Keeping Regulatory Training Current

Posted on October 31, 2014 by Bill Egbert

Most records of training for compliance training are valid for three years. A lot can happen in terms of regulatory requirements in three years. This article, summarizes information from two articles which first appeared in the Sep/Oct and Nov/Dec 2014 editions of Propane Canada Magazine. This article discusses the importance of ensuring you are keeping regulatory training current so that your employees remain properly trained.

As detailed in previous articles earlier this year the B149.1 – Natural Gas and Propane Installation Code and the B149.2 – Propane Storage and Handling Code have been extensively amended for publication by the Canadian Standards Association in 2015.

Also, the B149.3 – Code for the Field Approval of Fuel Related Components on Appliances and Equipment and the B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles will have new Codes published by the Canadian Standards Association in 2015.

The provincial adoption of the 2015 codes will start to take place sometime after January 2015. Some provinces adopt the codes as soon as they are published, while other provinces adopt several months later. It is, therefore, important that, as users of the Codes, you are aware of when your particular province will adopt the Codes that regulate the work you perform.

Ontario Adoption of Codes

Ontario has issued an Ontario Code Adoption Document (CAD) for both 2010 editions of B149.1 and B149.2 codes which become effective October 1, 2014. The CAD adopts many of the changes that will appear in the 2015 editions of the B149.1 and B149.2 codes. The CADs are available on the TSSA website for download. Significant changes made by the Gaseous Fuels amendment include:

Permitting press-connect fittings;
Re-classifying clothes dryers in accordance with the certification standard;
Adding a new section regulating unvented heaters installed in livestock or poultry facilities;
Incorporating Director’s Order FS-051-04 (re B-Vents not certified for exterior applications installed outdoors) into the code, for ease of reference; and
Adoption of TSSA-MFSE-2014 for field approval of mobile food service equipment.

The Propane Storage & Handling Code Adoption Document adopts the 2010 edition of the Code and new requirements approved by the B149.2 and B149.5 Code Committees for the 2015 Code which are considered important to be implemented in Ontario now and addresses gaps in the current codes to enhance safety.

Major changes in this version include the following:

New definitions added for “construction site” and “cylinder exchange”;
New requirements for cylinder storage, including storage at construction sites and rooftops;
New requirements for cylinder exchanges;
Reiterating the need for compliance with Branch Standard #9 or a full risk and safety management plan for facilities in heavily populated or congested areas; and
New certification requirements for valves, components, and accessories for propane vehicle conversion; replacing IGAC Protocol 01-97.

Code Updates Referred to in TDG Regulations

At the same time there is a new, 2014 edition of the B620 – Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods and B622 – Selection and Use of Highway Tanks, Multiunit Tank Car Tanks, and Portable Tanks for the Transportation of Dangerous Goods, Class 2.

While Transport Canada recently adopted the 2009 editions of the CSA/B620 and CSA/B622, the 2014 editions are completed and ready for adoption. It is important for one to keep abreast of the latest Codes and Standards as you know eventually any new requirements will become law.

Training Requires Updating

Once the Codes and Standards are adopted there will be an immediate training need for persons who perform work that is regulated by these documents. In Ontario, this is October 1, 2014, which means that training programs that are used by the propane industry to train people must reflect the latest regulatory requirements as of October 1, 2014, for Ontario and in other provinces early next year.

This does create some issues as the current Record of Training (ROT) retraining requirements are once every 3 years, which means that people can actually be working in the field for up to 3 years before they are trained on the new regulatory requirements.

Given that 2015 is the year for the issuance of new codes it may be advisable for employers in certain segments of the industry such as gas technicians, propane cylinder, cargo liner and bulk delivery and propane construction heating, to have their employees trained on the new requirements rather than wait until such time that the person’s ROT is up for renewal.

One of the largest impacts is going to be in the construction industry where the requirements for the storage and use of cylinders have been extensively amended. If your cylinder delivery driver is not aware of the new requirements he could inadvertently create a non-compliance situation which could result in fines and disruption of service to your customer.

For example, Ontario Director’s Order FS-095-06, issued November 2013, states that “when distributors provide fuel to tanks or cylinders not connected to the premises, the distributor shall ensure that the fuel storage is compliant with Ontario Regulation 211/01”.

If not aware of the new requirements, the contractor who uses the propane cylinders and construction heaters can also inadvertently create a non-compliant situation which could result in fines and impact the ongoing construction of the building. The contractor could also be at a disadvantage from an efficiency perspective if he does not know the new requirements with respect to the use and storage of propane cylinders on rooftops.

Another example is the increased size of cylinders which may be stored in cylinder exchange cabinets. Due to demand from the RV industry, the maximum was changed from 20 lb. 30 lb. cylinder sizes. The cabinet maximum capacity of 500 lb. (25 x 20 lb., or 16 x 30 lb., or a combination thereof) has been maintained. If you were not aware of these new requirements you could be missing out on an opportunity to serve the recreational market with the larger propane cylinders.

The CSA-B620-14 has new requirements for “off truck emergency shutdown system” to include tanks in non-metered propane delivery as well as engine shutdown when the engine air intake senses flammable vapors. When adopted, drivers of unmetered deliveries need to be trained in the inspection and use of these new requirements

It does not make economical or practical sense to train people with outdated training programs. As indicated by the examples above it is crucial to one’s business that employees are trained in understanding the latest regulatory requirements.

Status of publication of the 2015 series of CSA Codes and Standards

2015 B149.1 – Natural Gas & Propane Installation Code
The committee last met on June 12, 2014. Public Review took place from March 12 to May 12, 2014; and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting of the Technical Committee (TC) will take place in February 2015 if needed for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B149.2 – Propane Storage & Handling Code
The committee last met on June 11, 2014. Public Review took place from March 12 to May 12, 2014, and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting will take place in February 2015 if needed, for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B139 – Installation Code for Oil Burning Equipment
The Technical Committee last met on June 24-26, 2014 to disposition Public Review comments and finalize the technical content in the Draft. The ballot for the approval of the Code took place from Sept. 3 to Oct. 3, 2014. The scope has been changed to include fuel oil storage tanks of all sizes including underground tanks. The Code is now divided into two major parts, B139.1 – Large Installations and B139.2 – Residential and Small Commercial Installations. Publication is scheduled for April 1, 2015, in both English and French.

Gas Appliances and Related Accessories
The CSA Gas Technical Committee held a joint meeting with the U.S. Z21/83 Technical Committee on Sept. 30. 2014. The following new standards were approved:

CSA 3.8, Gas-fired Equipment for Drying Crops;
Z21.10.1/CSA 4.1, Water Heaters Volume 1; Z21.10.3/CSA 4.3, Water Heaters Volume Ill;
Z21.54/CSA 8.4, Gas Hose
Connectors;
Z21.19/CSA 1.4, Refrigerators Using Gas Fuel;
Z21.56/CSA 4.7, Pool Heaters; and
Z21.58/CSA 1.6, Outdoor Cooking Appliances.

Oil Burning Appliance Standards (B140 Series, B211 & B212)
The B 140 series of Standards have been reaffirmed; however, they are in need of review and updating. The last Technical Committee meeting was held on May 2, 2012. CSA will be looking at reconstituting the TC to begin work on these documents.

Carbon Monoxide Detectors Standard
The Technical Committee has been reinstituted for a new edition of the CSA 6.19 standard. The TC’s first meeting was Sept. 25, 2014, with the publication date projected for September 2016.

Introduction of the Fuels Learning Centre

Recent events provided a business opportunity for me to partner with Bill Egbert in the creation of a new training provider for the fuels industry. The company is called Fuels Learning Center Limited (FLC) which will not only provide training modules to the propane industry but also the fuel oil and natural gas industries.

As most of you are aware Bill was for many years, the General Manager of the Propane Training Institute. I was under contract to the Canadian Propane Association to write new training programs and update existing programs with the latest technical and regulatory requirements.

The Fuels Learning Centre currently has nine provincially approved training courses which reference the latest regulatory requirements of the Codes and the Standards to be adopted:

These programs, when successfully completed, will provide the provincially acceptable ROT and where required the TDG qualifications for persons who need to be trained in the handling and use of propane. We have been able to streamline these programs to focus more on what a person needs to know and less of what is not required to know to safely perform their tasks.

