the shipping documents, placards, labels, other safety marks or means of containment seem inadequate or incorrect;
  8. What constitutes an accidental re-lease and the reporting requirements if an accident happens;
  9. Proper use of all equipment that is used in the handling, offering for transport and/or transportation of dangerous goods; and
  10. Emergency Response Assistance Plans (ERAP) requirements if a plan is required.

Training for Handlers of Propane
In addition to the standard items required in all TDG training, handlers of propane must also receive training in the following areas:

  1. Types of placards, labels, signs, num-bers and other safety marks, what they mean, and when and where to display them;
  2. A thorough knowledge of the control and emergency features for all handling equipment used in the day-to-day activities of the job;
  3. Safe practices on the loading and stowage of propane;
  4. When to remove placards, UN numbers, and other safety marks;
  5. The proper selection and use of means of containment for propane.

TDG Cylinder Label

Training for Offerers of Propane
In addition to the standard items required in all TDG training, offerers (con-signors) of propane must also receive training in the following areas:

  1. All of the requirements required for documentation except for the location and the rail consist;
  2. How to communicate the special instructions and precautions for the handling and/or transporting of propane while on the job;
  3. Types of placards, labels, signs, numbers and other safety marks, what they mean, and when and where to display them;
  4. The proper selection and use of means of containment for propane;
  5. The Emergency Response Assistance Plan requirements (ERAP) if a plan is required.

Office Worker on Computer

Training for Transporters of Propane
In addition to the standard items required in all TDG training, transporters of propane must also receive training in the following items:

  1. Types of placards, labels, signs, numbers and other safety marks, what they mean, and when and where to display them;
  2. The location of the shipping documents and the importance of keeping them accurate;
  3. Requirements for parking, loading and vehicle inspection which may apply.

Vehicle Parking

Training Required to Fill Cylinders Larger than 46 Litres in Capacity

We have been asked many times about the requirement for TDG training for individuals who fill cylinders at retail filling centres. The 150 kg and 500 kg exemptions in the regulations remove the training requirement, however, the exemption is limited to cylinders up to 46 L in capacity.  The Small Means of Containment exemption does allow for larger cylinders, however, the exemptions only apply to the transport of the propane and not the handling.  Therefore, if your employees are going to be filling cylinders larger than 40 pounds in capacity, they must have TDG training specific to the handling of propane.

Embedding of Specific Training into Training Courses

At Fuels Learning Centre we not only embed the required TDG training but also, dependent on the training module, we embed other specific training requirements a person needs to complete the tasks required for their job.

Trained Individuals Danger Sign


For example, a version of our tank truck driver training course includes inspection of propane tanks and pressure relief valves, truck-to-truck transfer requirements specific to each province and directions for how to safely light appliances for fuel outages.

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Inspection of Propane Systems on Recreational Vehicles

This article, related to the inspection of propane systems on recreational vehicles first appeared in the 2016 Jan/Feb edition of Propane Canada Magazine.

In recent articles, I have mentioned that the province of Ontario is in the process of developing Code Adoption Documents (CAD) that would amend and adopt the 2015 B149 series of codes.  One of the new requirements is the inspection of propane systems installed on Recreational Vehicles (RVs) equipped with a permanently mounted propane tank.

Inspection of Recreational Vehicles in Ontario

Propane Tank on RVProposed revisions in the Ontario 2016 Propane Code Adoption Document will require RVs equipped with permanently mounted propane tanks to have the pro-pane appliances, propane piping system and tank inspected on a five-year cycle.  An RV that successfully passes the inspection process will be affixed with two labels to identify that the unit is acceptable to the Authority Having Jurisdiction (AHJ) for the onboard propane tank to be filled.

The RVs in question are actually motorhomes, as these are the only RVs that have permanently mounted propane tanks.  Other RVs are towed vehicles that use propane cylinders to supply fuel to the propane appliances installed in the units.  The only difference with respect to the propane systems on board between the motorhomes and towed RVs is the actual propane container; the piping systems and appliances are installed in accordance with the CSA standard regardless of whether the unit is self-propelled or towed.