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Documenting Compliant Propane Installations

Posted on August 31, 2014 by Bill Egbert

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

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

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

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

Using Approved Appliances

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

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

Approval Labels from Recognized Testing Organizations

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

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

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

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

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

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

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

Use a Checklist as Part of Documentation

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

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

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

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

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

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

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Changes in 2015 Version of B149.2 Propane Storage & Handling Code

Posted on June 30, 2014 by Bill Egbert

This article, related to Changes in 2015 Version of B149.2 Propane Storage & Handling Code, first appeared in the May/June 2014 edition of Propane Canada magazine and was updated in October 2014.

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

This article provides a summary of the clauses that have been amended, added and deleted in the CAN/CSA B149.2 Propane Storage and Handling Code.

The 2015 editions of the Codes are the completion of a 5-year code cycle that CSA uses to keep the Codes updated to address new technologies, new installation materials, and changing building environments. The committees who update the codes also consider changes to improve the usability of the document. Many of the amendments consolidate subjects so that a gas technician has to only look in one place for the requirements of a specific component. For example, the requirements for appliance installation, regardless of where the appliance is being installed, home or RV, are now in the CAN/CSA B149.1 Natural Gas & Propane Installation Code instead of being split between this code and the CAN/CSA B149.2 Propane Storage & Handling Code.

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

Ontario Adopts 2015 Code

Since this article was first published in Propane Canada magazine, the Technical Standards & Safety Authority (TSSA) issued an amendment to their Propane Code Adoption Document which is effective October 1, 2014. TSSA felt that new requirements in the 2015 version of the Code are considered important to be implemented in Ontario right away and addresses gaps in the current Code to enhance safety. In particular, the new requirements pertaining to cylinder use and storage at construction sites will become effective as of October 1, 2014.

The following is a summary of revisions included in the 2015 edition of the CAN/CSA B149.2 – Propane Storage & Handling Code.

Section 1 – Scope

The scope of the CAN/CSA B149.2 Propane Storage and Handling Code has been amended to remove sections that were transferred over to the CAN/CSA B149.1 Natural Gas and Propane Installation Code; namely the installation of appliances, equipment, components, accessories, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles when propane is to be used for fuel purposes;

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

The section of the scope that identifies areas to which the Code does not apply was also amended to exclude transportation of propane and the manufacture, selection, and use of standardized means of containment under Transportation of Dangerous Goods (TDG) Act and Regulations

Item (j) of the exclusions was amended to exclude any equipment extending downstream from the inlet to any container pressure regulator, commonly referred to as the 1st stage regulator. The propane system downstream of the 1st stage regulator outlet is governed by the CAN/CSA B149.1 Natural Gas and Propane Installation Code.

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

Item (k) of the exclusions was also amended to exclude the installation of propane fuel system components and tanks on vehicles covered by CAN/CSA B149.5 Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles.

Section 3 – Definitions

Section 3 of the Code provides definitions of terms used within the Code. A number of definitions were added or amended in the 2015 edition of the CAN/CSA B149.2 Propane Storage and Handling Code.

Aerosol Container (new)
A new definition for “Aerosol Container” was added which is to simplify parts of the Code and close the loophole created where restrictions are made on the manufacture, use or storage of TC 2P and TC 2Q specification aerosol containers. The same amendments are not carried over to include US DOT corresponding specification aerosol containers which are permitted by the TDG Regulations under specific conditions. New standards and specifications for aerosol containers under the TDG Regulations are planned.

A note added to the definition for aerosol containers states that pressure limits on aerosol containers in the TDG Regulations (1245 kPa at 55°C for 2Q and 1105kPa for 2P) exclude the use of 2P and 2Q containers for pure propane.

Connected For Use (new)
A new definition for “Connected For Use “was added to clarify whether or not cylinders that are properly connected to an appliance that is not running and which may or may not be turned on for use, are not in storage. Properly connected cylinders that remain connected for current, intermittent or future use, would not be subject to storage requirements.

Construction Site (new)
A new definition for “Construction Site” has been added to indicate that the handling of cylinders and propane apparatus in use or in storage at construction sites are subject to significantly differing situations.

Container
Definition of “container” was amended to remove reference to NGV. The term NGV (Natural Gas for Vehicle) is used many times in the B149.2, which is a code dedicated to propane.
NGV references are now located in the CAN/CSA B149.1 Natural Gas and Propane Installation Code. Also, the definition was modified to include the aerosol containers.

Container Refill Centre (Propane Service Station)
The definition for Container Refill Centre (propane service station) was amended to include “dispensing system” which is a new definition within the Code.

Dispensing System (new)
New definition “Dispensing System” and an amendment to the definition of “Kiosk” was created to clarify confusion within the code regarding exactly what a “dispenser” is. As a result, the word is used in various contexts throughout the code. It is proposed to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Filling Plant
The definition for “Filling Plant (bulk plant)” was amended to remove the words “and” & “or” so that the definition now states that such plants have bulk storage or container filling or vehicle transfer facilities on the premises.

The rationale provided stated it had recently come to the committee’s attention that there is a practice of transferring from rail cars to cargo liners, bulk trucks or other mobile storage vehicles, outside of a bulk plant. Presently there are no rules for how this is to be done in a safe manner. This proposed clause uses wording very similar to the accepted wording for truck-to-truck transfers since the two situations are somewhat analogous (see also revisions for 7.18.3).

Kiosk
New definition “Dispensing System” and an amendment to the definition of “Kiosk” to clarify confusion within the code regarding exactly what a “dispenser” is. As a result, the word is used in various contexts throughout the code. It is proposed to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Mass Gauge
The definition “Mass Gauge” was amended to remove the potential for the reader to conclude that there are no requirements for mass measurement gauges.

Propane Dispenser (new)
New definition for “Propane Dispenser” as part of a series of definition amendments to clarify the definitions of the various uses of “dispenser” and then incorporate these into the code as required.

Refuelling Station
The definition for “Refueling station” and “remote Dispensing Device” were deleted as they refer to natural gas installations, not propane. The definitions now exist in the CAN/CSA B149.1 Natural Gas and Propane Installation Code.

Tank
The definition for “Tank” was amended to remove reference to tanks used for NGV installations.

Tank Heater
The original definition for “Tank Heater” has been amended as well as a new definition to take into account indirect and direct gas-fired tank heaters.

Vapourizer
There are several types of vapourizers defined in the Code. Not all vapourizers are appliances as defined under the term “appliance” in B149.2 section 3. Electric vapourizers, for example, do not convert LP-Gas to useable energy. They use electricity to convert LP-Gas from the liquid phase to the vapour phase. Meanwhile, all direct-fired vaporizers are considered to be appliances by their very nature. The amendments add a definition to clarify the term “direct gas-fired tank heater” which is used in section 9 – Vaporizers.

Section 5 – General requirements for propane and propane equipment

Section 5 of the Code describes the general requirements for the storage and handling of propane and propane equipment. Changes to Section 5 in the 2015 edition affect the following sub-sections:

5.2 Container filling
5.10 Propane container restrictions

The following describes the specific parts within Section 5 which have changed within the 2015 edition of the Code.

Revision to Clause 5.2.3
This Clause is an exemption clause that exempts propane from being put into containers specifically designed for butane. The clause has been amended to provide the Transport Canada and CSGB Standards for cylinders that can be used for propane.

Revision to Clause 5.2.5
This clause was amended to clarify what standard a cylinder used for propane must meet for it to be used for anhydrous ammonia.

Revision to Clause 5.10
This clause originally restricted cylinders from being installed under any fire escape, stairway, or ramp used as a means of egress from a building. The clause has been amended to read “container” so the restriction applies to cylinders and tanks. As a result of this revision, Clause 6.5.13 was deleted.

Section 6 – Cylinder Systems

Section 6 of the Code describes the requirements for cylinder systems. Changes to Section 6 in the 2015 edition affect the following sub-sections:

6.1 Requirements for cylinders
6.2 Liquid level gauges on cylinders
6.4 Purging and filling of cylinders
6.5 Storage and use of cylinders at locations other than filling plants
6.6 Transportation of cylinders
6.8 Rooftop installation of cylinder systems

In addition, the following tables were amended in the 2015 edition:

Table 6.3 Cylinder storage clearances
Table 6.4 Storage of non-refillable cylinders in mercantile occupancies
Table 6.5 Storage of non-refillable cylinders in the back stock (warehouse) area of mercantile occupancies

Revision to Clause 6.1.1
This clause specified that cylinders must be manufactured, tested, inspected, and marked in accordance with both CAN/CSA B339 Cylinders, Spheres, and Tubes for the Transportation of Dangerous Goods code and the TDG Regulations. The clause was amended to remove the TDG Regulations requirement so that the CSA is the prescribed standard to which cylinders must be inspected and qualified. The rationale for this amendment was that when a new edition of CSA B339 is published, the TDG Regulations and this Code may find themselves referring to different editions of CSA B339 potentially leading to confusion.

Revision to Clause 6.1.2
This clause was amended to harmonize with US requirements. NFPA 58 -2008 states that cylinders with 4 lb. (1.8 kg) through 40 lb. (18 kg) propane capacity for vapour service shall be equipped or fitted with a listed overfill protection device; the current Canadian requirement starts at zero, not 4 lbs. (1.8 kg) as in the US.

Revision to Clause 6.1.5
This clause has been amended to remove the previous requirements for the 10-year cylinder inspection and requalification from the Code. The clause now states that refillable cylinders shall not be refilled if they are due for requalification as prescribed by requirements of the CSA B339.

In addition, the exemption for cylinders in excess of 240 lb (110 kg) water capacity with a protective dome cover not requiring PRV replacement was removed to be consistent with the requirements of B339. This means that all cylinders built to B339 standards must have the PRV replaced during the 10-year requalification period.

Revision to Clause 6.1.7
This clause was amended to require that cylinders have a pressure relief valve installed that meets the requirements of CAN/CSA B340 – Selection and Use of Cylinders, Spheres, Tubes, and Other Containers for the Transportation of Dangerous Goods, Class 2.

New Clause 6.1.16
This clause clarifies requirements for storing cylinders.

New Clause 6.2.3
This clause was added to mirror the markings for a dip tube in CSA B339.

Revision to Clause 6.4.5
This clause was amended to clarify that Specification TC-39M and aerosol containers cannot be filled.

Revision to Clause 6.5.1.4
The clause deals with the number of aerosol containers and TC-39 non-refillable cylinders that can be stored in a dwelling. The clause was amended for correctness.

Revision to Clause 6.5.1.4
This clause was amended to remove maximum temperature to which a cylinder can be exposed. The temperature requirement is now located in new Clause 6.1.16.

Revision to Clause 6.5.1.14
This clause was amended to permit the storage of cylinders on roofs in accordance with Clause 6.5.3.9.

Revision to Clause 6.5.1.15
This clause was amended extensively to update guidelines for cage construction to reflect current acceptable practices and to provide clear minimum design criteria that allow innovation. The changes also ensure only well-ventilated cages are used. The present location of the affected clause is under 6.5.2 Cylinders stored outdoors for commercial or industrial use or sale; however, propane cylinders can be placed in cabinets or other containers on many other sites. Therefore in addition to providing guidance on how to properly construct just industrial and commercial cabinets, the clause will now have an effect on any storage cabinet housing propane. As a result of the amendments to Clause 6.5.1.15, Clause 6.5.2.4 was deleted from the Code.

New Clauses 6.5.2.7 and 6.5.2.7.2
These clauses have been added to address any confusion regarding the sighting and signage requirements for cylinder exchange equipment. Over the last ten years, there has been a rapid increase in the use of LP-gas cylinder exchange stations for consumer propane tanks. The next step of providing better accessibility to propane tanks was the introduction of automated exchange machines.

The code needed to address the requirements for automated exchange operations. The new requirements also address risks associated with the absence of the attendant so that automated operations can be conducted safely. The Clause wording is consistent with the National Fire Code proposals and NPGA dockets.

Revisions to Section 6.5.1
This section, which addresses cylinders not connected for use at construction sites has been extensively amended to clarify acceptable “outdoor” storage by identifying proper and safe storage options that reflect conditions on construction sites. It is based on the hazards rather than focusing on the location alone.

Revision to Clause 6.5.3.2
This clause has been amended to address specific requirements for cylinder storage on construction sites which also address worksite hazards.

New Clause 6.5.3.8
This new clause provides the requirements to be followed on construction sites when moving cylinders between floors and the storage of cylinders on roofs.

Revision to Clause 6.5.3
This clause has been amended to require that non-refillable cylinders be packaged in accordance with CSA B340 and marked in compliance with the provisions of the CSA B339.

Revision to Section 6.6
Transportation of cylinders has had a note added to the beginning of the Section stating that the transportation of propane falls under the TDG Regulations and that activity under the TDG Regulations must be satisfied when transporting cylinders.

Deletion of Clauses 6.6.2 through 6.6.7.
The requirements for protection of valves are prescribed in detail in Clause 4.2.2 of CSA B340-08. The clauses were deleted to avoid overlapping and potentially conflicting requirements.

Revision to Section 6.8
This section has been amended to have propane cylinders installed on the uppermost flat roof of a building. This amendment addresses cases where a housing building is in the shape of a stair, where the roof of one level is a terrace for the level above. Being on the roof of a typical building, in the case of a fire, no one has to cross the level where the cylinders are installed. This level of protection and isolation is lost in the case of a step-shaped building.

Revision to Table 6.3
The table was amended to delete the 20 lb. maximum cylinder size that may be stored at a cylinder exchange. The rationale provided is that due to a demand from RV customers, 30 lb. cylinders are being offered at exchange locations and that the safety concerns of 30 lb. cylinders are not different from those of 20 lb. cylinders. Maintaining the cabinet maximum capacity of 500 lb. (25 x 20 lb., or 16 x 30 lb., or combination thereof) maintains the same risk and requirements of a single full exchange cabinet.

Revisions to Tables 6.4 and 6.5
These tables were amended to clarify the volume of propane in non-refillable cylinders that can be stored in retail locations. The changes replace each phrase “net weight of cylinders” in tables 6.4 and 6.5 with “quantity of propane”.

Section 7 – Tank Systems, Filling Plants, and Refill Centres

Section 7 of the Code describes the requirements for tank systems, filling plant and refill centres. Changes to Section 7 in the 2015 edition affect the following sub-sections:

7.1 General
7.4 Excess-flow and back check valves
7.8 Installation of underground tanks
7.9 Discharge from tank relief valves
7.10 Location of consumer tanks
7.17 Container filling locations with provisions for container storage
7.18 Filling plants served by rail
7.19 Container refill centres
7.20 Dispensing System
7.22 Operations and Maintenance Procedures
In addition, Table 7.5 (Location of Tanks at Filling Plant and Container Refill Centres) was amended in the 2015 edition.

Revision to Clause 7.1.10
When the liquid connections of horizontal or vertical tanks are manifolded together, the tops of the tanks shall be at the same horizontal level. Tanks that have liquid interconnections shall be installed so that the maximum permitted filling level of each container is at the same elevation. Vertical containers used in liquid service shall not be manifolded to horizontal containers. Vertical containers of different dimensions shall not be manifolded together. This revision addresses the concern that when two horizontal tanks are connected together by a common liquid line there may be instances when the larger of the two tanks is overfilled when the top of these tanks are not at the same horizontal level.

New Clause 7.4.8
This clause requires that any line utilized for product flow must have a flow capacity greater than the rated flow of the excess flow valve protecting the line.

Revision to Clause 7.8.8
A note was added to the clause recognizing that non-metallic tubing installed between metallic piping and an underground tank is acceptable as a dielectric joint. When a non-metallic line is used (typically polyethylene tubing) between the first stage regulator at the tank and the second stage regulator attached to a building there is no function served in using a dielectric union or other isolating fitting, because the polyethylene tubing is non-conducting and serves the purpose of isolating the tank and its fittings from the metal components of the building.

Revision to Clause 7.8.12
This clause has been amended to provide clearances for underground propane tanks with a capacity of 2,000 USWG or less from the building, property line, other underground services, and tanks.

New Clause 7.8.18
This clause provides underground clearances for tanks greater than 2,000 USWG.

New Clause 7.9.3
This clause now permits the discharge of a safety relief valve and other vent devices or lines to be vented within the dome, housing or curb box on underground propane tanks with a capacity of 2,000 USWG or less.

Revision to Clause 7.10.2
This clause has been amended to allow manifolded tanks with a capacity less than 125 USWG (475 L). The aggregate capacity is not used when determining separation distance to an important building, a group of buildings, or line of adjoining property that can be built upon. The largest single container in the manifolded system is used to determine the clearances required in Table 7.4.