Inspection Process

Ontario - TSSA Logo 01To obtain the two labels a motorhome owner will have to take the unit to an RV dealer, propane supply or heating contractor who has the staff with the appropriate propane certificates to inspect the appliances and piping system and issue a certificate indicating the appliances and piping system are acceptable.  Then, the owner must take the unit to a Technical Standards & Safety Authority (TSSA) Registered Conversion Inspection Facility to have the tank inspected by a person with an ICE certificate.  The Registered Conversion Centres will be the only ones able to obtain and affix the two labels required directly from TSSA.

To provide some perspective on the magnitude of the inspection requirement, there are currently over 25,000 licensed motorhomes in the province of Ontario.  If the requirements in the CAD are adopted, each motorhome will require 2 inspections, by different service providers, so that the owners can have affixed the labels that will permit the propane filling attendant to fill the propane tank.  This works out to a total of 50,000 inspections.

There is also a question with respect to new motorhomes sitting unsold on dealer lots. Unless the dealer puts the motorhome through the inspection process, these brand-new units at the time of sale will not have the two propane labels required in order for the propane tank to be filled.  This means that the first thing the new owner must do is arrange for his/her brand-new unused unit to go through the 2-part inspection process in order to obtain the necessary labels.

Rationale and Risk

I suspect that one of the drivers for the inspection of the propane tanks on RVs may be the requirements for the inspection of tanks and fuel systems on converted vehicles where propane is used as an engine fuel.  Vehicles converted to run on propane are usually fleet type vehicles such as taxis, limousines, and delivery which are on the road every day 365 days a year regardless of the weather conditions.  Conversely RVs are usually limited to summer use and in the winter are relocated to the southern climates where snow or ice and salt does not have the same impact on exposed propane tanks.

If there is a need, risk or safety driven, to inspect the propane piping and appliances on a motorhome, one must ask, why would these requirements not apply to a towed RV as these vehicles operate in the same outdoor environment?  While I can appreciate that the owner of a towed RV can remove the propane cylinders and the filling attendant may or may not see the RV, reducing control for compliance, the inspection requirements of the propane piping system and appliances on motorhomes creates an uneven playing field between an RV that is self-propelled and one that is towed.

If the risk is the corrosion and failure of the permanently mounted exposed propane tank, then it would make sense to look to the inspection of the tank only, say on a 10-year cycle, which would, in essence, parallel the propane container inspection required for propane cylinders installed on towed RVs.

The current inspection model being promoted in Ontario is risk-based where the assessed risk drives the frequency of inspection.  While there certainly have been incidents in the past with the propane systems and appliances installed on RVs, we have no sense of the frequency nor have we seen any data to indicate the risk to the general public warrants the inspection the propane systems and appliances on a regular basis.

Barriers to Compliance

I did a considerable amount of research, on the TSSA website, Yellow Pages, 411 and speaking with people in the industry in an attempt to identify the number of TSSA Registered Conversion Centres that could perform the propane tank inspection and affix the two labels.  My best guesstimate is less than 25 such facilities that are primarily located around the Golden horseshoe.  Two facilities were located in Sault Ste. Marie.  My research failed to identify whether all of these facilities could accommodate the inspection of propane tanks on large motorhomes.

For example, I was told that Canada Post has a registered conversion centre which is used strictly for their own vehicles and would therefore not be available to inspect propane tanks on motorhomes.  My question is, if I had trouble finding the location and number of registered conversion centres, how would one expect a motorhome owner to find this information.

Given the limited number of inspection facilities, their geographic locations, and the sheer number of motorhomes to be inspected the proposed requirements will create a substantial barrier to compliance.  This will disadvantage the motorhome industry in Ontario and could very well deter the consumer from purchasing a motorhome to be licensed in the province.