Revision to Clause 7.10.3
This clause has been amended to remove the word “aggregate” from the clause. This provides clarification around the clearances required for tanks manifolded together to make a system as allowed in 7.10.2. This addresses issues in metropolitan areas where the 10-foot clearance to property lines cannot be met. Currently, on a bank of four 123 USWG (454 L) tanks technicians are basing their tank sets on the aggregate capacity of over 125 USWG (475 L) up to and including 1000 USWG (3800 L).

Revision to Clause 7.17.3
This clause has been amended to add the clarification that section 7.17.3 also applies to buildings housing vapourizers and that pressure relief discharges need to be located outside the building,

New Clause 7.18.3
This clause addresses the transfer of propane at a filling plant from a railcar to tank truck, tank trailer or cargo liner. The clause requires that Clauses 7.12 to 7.18 and 7.19.4 be met and that the approval of the authority having jurisdiction is needed. The clause addresses the issue of transferring from rail cars to cargo liners, bulk trucks or other mobile storage vehicles, outside of a bulk plant. The clause uses wording very similar to the accepted wording for truck-to-truck transfers since the two situations are somewhat analogous.

It should be noted that there could be confusion in terms of which authority has jurisdiction – the local Authority or Transport Canada since the unloading of railcars typically falls within the jurisdiction of Transport Canada.

New Clause 7.19.4.4
This clause permits the use of barriers other than those listed if it can be demonstrated that they provide an equivalent level of protection.

Revisions to Clause 7.20.2
This clause has been amended to permit additional methods to protect remote dispensing devices.

New Clauses 7:22 to 7:22.4.2
These new clauses prescribe operations and maintenance procedures. 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 vapourizer 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, so the new clauses establish a baseline or minimum standard.

Revision to Table 7.5
This table has been expanded to provided distances for tanks up to 90,000 uswg. The rationale for this expansion is that with installations over 10,000 USWG, the local authorities use the table in the NFPA 58. This change is to provide the tool to the local authorities and to harmonize minimum distance requirements with NFPA 58.

Section 8 – Tank Trucks, Tank Trailers, and Cargo Liners

Section 8 of the Code describes the requirements for tank truck, tank trailer, and cargo liners. Several sub-sections and clauses have been deleted in the 2015 version of the code since the activities described fall under the jurisdiction of Transport Canada. The deleted sub-sections and clauses have been moved to the CAN/CSA B620 – Highway Tanks and TC Portable Tanks for the Transportation of Dangerous Goods code as follows:

8.2 Tank equipment on tank trucks, tank trailers, and cargo liners
8.3 Pumps and compressors on tank trucks and cargo liners
8.4 Piping, tubing, hose, and fittings on tank trucks, tank trailers, and cargo
8.6 Braking systems and chock blocks
8.7 Exhaust systems
8.9 Fire extinguishers
8.10 Tank truck and cargo liner lettering
8.11 Towing tank trailers
8.12 Filling of tank trucks, tank trailers, and cargo liners

Changes to Section 8 in the 2015 edition of the Code affect the following sub-sections:

8.1 General
8.12 Filling of tank trucks, tank trailers, and cargo liners
8.13 Operation of tank trucks, tank trailers, and cargo liners
8.14 Parking vehicles used to transport propane
8.18 Repair or servicing in repair garages

Revision to Clause 8.1.1
A note has been added to this clause to explain that the requirements for design, manufacture, repair, inspection, test, marking, selection, and use of tank trucks, tank trailers, cargo liners, and portable tanks for transporting propane are prescribed by the Transport Canada’s Transportation of Dangerous Goods Regulations.

Revision to Clause 8.12.3
This clause was amended to disallow truck to truck transfers unless it is an emergency or specifically approved by the AHJ. This amendment allows the Authority Having Jurisdiction to approve truck-to-transfers in certain geographic regions within Canada where truck to truck transfers are necessitated by the need to deliver propane under uniquely difficult circumstances such as:

Coastal and island delivery where barges are used to transport propane bulk trucks to customer sites. Bulk trucks are refilled without being removed from the barge.
Delivery of propane to wellheads where the rugged terrain prevents highway bulk trucks from traveling directly to the propane tank locations. Bulk trucks specifically designed to handle the terrain are refilled by highway bulk trucks.
Delivery to logging camps and asphalt plants within the interior at certain times of the year requires that truck to truck transfers take place between the highway bulk truck and bulk trucks designed to travel rough unassumed interior roads.

New Clause 8.12.4
This new clause allows the content of a rail car may be transferred to a tank truck, tank trailer or cargo liner other than at a filling plant when approved by the authority having jurisdiction.

It should be noted that the code refers to the provincial regulator, not Transport Canada, who actually has jurisdiction over this practice.

Deleted Clause 8.13.1
The clause was deleted since the requirements for the operation of highway tanks (tank trucks, tank trailers and cargo liners) are within the scope of the TDG Regulations and included in CSA B620, CSA B621 and CSA B622 for all highway tanks.

New Clause 8.14.7
This clause requires that a tank truck, tank trailer, or cargo liner used for storage comply with Clause 7. The new clause addresses safety issues associated with parking of vehicles carrying propane for longer periods of time.

Deleted Clause 8.18.3
This clause, which dealt with repair work performed on a tank or tank equipment of a tank truck or cargo liner was deleted since the repair work is governed by TDG Regulations.

Section 9 – Vapourizers

Section 9 of the Code describes the requirements for vapourizers. Changes to Section 9 in the 2015 edition affect the following sub-sections:

9.1 General
9.2 Indirect vaporizers
9.4 Tank Heaters

New Clause 9.1.10
This clause requires that an emergency shutdown system must be installed in any tank system supplying propane to direct-fired vapourizers.

Revision to Clause 9.2.3
This clause has been amended to require the heating medium piping for an indirect vapourizer to be provided with backflow preventers and phase separators to prevent the flow of propane into such piping.

New Clause 9.2.5
This clause stipulates that if the heat source of an indirect-fired vapourizer is a source of ignition, is not certified for hazardous locations, and is located within 15 ft (4.5 m) of the vapourizer, the vapourizer and its heat source must be installed as a direct-fired vapourizer.

New Clauses 9.4 to 9.4.10
These clauses support the new definitions of vapourizers. These Clauses provide further constraints around tank heaters while also specifying the proper requirements for safe installation and use of acceptable types of tank heaters.

Section 10 – Propane as an Engine Fuel

Section 10 of the Code describes the requirements for propane as an engine fuel. A number of sub-sections and clauses were deleted in the 2015 edition of the code and moved to the CAN/CSA B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles. Deletions, including entire sub-sections, or specific clauses affect the following sub-sections:

10.1 General
10.2 Engine fuel containers
10.3 Engine fuel piping, tubing, hose, and fittings
10.4 Engine fuel container equipment
10.5 Hydrostatic relief valves
10.6 Engine fuel vaporizers (converters)
10.7 Engine fuel regulators and valves

Section 11 – Installation of appliances, equipment, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles

Section 11 of the Code describes the requirements related to the installation of appliances, equipment, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles. Most of the sub-sections and clauses in this Section have been deleted in the 2015 version of the code. These sub-sections and clauses have been moved to either the CAN/CSA B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles code or CAN/CSA B149.1 – Natural Gas and Propane Installation Code.

This section will also be renamed to “Installation of equipment, and containers on highway vehicles, recreational vehicles, outdoor food service units, and wash-mobiles”. The remaining sub-sections and clauses will be renumbered in the 2015 edition of the code.

Annex M – Risk and Safety Management Plans (non-mandatory)

A new Annex has been added to the CAN/CSA B149.2 Propane Storage and Handling Code. Risk and Safety Management Plans (RSMPs) are formal plans used to manage the risk of incidents that could result in negative consequences to like and property. The Annex specifies the approach, the management components, and resources to be applied to the management of risk. There are four primary elements of Risk and Safety Management Plans:

Hazard Analysis
Risk Assessment
Risk Mitigation & Control
Emergency Response & Preparedness

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Changes in 2015 Version of B149.1 Natural Gas & Propane Installation Code

Posted on April 30, 2014 by Bill Egbert

This article, related to changes in 2015 version of B149.1 Natural Gas & Propane Installation code first appeared in the March/April 2014 edition of Propane Canada magazine. It was updated in October 2014.