In addition, propane filling attendants in Ontario will require training to identify and recognize the new label requirements.

Out of Province RVs

Filling RV Propane TankThe requirements will also need to address out-of-province or out-of-country motorhomes that can either be vacationing in Ontario or travelling through.  How will these owners get propane if they do not have the necessary labels attached to the vehicle?  The propane fill attendants are instructed not to fill any propane tanks on vehicles unless the vehicle has the appropriate labels displayed to show that it meets the requirements for the province of Ontario.

Action Being Taken

I have been retained to assist the Ontario RV Dealers Association in an effort to address the issues identified. A letter outlining the issues has been sent to the chair of TSSA’s Propane Risk Reduction Group.  At the time of writing this article, we are awaiting a response.


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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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Ontario Code Adoption Documents

This article, related to Ontario code adoption documents, first appeared in the 2015 Sep/Aug edition of Propane Canada Magazine.

I normally try to write articles on the regulatory and technical issues which apply equally across all provinces and territories.  However, with the new 2015 B149 series of codes being published by CSA this past August, many of the Authorities Having Jurisdiction are now in the process of developing code adoption documents to adopt the 2015 versions.  I will report on the activities of each Authority Having Jurisdiction as they progress towards the adoption of the 2015 codes.

Ontario - TSSA Logo 01As previously reported, Ontario issued an Ontario Code Adoption Document (CAD) in August 2014 which continued the adoption of the 2010 editions of CSA-B149.1 and CSA-B149.2.  The purpose of this 2014 CAD was to not only continue the adoption of the 2010 Codes in Ontario but to adopt as early as possible many of the 2015 Code requirements that Ontario felt were important to put in place as soon as possible. The 2014 CAD became effective October 1, 2014.

The next round of Ontario amendments to the CSA-B149.2 Code will be released January 1, 2016.  The 2016 CAD drops the 2015 Code requirements listed in the 2014 CAD.

The 2016 CAD not only adopts the B149.2 but revokes the requirements listed in the 2014 CAD and provides new requirements for the following:

  • Adoption of Field Approval Code and Mobile Food Unit Approval Code for appliances on those units that are not approved;
  • New requirements for labelling of tanks mounted on OEM and converted vehicles for motive power and for RV for supplying appliances;
  • Exemption of vehicular protection for cylinders of 20 lb. or less stored in cabinets;
  • New requirements for inspection of tanks and inspection/replacement of relief valves; and
  • Annex Q is added for requirements for use of non-refillable cylinders in classrooms in schools.

Primary Amendments

The following are the primary Code amendments/edits that will appear in the 2016 CAD.

Cylinder Exchange
Cylinder Exchange CageNew definition to clarify what a cylinder exchange is, for the purpose of licensing and the respective requirements.  Cylinder Exchange means a type of a propane cylinder handling facility where propane in refillable cylinders are sold or other-wise distributed to an end user, with cylinders stored in no more than four (4) cabinets and each cabinet contains no more than 500 lb. of propane.

Cutting or Welding Applications
When TC-4BWM18 cylinders, with a propane capacity of 40 lb. (18 kg) or less, used in cutting or welding applications are requalified, they are exempt from having a cylinder valve that does not permit the flow of propane until a positive seal has been achieved.  When requalifying TC-4BWM18 cylinders, valve replacement may be made by using a valve outlet conforming to the CGA 510 standard, not requiring a positive seal and with a PRV set at 405 psi.

Refueling Equipment Indoors
This CAD requirement is to require all equipment fueled with propane, including ice resurfacing machines, to be subjected to the same requirements.  Therefore, clause 5.11.3 in the Code is revoked.

The new clause states that when equipment, such as an industrial tractor, lift truck or ice resurfacing machine, is fueled by propane and is used indoors, the area shall be ventilated in accordance with the requirement of Table 5.1 as found in the code.