This article provides a summary of the clauses that have been amended, added and deleted in the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

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

When inspecting installations one must use the Code in existence at the time the installation was installed as Codes are generally not retroactive. It is important to remember that an existing propane installation is considered to be in compliance if it still meets the requirements of the Code at the time of installation.

It is, therefore, crucial that the gas technician not only has the latest edition of the Code and current provincial regulations but access to previous Codes for reference when inspecting existing installations.

The following is a summary of revisions included in the 2015 edition of the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

Section 2 – Reference Publications

Section 2 of the Code provides a listing of the supporting codes and publications referred to within the CAN/CSA B149.1 Natural Gas & Propane Installation Code. The following provides information related to references that have been changed or added.

Acceptance of ANSI/LC-4/CSA6.32-2012 Standard
The code accepts the ANSI/LC-4/CSA6.32-2012 Press-Connect Metallic Fittings for Use in Fuel Gas Distribution Systems Standard to permit the use of press-connect metallic fittings for use on natural gas and propane systems. The standard was originally developed for copper metallic press fittings but in 2012 the standard was revised to include other metallic materials (copper, carbon steel and stainless steel).

Section 3 – Definitions

Section 3 of the Code provides definitions of terms used within the Code. A number of definitions were added or amended in the 2015 edition of the CAN/CSA B149.1 Natural Gas & Propane Installation Code.

Boiler
An appliance intended to supply hot liquid or vapour for space-heating, processing, or power purposes and does not include appliances certified as water heaters. The definition was changed to exclude appliances certified as water heaters.

Flue backflow preventer (new)
A system or device used in common venting of positive pressure appliances to prevent the exhaust flue from active appliances sharing the system from flowing back into the vent of dormant or idling appliance(s). This definition recognizes check valve technology developed to prevent flue products backflow issues.

Gas Connector
Expansion of the definition of what is a “gas connector” to recognize the different types of appliance installations and connector applications;

Permanently installed appliances where the gas connector is designed not to be repeatedly moved or disconnected/connected to the piping system.
Movable appliances where the connector is designed for repeated movement and disconnects or reconnection.
Gas connectors for outdoor use.
Quick disconnect devices or gas convenience outlets.

Gas Convenience Outlet (new)
A permanently mounted certified hand-operated device that provides a means for connecting and disconnecting an appliance to the gas supply piping by way of a gas hose or gas connector.

Direct Gas-Fired Air Heaters (new)
The new definition recognizes that a direct gas-fired air heater may be capable of either ventilation mode, to off-set building heat loss; or process mode, intended for drying, baking or curing product; or both operating modes.

Pipe Wrap Tape (new)
Adhesive tape made of PVC or polyethylene material with a minimum thickness of 10 mil (0.25 mm), with an adhesive resistant to water. The definition explains what is considered to be acceptable wrap since field inspection continues to find unacceptable pipe wraps such as duct tape and thin, low-quality electrical tape being used in the applications addressed by the two subject clauses.

Quick-disconnect Device
The definition was expanded to address a disconnect device equipped with an automatic means to shut off the gas supply when the device is disconnected and is certified to ANSI Z21.41/CSA 6.9.

Section 4 – General

Section 4 of the Code describes the general requirements of propane and natural gas installations. Changes to Section 4 in the 2015 edition affect the following sub-sections:

4.8 Mobile homes
4.9 Hazardous locations
4.24 Odorization of propane
4.25 Mobile homes and recreational vehicles

New Section 4.8 – Mobile homes
This Section was transferred from the CAN/CSA B149.2-10 Propane Storage and Handling Code. It provides a single source for appliance and gas system installations regardless of installed location.

Revision to Clause 4.9.2
Recognizes engineered appliances that are used in hazardous locations that are not certified, but field approved.

New Clause 4.24.1
To address the odourization of natural gas from private natural gas wells where it is used for fuel purposes supplying an occupied building.

New Section 4.25 – Mobile homes and recreational vehicles
This Section was transferred from the CAN/CSA B149.2-10 Propane Storage & Handling Code. It provides a single source for the installation of appliances regardless of their installed location.

Section 5 – Pressure Controls

Section 5 of the Code describes the requirements for pressure controls in natural gas and propane installations. Changes to Section 5 in the 2015 edition affect the following sub-sections:

5.1 Gas system pressure
5.2 Pressure regulators

Clarification to Table 5.1
As currently written, the code suggests that it would be impossible to use natural gas in a building under construction. To be consistent, a value for the natural gas was inserted in the last row of Table 5.1 – Pressure inside buildings.

New Clauses 5.2.2.5 and 5.2.2.6
Two clauses dealing with regulators installed on vehicles from CAN/CSA B149.2-10 Propane Storage & Handling Code have been transferred to this Code so that all requirements for regulator installation are in a single source regardless of installed location.

Section 6 – Piping and tubing systems, gas hose, and fittings

Section 6 of the Code describes the requirements for piping and tubing systems, gas hose, and fittings in natural gas and propane installations. Changes to Section 6 in the 2015 edition affect the following sub-sections:

6.2 Material
6.9 Joints and connections
6.11 Appliance connections
6.15 Underground piping and tubing
6.16 Protection of piping and tubing
6.17 Identification of piping or tubing
6.18 Manual shut off valves
6.21 Gas connectors
6.27 Hoses

Revisions to Clause 6.2.2
To recognize fittings manufactured to ANSI-LC-CSA 6.32.

Revisions to Clauses 6.9.1 and 6.9.9
To recognize the use of press connection joints.

Revisions to Section 6.11
To clarify how an appliance is to be connected to the gas piping system; addresses the use of corrugated stainless steel tubing (CSST) systems and tubing system installations and recognizes the use of gas convenience outlets.

Revisions to Clauses 6.15.2 & 6.15.3
To recognize the use of press-connect fittings on underground piping and tubing systems.

New Clause 6.16.1
To address the contact of metallic gas piping with a pipe of a different material which can result in galvanic corrosion.

Revision to Clause 6.16.7
To add the definition of “pipe wrap tape”.

Revision to Clause 6.17.2
Clarifies that all piping/tubing needs to be identified; not just indoor piping/tubing systems at care, detention, occupancy, commercial, industrial, and assembly buildings.

Revision to Clause 6.18.1
Added wording to clarify that a manual shut-off valve must be certified for its intended purpose and rating.

New Clause 6.21.4
Permits the use of a gas connector certified to ANSI Z21.101/CSA8.5 for connecting ranges, refrigerators, and clothes dryers to the building piping.

New Section 6.27
Transfers clauses dealing with hoses transferred from CAN/CSA B149.2-10 Propane Storage & Handling Code to this Code to provide a single source for the installation of hoses.

Section 7 – Installation of specific types of appliances

Section 7 of the Code describes the requirements for specifics types of appliance installations. Changes to Section 7 in the 2015 edition affect the following sub-sections:

7.2 Generators, compressors/pressure boosters, stationary engines, and turbines
7.13 Central furnaces
7.18 Construction heaters and torches
7.19 Direct fired door air heaters
7.21 Non-recirculating direct gas-fired industrial air heaters (DFIAH)
7.22 Infrared heaters
7.26 Water heaters
7.27 Unit heaters

Revision to Clause 7.2.1.3
The clause related to venting and air supply excludes Clause 8.5.4 from the requirements to provide consistency of intent.

Revision to Clauses 7.2.4.2 & 7.2.4.3
This clause, related to stationary engines and turbines, recognizes ANSI Z21.21/CSA 6.5 C/I for safety shut-off valves and to permit the second safety shut-off valve to be installed upstream of the appliance zero governor type regulator.

Revision to Clause 7.13.1
Clarifies that a furnace must be installed on a firm level base.

Revision to 7.18.10
Changes the requirement to not leave a torch unattended to apply to both natural gas and propane.

Revisions to Section 7.19
The clause, related to direct-fired door air heaters, addresses the installation of refurbished used direct-fired door heaters that were originally certified to withdrawn Standard CGA 3.12 or CAN 1.3 12-78. There is a used market for these heaters and they can still be functional, if well maintained, after 30 years. Because of this used market, they will often be installed on renovations or new projects.

New Clause 7.21.1
This clause related to non-recirculating direct fired industrial air heaters was the result of editorially separating current clause 7.21.2 into two separate clauses and revise the numbering accordingly.