Approval Labels for Recreational Vehicles (RVs)
RVs which have permanently mounted propane tanks for fueling the appliances will have to have two labels of approved design, affixed by a licensed conversion centre certificate holder.  The labels are to be affixed on the rear window or side window nearest the fill connection, at the door latch, or in the glove compartment.

The CAD requires that the appliances be inspected every 5 years in accordance with the B149.1 and the inspection reports are to be provided to the propane conversion centre. The copy of the inspection report must be no older than 90 days when received by the propane con-version centre.

To inspect an RV will require that a valid G1, G2, RV1 certificate holder inspect the appliances and the inspection of the tank and associated liquid piping and components be inspected by a holder of a valid Internal Combustion Alternate Fuel Technician, Propane (ICE-P) certificate.

Also, the inspection of the tank and associated liquid piping and components is to be carried out at a registered vehicle conversion centre.

Moving propane cylinders from one level to another
The use of passenger escalators is removed as this is not an acceptable practice.

Vehicle Impact Protection
Vehicle impact protection will not be required for protection of 20 lb. propane cylinders where the cylinders are kept in lockable ventilated cabinets of metal construction.

It was submitted by the industry group that it is proven cylinders are well protected with cages of metal construction. The same requirements were adopted in IFC and in the process of adoption in NFPA.

Filling cylinders under 100 lbs. from bulk trucks

100 lb CylinderThe filling of cylinders under 100 lbs. from bulk trucks shall comply with Annex P of the CAD.

Annex P requires that:

  • Drawings are submitted and that each location is approved;
  • A letter from the local municipality stating that the refueling of propane cylinders does not contravene any applicable zoning bylaws;
  • Calculations submitted confirming that Branch Standard No. 9 has been met; and
  • Written procedures are available for filling cylinders from a bulk truck.

Tank Inspections
All installed tanks will require a recorded tank inspection every 10 years, in accordance with National Board Inspection Code (NBIC) inspection and acceptance criteria.

Pressure Relief Valve (PRV) Inspections
The CAD provides clauses to adopt the requirements in the new edition of B51 and allows a grace period of seven (7) years for tanks greater than 2,500 USWG and ten (10) years for tanks of 2,500 USWG or less.  Each operating company should have a plan and start acting as soon as these requirements come into effect.

Pressure relief valves (PRV) of tanks are to be visually inspected periodically to ensure that there are no impediments that will prevent them from operating properly.  The frequency of the periodic visual inspection depends on the operating environment and the manufacture’s recommendation.

The PRV inspection is to be recorded at a minimum interval of every five (5) years. The record must include the date of in-spection and the person carrying out the inspection.

The inspection will ensure that:

  • the outlet and, where applicable, weep hole is open and free to discharge;
  • there are no signs of corrosion, cracks, debris, tampering, or other mechanical damage;
  • there is no leakage;
  • the discharge is directed to a safe location, and any piping installed is adequately supported and does not obstruct the discharge;
  • the seal, where applicable, has not been broken; and
  • the rain cap, where applicable, has been installed.

Tanks of greater than 2,500 USWG must have the relief valves rebuilt/certified or replaced every 10 years.  All overdue relief valves are to be rebuilt/certified or replaced by January 1, 2023.

Tanks of 2,500 USWG or less must have the relief valves rebuilt/certified or replaced every 25 years.  All overdue relief valves are to be rebuilt/certified or re-placed by January 1, 2026.

Tank owners must develop a plan that provides an achievable pathway for full compliance with the PRV replacement requirements for tanks regardless of size within the implementation periods stated above (January 1, 2023 & January 1, 2026). The plan must be developed by July 1, 2016.

Within a ten (10) year period from the implementation of these requirements (seven [7] years for tanks of greater than 2500 USWG), each owner should keep records of the PRV for each in-service tank, including:

  • the name of the PRV manufacturer;
  • the date on which the PRV was put into service;
  • an approval stamp – the PRV must have the UL code symbol on it in accordance with the applicable design code (ANSI/UL 132);
  • a record that the set pressure of the PRV meets the specified requirements for the tank;
  • a record that the relief capacity in SCFM air conforms to the appropriate rate for the size of the tank; and
  • records of this information shall be held by the distributor and may be kept in hard copy or electronic format.