Revisions to renumbered Clause 7.21.8
Ensures that outside air dampers or closing louvers not certified as an integral part of the appliance are interlocked so that the main burners do not operate until the air dampers are fully open.

New to Section 7.22
Clauses were added to address the installation instructions for refurbished Direct Gas-Fired Process Air Heaters, which have not been manufactured since 2002.

Deleted Clause 7.26.4
The clause addressed minimum access clearance to the water heater burner. The present accessibility section and manufacturer’s instructions were deemed adequate.

Revisions to Clause 7.27.6
Changes address return air inlets in combo heating systems. The present clause was found to be confusing and was rewritten for clarification.

Section 8 – Venting systems and air supply for appliances

Section 8 of the Code describes the requirements for venting systems and air supply for appliance installations. Changes to Section 8 in the 2015 edition affect the following sub-sections:

8.2 Air-supply determination for central-heating furnaces, boilers, and hot water heaters
8.3 Air supply openings and ducts
8.8 Air supply by mechanical means
8.10 Methods of venting appliances
8.14 Vent and chimney termination
8.16 Vents and chimneys serving two or more appliances
8.20 Size and height of interconnected vent connectors

Revision to Clause 8.2.4
Clarifies that an outdoor air supply to an enclosure can be sized using either table 8.3, for appliances having draft control devices; or table 8.4 for appliances not having draft control devices.

Revision to Clause 8.3.4
Ensures a combustion air supply device has air flow proving interlocked to the appliance(s) served and sufficient airflow is demonstrated.

Revision to Clause 8.8.2
The clause, related to air supply was found to be confusing and was rewritten for clarification.

Revision to Clauses 8.10.6, 8.14.13 & 8.20
Provides requirements for common venting of appliances with positive pressure venting. Check valve technology has been developed to prevent flue products backflow issues. This venting technology is currently permitted in Europe.

Revision to Section 8.16
For vents and chimneys serving two or more appliances, a note was added to explain differences between common venting of Category 1 & 11 appliances and Category 111 & 1V appliances.

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Why Employee Engagement Matters

Posted on February 28, 2014 by Bill Egbert

This article, related to why employee engagement matters, first appeared in the Jan/Feb 2014 edition of Propane Canada magazine.

One of my favourite parts of facilitating a course entitled “Achieving Extraordinary Customer Relations” for a national propane retailer was when I asked participants to describe their worst and best customer service experiences. While the point of the exercise was to illustrate the negative impacts of poor customer service on the organization, the underlying reality is that high customer satisfaction cannot be achieved through interaction with disengaged employees.

An ever increasing body of research continues to make the point that employee engagement has a direct impact on key business performance. For example, organizations with higher employee engagement benefit from higher staff retention rates, happier customers resulting in increased revenues and repeat business, improved safety rates, often above industry norms, and greater efficiency and productivity.

So what does the term “employee engagement” really mean?

When asked to describe an “engaged employee,” people will often describe enthusiastic people who can be counted on to roll up their sleeves when it matters, help other team members without being asked, take extraordinary steps to satisfy customers, accept new job challenges and tasks, and show flexibility in the face of changing workplace priorities. Every manager wants employees that can be described this way, yet this goal seems elusive. Study after study continues to show that on average, only around 30% of employees describe themselves as “engaged” or “highly engaged” and another 45% describe themselves as “partially engaged.” The majority of employees know how to keep doing competent or passable work to keep the paychecks coming in but are not really engaged in their work.

Two factors affecting Employee Engagement

So why are we seeing these disappointing engagement statistics in spite of well-intentioned efforts to engage employees? Two factors deserve attention.

First, many organizations are trying to improve employee engagement solely through organization-wide engagement surveys designed to assess engagement, identify successes, and point to areas for improvement. While these surveys certainly paint a broad picture of engagement, they are not as helpful when it comes to understanding and acting on the needs of unique individuals, which is essential to sustaining engagement. Surveys are best for identifying organization-wide issues and opportunities and their success is dependent on making visible changes based on results. Failing to respond to survey feedback can very easily increase skepticism and disengagement and amount to a missed opportunity.

Beyond relying too heavily on a single tactic (i.e. surveys), another important factor contributing to less-than-desired engagement is arguably what is taking place (or not taking place) between employees and their managers.

Let me explain the second factor. Something important to remember is that engagement is a personal choice, based on criteria defined by each individual employee. No two employees have the same needs or motivators, so it is important to identify what motivates each employee individually. This can only be achieved through direct and deliberate conversations and collaboration between the employee and his or her immediate manager.

In many organizations, especially small and medium-sized ones, managers are often not supported in carrying out the conversations and collaboration that can foster engagement. Managers certainly try to engage their employees, with varying degrees of success, but without the needed skills or tools, their efforts often fall short of the mark. Fortunately, there are a number of tools and training programs available to assist managers in acquiring these skills. If you look at your own organization, to what extent do such conversations and collaboration take place, and how effective are they? As we are seeing (and if this is any comfort), the propane industry is not unique in its need to address skills gaps and an aging workforce.

Tools to help to achieve increased engagement

So how can organizations achieve greater employee engagement overall? Further, if identifying an employee’s unique motivators, aspirations and concerns and providing ongoing assistance in achieving the employee’s goals is essential for engaging employees and these are skills that many managers lack, what can the organization do?

Very simply, I am advocating a balanced approach – one that combines the macro and the micro: Organization-wide surveys provide good value and should be combined with greater attention and support to employee-manager collaboration, which has a great impact on individual engagement. To go the distance in engaging your employees you need both the macro and the micro. A one-sided approach emphasizing surveys won’t fully achieve your goals.

Fortunately, there are some excellent tools available to assist managers to strengthen employee-manager collaboration and increase employee engagement at the individual level. These provide managers with the skills they require to understand and act upon the individual needs of their employees. By creating the environment where employees choose to be and remain fully engaged you are also setting up your organization to be an employer of choice among desirable candidates who may be considering many employment options.

When I think back to the days I was facilitating customer service workshops, I heard a number of great stories involving customer service nightmares and horrible bosses and we shared a lot of laughter. However, when the conversation shifted to describing great customer service experiences, many of the participants observed, in their own way, the commonality of great customer service experiences – fully engaged employees.

Everybody has the capacity to be fully engaged. The challenge is to create the environment where employees make the choice to be and remain engaged. More attention to individual employees and their unique needs is a great start if your goal is to create a more engaged workforce.

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Responding to Carbon Monoxide Calls

Posted on February 28, 2014 by Bill Egbert

This article is a compilation of two articles which first appeared in the 2013 Nov/Dec and 2014 Jan/Feb editions of Propane Canada Magazine and provides guidelines related to responding to carbon monoxide calls.

With the onset of fall and winter, heating systems will be reactivated after a summer of disuse. It is the season where, as a gas service technician your knowledge
and skills will be called upon to keep people warm and safe. There are two calls that should cause a heightened response: Gas leak and carbon monoxide (CO). Your company and employees response can save lives and reduce injuries caused by CO poisoning. Your company’s emergency response procedures for CO incidents are most effective when you coordinate with fire services, ambulance, and police.

It is important that you establish a “Safe Entry Procedure” for when you are going to enter a building where there is a reported CO incident. CO calls can be made when a CO alarm has sounded or when the occupants suspect a possible CO exposure due to illness or strange odours. A CO alarm should never be ignored.

Immediate evacuation is necessary when a CO alarm sounds. CO alarms are designed to alarm at exposure levels below the level at which people exhibit symptoms of CO poisoning. This gives the occupants time to take action to protect themselves. That being said, CO levels can escalate quickly, in which case the CO alarm is responding to a high level of CO in the atmosphere. CO alarms should not activate below 30 ppm.

There have been instances where CO alarms have sounded and neither a CO elevation nor a source could be identified. Over the years, changes have been introduced into standards for CO detectors to reduce the number of unexplained occurrences.

If a CO alarm is manufactured prior to October 1, 1998, and a CO elevation or CO source cannot be located, the resident should be advised to purchase a new alarm. CO alarms also have a service life marked on them and should be replaced when the end of the service life is reached.

A new CO alarm should meet one of the following standards:

CSA 6-19-10, 2001;
UL 2034, Second Edition 1998; or
IAS 6-96 Second Edition, June 1, 1998.