*Not all valves will have a nameplate. If there is no nameplate the markings are stamped into the body of the valve.  All valves should be marked with the manufacturer’s name or an abbreviation, the manufacturer’s part number, set pressure, capacity, date or date code for the year of manufacture, and the UL rating code symbol.

Use of Non-Refillable Propane Cylinders in Laboratories/Classrooms in Schools, Colleges, and Universities

Non-Refillable CylindersThe CAD provides an Annex Q to address the use of non-refillable cylinders in classrooms.

In Closing

In this article I have attempted to raise awareness on the issues I believe will most impact the Ontario propane industry.  There are a few requirements within the 2016 CAD that are carryovers from the previous 2014 CAD and some requirements with slight amendments to them.

It is, therefore, important that each person who works under the B149 series of codes obtain a copy of the final, approved 2016 CADs for propane storage & handling, natural gas installation, and vehicle conversion codes to become familiar with their requirements.  The CADs, when issued, will be available on the TSSA website.


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Adoption of 2015 Versions of B149 Codes


This article, related to the adoption of 2015 versions of B149 codes, first appeared in the 2015 Jul/Aug edition of Propane Canada Magazine.

I recently chaired the CSA B149.1 Natural Gas & Propane Installation Code Technical Committee meeting and attended as a member of the CSA B149.2 Propane & Storage & Handling Code Technical Committee meeting Niagara Falls, Ontario.

As you are all aware CSA will be publishing the latest editions of the B149 series of Codes in August 2015.  I thought this would be an opportune time to provide information on the provincial and territorial adoption dates of the Codes and to reiterate a couple of sections of the new Code that I believe need to be highlighted, namely maintenance and operating procedures and PRV replacement in cylinders.

Also, this edition of Propane Canada magazine is focusing on temporary heat; so I thought it would be appropriate if I highlighted some of the key regulatory changes coming in the next Code edition with respect to construction heating.

Adoption of 2015 CSA Codes

One of the agenda items was the adoption of the 2015 B149 series of codes.  The following chart provides the latest proposed adoption dates for each of the provinces and territories.  While this is the latest information available it is best to follow up on a regular basis with your provincial or territorial Authority Having Jurisdiction to see if the dates listed will actually be implemented.

B149 Adoption Table

Why You Need to Obtain the 2015 Codes

B149.2 Edition
The following are some of the highlights of the 2015 edition of the B149.2 Propane Storage & Handling Code:

  • Transfer of clauses to other standards in the B149 Series to make the Code more comprehensive and streamlined;
  • New definitions for construction sites, cylinders in storage and connected for use;
  • New clauses for construction sites, tank heaters, vaporizer installations and propane storage facility operation and maintenance.

B149.1 Edition

The following are some of the highlights of the 2015 edition of the B149.1 Natural Gas & Propane Installation Code:

  • Updated scope provides guidance on metallic fittings, stainless steel tub-ing, pressure regulators for propane vehicle usage, direct gas-fired pro-cess air heaters and more;
  • Consolidated clauses from other Codes in the B149 Series make the Code more comprehensive and streamlined;
  • New clauses for mobile homes, rec-reational vehicles, highway vehicles, outdoor food service units, and wash-mobiles include specialized re-quirements;
  • Simplified references and definitions allow for improved application of the standard’s clauses.

Pre-Order Codes
CSA is currently offering, on their web-site, several different 2015 B149 Code packages that you can pre-order.  CSA will also be publishing a handbook for the B149.1 Code.  The latest technological advancement is a complete inter-active version of the B149.1-15 and the B149.1-15 Handbook for your iOS or Android tablet or mobile device.

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 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.  Industry association publications and training programs provide guidance to individuals preparing site specific procedures and may be referenced.  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.

Replacement of PRVs for Propane Cylinders with Dome Covers

This requirement addresses the conflict between the B149.2 Code and the CSA-B339 Standard currently adopted by Transport Canada.  The new clause means that the owner of a propane cylinder equipped with a pressure relief valve, previously exempted from replacement by their installation under the dome cover, will now have no conflicting requirement to be used as an argument for not replacing the pressure relief valve at the time of the 10-year cylinder inspection and requalification.

In fact, the new clause is very specific by stating that the PRV is to be removed and replaced with either a new relief valve or one that has been tested to and complies with CGA S 1.1, and found acceptable for use.  The clause also requires that a replacement valve has the PRV and dip tube length sized for the cylinder.

There are also new record-keeping requirements listed in the Code which require the facility conducting the visual inspection and requalification to maintain records showing the results of the inspection and requalification until the date of expiration of the requalification period; or the date the cylinder is reinspected.

Personally, it is my opinion that anyone not already replacing the PRV, at the time of requalification of cylinders, such as 420 lb. propane cylinders have been putting non-compliant propane cylinders back into service.  The requirement to replace the PRV at the time of the visual inspection and requalification for PRVs protected by a dome cover has been in the CSA-B339 for several years.

Temporary Construction Heat

The chart indicates that provinces will be adopting the 2015 Codes in the middle of this heating season. This means that you must be aware of the new and amended requirements for temporary construction heat. The main focus of the new requirements is the storage, handling and use of propane cylinders at construction sites.

In order to understand how the new requirements will impact their day-to-day activities, cylinder delivery and bulk truck drivers who service the sites must have the knowledge of how to comply with the new requirements.

New 2015 B149.2 Definitions

Connected for Use – this new definition is to clear up the confusion as to whether the propane cylinder is in use or storage when connected to a construction heater and the construction heater is not operating. The definition stipulates that a propane cylinder connected to an approved appliance (construction heat-er) regardless of whether the heater is operating or not is to be considered in use, not storage as some have interpret-ed in the past.

Construction Site – the clause expands on what exactly is a construction site and provides the guidance as to when the site can be considered a construction site for the storage, installation, and use of propane cylinders.

New or Amended Clauses

Cylinder Not Connected for Use – requires cylinders not connected for use to be housed in acceptable storage sites and further clarifies that a propane cylinder connected for use is not considered in storage.

Storage of Cylinders – Provides storage requirements and, under certain conditions, permits cylinders to be stored on the roof of buildings under construction and clarifies acceptable “outdoor” storage by identifying proper and safe storage options that reflect conditions on construction sites.  The requirements are based on the hazards (gas accumulation, vehicular traffic, hoisting, etc.), rather than focusing on the location alone.

Presently, rules from various parts of the Code 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, in-consistency in enforcement, and disagreement on the job site over safety.

Moving Cylinders – When moving propane cylinders on construction sites by elevator, hoist, or escalator, it was only assumed that other clauses within the Code not specifically related to a construction site would not be referenced and applied on construction sites. The new specific clause with some modification for construction, makes the acceptable means clear to both users and regulators.

In Conclusion

It’s imperative that supervisors, propane technicians and those who deliver cylinders and bulk propane are familiar with the latest Code requirements.  To be proactive, a person should order and obtain the latest editions of the Codes from CSA as soon as the Codes are published in August 2015.  This will give an opportunity to train on the latest requirements and to understand the impact these new requirements will have on your company prior to their adoption by the Authority Having Jurisdiction in your province or territory.

The Fuels Learning Centre offers training programs addressing the 2015 Code requirements for cylinder requalification (Visual Inspection & Requalification of Propane Cylinders – SO01) and the use of temporary construction heat (Construction Heaters and Propane Cylinders at Construction Sites – AV02).


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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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Inspection of PRVs in Propane Service


This article, regarding the inspection of PRVs in propane service first appeared in the March/April 2015 edition of Propane Canada magazine.