Professional CO detection equipment in the hands of a trained gas technician is essential for attending CO calls and finding the source of elevated CO readings in a building’s atmosphere. Use, maintenance and periodic calibration procedures should be established. Manufacturers of CO detection equipment generally provide recommendations and instructions for maintenance and recalibration.

It is important that the CO detector a gas service technician is using is within the calibration time frame. Most CO detectors require recalibration once every 12 months.

The calibration period can be shortened depending on use, stored environment, handling and how transported in the service vehicle. This is the type of instrument you do not want bouncing around in your service vehicle.

Finding the reason for the CO alarm can be time-consuming and difficult, especially if the elevated levels are the result of transient conditions such as downdrafts from exhaust vents and chimneys, CO infiltration from outdoor equipment operating near open windows or doors, etc.

The responding service technician must have a basic level of knowledge about carbon monoxide:

How it is generated;
How it can become abnormally elevated;
How it is distributed through a home; and
What the exposure symptoms are.

The first level of response is the person taking the call. It is important that that person has a procedure to instruct the customer on what actions they should take to protect human life and then property. If you use a third-party call service be sure to supply them with your company’s response procedures for a leak or CO call.

The following is a possible response scenario that the person receiving the CO call could follow. Each company should develop their own response procedures based on how service calls are received and how the response is to be delivered.

When developing procedures, the amount of time a response will take must be considered. For example, it may be quicker to contact the local fire service or HVAC contractor rather than wait for your service technician to arrive.

CO Incident Guidelines for Dispatchers

Obtain caller’s name, address and telephone number. Ask if anyone is unconscious, nauseous, lightheaded, having headaches or chest pains.

If the answer is “YES”, then complete the following steps :

Send ambulance and fire services;
Send trained service technician equipped with a professional CO detector;
Advise caller and all other residents to go outside or to a neighbour’s home immediately. DO NOT TAKE TIME TO VENTILATE THE HOME, UNLESS SOMEONE IS UNCONSCIOUS OR CANNOT LEAVE;
Advise residents that once they are outside they should not re-enter the home until response personnel have inspected conditions in the structure and have determined that it is safe to return;
In extreme weather conditions and when neighbours are far away, advise residents that they can shelter indoors by staying in one room with a door or window open to the outside. There should be no vehicles running in the garage or any fuel burning appliances operating in the room where the residents seek shelter;
Advise the caller to open all windows in the room and close any doors that go to other parts of the house. If there is an exhaust fan in the room, turn it on to help bring in fresh air more quickly.

If the answer is “NO“, then complete the following steps:

Ask if a CO alarm is sounding. If yes or don’t know, follow procedures listed under “YES”.
If the answer is “NO” to the alarm sounding, record caller’s reason to suspect CO incident and determine if CO investigation is needed. If so, then follow the procedures provided by your company.

CO Incident Reporting Form

A Carbon Monoxide Incident Report Form is essential in providing a structured approach to help you identify the cause of the call for help and to assess when it is safe for a resident to re-enter the home. The form should list the CO levels and what action is required to be taken. The form should also capture all the readings taken.

The following are areas that a CO incident reporting form should address:

Determine the level of care needed by household members;
Identify potential sources of elevated CO in the home and attached garage;
Take and record indoor CO measurements;
Evaluate information;
Complete the investigation; and
Advise and follow up.

Investigation Process

During the investigation process, residents should be evacuated from the home. After the investigation is complete, it is time to assess the information you have and in conjunction with fire services. If they responded, provide advice to the residents, including whether they can safely re-enter their home. The final decision on re-entry may need to be made by someone other than the first responder.

The CO levels you measured in various rooms of the building should be taken in the centre of the room in ambient air, making sure that you are about 5 feet away from any appliance. Based on those measurements and your evaluation of the information you gathered in your investigation, identify any areas of the structure with measured CO levels of:

70 ppm or higher;
Between 30 ppm and 70 ppm; or
Less than 30 ppm.

These levels are benchmarks used to provide guidelines for giving advice to residents.
These following Benchmark Guidelines were sourced from a document published by the U.S. Consumer Product Safety Commission. I expanded the advice to be given and actions to be taken to include provincial regulatory requirements. Your company may have different benchmarks with specific actions that you are to follow.

When CO Levels are 70 ppm or higher

The following steps provide action guidelines when carbon monoxide levels are 70 ppm or higher:

If the source of CO appears to be a vehicle or a lawnmower or generator in a garage then:
1. Turn off the engine if it is still operating; and
2. Advise the residents that an engine should not be left idling in an attached garage, even if the garage door is open.
If the source of CO appears to be a permanently installed appliance then:
1. Turn off the appliance;
2. Shut off the fuel supply to the appliance – tag the appliance in accordance with your company and provincial requirements;
3. If an independent contractor verbally, and in writing notifies the fuel supplier in accordance with your company and provincial requirements; and
4. Advise the residents in writing (use your work order to document) that the appliance is creating large amounts of CO and must not be reactivated until the reason for the high CO levels has been identified and corrected by a certified propane technician.
  1. Note: The appliance may not need repair or replacement. It is possible that exhaust fans or other large air moving appliances are creating a situation in the home that may need attention. House depressurization is a complex and sometimes difficult situation to recreate and is beyond the skill sets of a propane technician.
  2. If you suspect that building depressurization is causing a problem then advise the customer to arrange for a depressurization test to be performed on the home. There are companies that specialize in doing this type of testing and can assist the customer in overcoming the depressurization problem.
  3. Provincial Authorities Having Jurisdiction (AHJ) have guidelines as to when you are required to report a CO incident to them. These guidelines should form a part of your company’s reporting and documentation procedures when responding to a CO call.
If the source of CO appears to be a portable appliance or misuse of an appliance then:
1. Turn off the appliance;
2. Unvented gas appliances, such as infrared camp heaters, barbecues, etc., are not permitted for use indoors.
3. The most common, especially during power outages, are gas range top burners and oven for heat; and
4. Educate the user about the dangers of CO and the proper use of appliances.
If you cannot find an apparent source of elevated levels of CO then follow your AHJ guidelines and your company’s policy. Advise the residents to follow up with a company that specializes in building depressurization, etc.
In co-operation with fire services advise the residents that they can return home after it is cleared of CO. When your equipment shows levels of CO below 30 ppm residents can return home. If your equipment shows a CO level below 30 ppm, and if a household CO alarm is still sounding, then advise the consumers to remove and replace it as soon as possible.
Advise the residents to have their gas burning appliances inspected immediately and maintained once a year by a certified gas technician.
Advise residents to use a CO alarm manufactured to the current standard issued by the Canadian Standards Association (CSA), Underwriters Laboratories Inc. (UL) or International Approval Services (IAS).
Advise the residents to call again if their CO alarm sounds, particularly if they have followed the above recommendations.

CO levels between 30 ppm and 70 ppm

In certain cases to address the possible cause of carbon monoxide, the following suggested actions and advice mirror those listed in the CO levels 70 ppm or higher:

If the source of CO appears to be a vehicle or a lawnmower or generator in a garage then:
1. Turn off the engine if it is still operating; and
2. Advise the residents that an engine should not be left: idling in an attached garage, even if the garage door is open.
If the source of CO appears to be a permanently installed appliance then:
1. If you cannot rectify an issue with the appliance, turn off the appliance, shut off the fuel supply to the appliance – tag the appliance in accordance with your company and provincial requirements;
2. If an independent contractor verbally and in writing notifies the fuel supplier in accordance with your company and provincial requirements; and
3. Advise the residents in writing (use your work order to document) that the appliance is creating potentially dangerous levels of CO and must not be reactivated until the reason for the CO levels has been identified and corrected by a certified gas technician.
If the source of CO appears to be a portable appliance or misuse of an appliance then:
1. Turn off the appliance;
2. Unvented gas appliances, such as infrared camp heaters, barbecues, etc., are not permitted for use indoors;
3. The use of an approved appliance for a purpose other than its intended use and approval is not permitted.
4. The most common, especially during power outages, are gas range top burners and oven for heat; and
5. Educate the user about the dangers of CO and the proper use of appliances.
Advise the residents to follow up with a company that specializes in building depressurization, etc.
In co-operation with fire services advise the residents that they can return home after it is cleared of CO. When your equipment shows levels of co below 30 ppm, residents can return home. If your equipment shows a CO level below 30 ppm, and if a household CO alarm is still sounding, then advise the consumers to remove and replace it as soon as possible.
Advise the residents to have their gas burning appliances inspected immediately and maintained once a year by a certified gas technician.
Advise residents to use a co alarm manufactured to the current standard issued by the Canadian Standards Association (CSA), Underwriters Laboratories Inc. (UL) or International Approval Services (lAS).
Advise the residents to call again if their CO alarm sounds, particularly if they have followed the above recommendations.