PRV 01The publishing of the mandatory Annex H of the CSA B51-14 Boilers, Pressure Vessel and Pressure Piping Code, that requires the replacement of Pressure Relief Valves (PRVs) in propane tank service has brought the issue of PRV inspection to the attention of provincial Authorities Having Jurisdiction (AHJ).

Mandated Inspection Cycles

The staff at the Fuels Learning Centre were recently contacted by a provincial AHJ to see if we could assist them in researching the history of the use and failures with PRVs in propane tank service and propane tanks. The AHJ is looking at possibly mandating a PRV and propane tank inspection program on a yet-to-be-determined cycle.

We provided a document representing a consolidation of information gained over the years. The document provided points to be considered by the AHJ in making a decision as to the mandating of PRV and tank inspections.

The rationale for putting a mandated documented inspection cycle in place is to ensure that PRVs with a potential for failure are identified and removed from service prior to a failure. We consider a pressure relief valve failure to be when the pressure relief valve fails to activate in an over pressure situation, or opened or partially opened in a non-over-pressure situation. The mechanical components of the valve failed to operate as designed.

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

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

We are aware of only one incident, in the past 25 years in which a used external spring type PRV was reinstalled in a propane tank and subsequently failed as per the criteria for a PRV failure.

There are approximately 750, 000 pro-pane tanks in Canada. All of these pro-pane tanks, regardless of size, are equipped with one or more PRV.  The majority of the propane tanks are located at residences, farms, and commercial establishments.

An industry standard practice is that the PRVs in propane service are visually looked at for any factors that could impair the operation of the PRV each time the container is filled.  This prefill examination is not documented.

Ontario is the only province that currently mandates a documented Inspection of PRVs in propane tank service and the propane tank on a three-year cycle. The person conducting the inspection must hold a valid Record of Training that permits the person to complete the documented visual inspection. The owner of the propane tank must maintain a record of the most current PRV inspection.

If all provinces and territories followed Ontario’s lead and mandated a three-year cycle for PRV and tank inspection it would mean that approximately 750,000/3 = 250,000 PRVs would have to be inspected on an annual basis.  The one saving grace in all of this is that the majority of propane tanks are visited at least once annually for refilling and the tank truck operator can be trained to perform the visual PRV and tank inspection while at the site.

If tank truck operators are excluded from being able to perform the documented visual inspection and tank owners are forced to rely on certified propane technicians to conduct the inspection, an impractical situation for compliance will be created.  There just are not enough certified propane technicians available to meet the demand for 250,000 annual inspections.

The other issues to be considered include document creation and retention as well as training costs.  There will be 250,000 documents to be created and retained per year. While one cannot put a cost on safety, the financial impact of training people to complete the inspection must also be considered for training sufficient staff to meet the demand for inspection.

Inspection Checklist

PRV Inspection ChecklistA properly sequenced checklist inspection document, supported by training, can assist the person completing the inspection to obtain all of the information required in a consistent manner.  It is also an opportunity to develop a database on the age of PRVs in service to assist in establishing a replacement schedule to meet the requirements of the CSA B51-14 Code.


We are currently aware of only one AHJ seriously looking at implementing a mandated inspection cycle; however, from a national perspective, it could be a daunting issue that will require a consolidated common national approach by the propane industry to ensure that the industry can meet the regulatory compliance.

History has shown that specific provincial requirements have a tendency at some point to become a national requirement.  If this occurs with PRV and tank inspections it will indeed create a potentially burdensome situation.

Available Training

To meet your training needs, the Fuels Learning Centre offers a version of its Tank Truck Operators training course which includes PRV and tank inspection embedded within the curriculum.  This means the tank truck operator needs to take only one training program – Loading and Unloading Propane Tank Trucks Including Visual Tank & PRV Inspections (TO04), reducing training time and costs.  We also offer a stand-alone inspection course for other personnel who need to learn these skills – Visual Tank & PRV Inspections (SO02).


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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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