CO levels less than 30 ppm

Advise residents that you did not find high levels of carbon monoxide. If the call was the result of a sounding CO alarm, advise the residents to review the manufacturer’s instructions about a sounding co alarm and contact the manufacturer if necessary. If the alarm was manufactured before October 1, 1998, advise the residents to purchase a new alarm meeting the standards published by CSA, UL or IAS.

Advise the residents that CO alarms have a limited life and that their alarm may need to be replaced.
Advise the residents never to ignore a sounding co alarm and to call again if the alarm activates.

Benchmark CO Levels

Varying levels of carbon monoxide exposure may cause varying health effects, including levels that are not likely to cause adverse health effects in healthy adults, higher exposure levels that can be potentially life threatening and levels so high as to cause death.

The effects of CO exposure depend on the length of time that a person has been exposed to CO, how high the CO concentration is, how physically active the person is at the time of exposure and the person’s general health.

When a person breathes in CO it combines with oxygen in the blood to form poisonous carboxyhemoglobin (COHb). The amount of COHb in a person’s blood is expressed as a percent. For example, a person exposed to CO might be described as having 8% COHb. Heavy smokers may have baseline levels of 10% COHb. A 10% COHb level is a reference value that is widely regarded by physicians as confirmation of CO poisoning, even when there are no symptoms. When used as an upper limit, it is recognized as protecting healthy adults against the harmful effects of CO.

This benchmark is built into industry standards for CO alarms, which must sound at exposures predicted to reach 10% COHb in healthy exercising individuals. This will occur at the following concentrations:

70 ppm CO for slightly more than 3 hours;
150 ppm for 50 minutes; and
400 ppm for approximately 15 minutes.

70 ppm is the lowest level that can cause COHb to exceed 10%. At these same exposures, less active individuals will have less than 10% COHb. At levels less than 30 ppm, it is unlikely that adverse health effects will occur in healthy adults. This is the second benchmark level in industry standard CO alarms – they cannot sound at less than 30 ppm or less. This helps to prevent false or nuisance alarms when co levels may temporarily spike due to outdoor air inversion or when an appliance is first turned on.

In conclusion, as previously mentioned, the benchmark levels used in this article are suggested guidelines based on a document published by the United States Consumer Product Safety Commission.

You may already be using Standard Operating Procedures (SOPs) that use different CO ppm levels as a benchmark. If your SOPs work well for your needs and resources, and if the benchmark levels of those SOPs based on your experience and that of medical personnel in your community adequately provide for the safety of residents, then you may want to continue using those SOPs.

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Incident Management

Posted on October 31, 2013 by Bill Egbert

If you store, transport or deliver fuels or install or service fuel-burning equipment, chances are, your company will be involved in an incident of some type. Learn how you can benefit from the creation of an Incident Management Team in this article, which first appeared in the Sep/Oct 2013 edition of Propane Canada magazine.

Managing Incidents

Over the years of investigating fires, explosions, fuel escapes and personal injury incidents in the propane, natural gas and fuel oil industries, I have seen, on many occasions, where the mismanagement of the incident by the fuel supplier has resulted in the fuel supplier being sued. If the incident had been managed correctly the lawsuit could have been avoided.

Obviously, the best way to manage incidents is not to have any in the first place. However, mechanical equipment will eventually fail and the human error factor is always present. If you store, transport or deliver a fuel, and/or install or service fuel burning equipment, then the chances are that at some point in time, your company will be involved in an incident of some type.

Ignoring an incident and leaving it to others, such as the local fire services or government investigators to determine if your company is or is not involved, is the worst possible position you can take. Doing nothing is not an option if you wish to stave off potential lawsuits that can affect your bottom line through deductible payouts, increased insurance premiums, and poor community reputation.

Even when you are convinced upfront that your company has no involvement, past experience has shown that by aggressively responding to and managing incidents you can significantly reduce your exposure and costs.

Benefits of Managing Incidents Correctly

Many years ago, a client of mine established a team and procedures for handling incidents with very positive results. I was fortunate to be a member of the team as an independent investigator. We had many successes in proving that our client had no responsibility for the incidents, saving a considerable amount of money in deductible payouts and legal fees, etc.

In one case, a heavy equipment repair and storage garage containing several expensive pieces of earth-moving equipment burned to the ground. The fire department investigator concluded that the fire had started in the wall behind a sealed combustion propane heater and that the heater must have been installed incorrectly.

The heater had been installed by my client several years prior to the incident. The heater had been removed from the scene by the local fire department and retained as evidence. During our examination of the heater, we removed the outer casing and noticed a green substance had melted on the heat exchanger.

At the site, we had found melted and partially melted one-litre green plastic containers of motor oil. With this evidence, interviews were conducted with the people working in the garage, and it was soon discovered that a common practice was to place the plastic containers of motor oil on the propane heater’s top grill to heat the oil to make it easier to pour.
We finally learned that a plastic container of motor oil had been placed on the heater when the employees went to a local restaurant for coffee. The structure was on fire when they returned to the garage.

The original cause of the accident was changed to reflect what our investigation had determined, which exonerated my client of any wrongdoing.

In a second incident, a propane kitchen range, installed by my client, was blamed by the local fire services for a fire that caused extensive damage to a home. Fortunately, we arrived at the scene prior to any evidence being disturbed. Our investigation at the scene determined that one of the top burner valves was in the high position and that a frying pan was sitting on that burner. After interviewing the homeowner, we learned that just prior to going to church that morning he had cooked bacon, eggs, and home fries for breakfast.

While the cast-iron frying pan was undamaged and all the grease in the pan consumed, fire patterns indicated that the fire had spread from the frying pan to the kitchen cabinets above the range, not from the wall behind the range as originally thought by the fire department investigator. The homeowner had forgotten to turn off the burner when he finished cooking breakfast.

Again, the original cause was changed to reflect what we had determined and our client was exonerated of any wrongdoing.

Incident Management Team

The management of an incident should use a team approach, which may or may not be dependent upon the severity of the incident, and include your insurer, adjuster, lawyer, company incident manager, internal company investigator, and possibly, an outside independent technical investigator.

The team should be established prior to any incidents taking place; since there is no time to put together a team if and when an incident occurs. Each team member must be aware of his/her responsibilities.

The incident has most likely been reported to fire services, police, etc. by the time you become aware that an incident has occurred.

Incident Manager
The internal company person who is notified of the incident, determines the severity of the incident and activates the appropriate team members, notifies senior management, insurer and enforcing authority (legal obligations). Other responsibilities include:

In accordance with company policy, provides information such as customer files, staff qualifications, work orders, etc. as requested by enforcing authority investigators; and
Continually monitors the investigation as it progress, receives and reviews reports from the technical investigator and adjuster, reports to senior management and adds or removes team members as the response requires.

Legal Services
I have several clients where the incident manager is either a part of the in-house legal team or a member of the corporation’s external law firm. It’s up to management of the company to determine at what stage of the investigation legal services become involved.

Having a lawyer involved in the first stages to help guide the investigation can be a great benefit down the road as he/she will know what information, from a legal point, must be determined, what information is to be kept privileged and what information can be shared.

Technical Investigator
Attends the scene and tries to become part of the investigation team where fire services or government investigators are involved. The Technical Investigator can act as the liaison between government investigators and the company, and keep abreast of the government investigation.

The Investigator
Conducts his/her independent investigation following practices as described in NFPA 921 Guide for Fire & Explosion Investigations. The Investigator acts as an expert witness and supports the legal team during mediation, examinations for discovery and trial.

Administrator
Each team needs an administrator who is familiar with the company’s filing system and record-keeping policies. The administrator is key in keeping track of customer and employee files that may be requested and provided to adjusters/government investigators and company investigator. The administrator photocopies files for distribution and retains the originals.

Insurer/Adjuster
Liaison with other insurance adjusters obtains permission for company investigator to enter the scene, interviews witnesses and company staff who may be involved. Provides reports to the insurer, and provides information to the technical investigator and incident manager.

Media Spokesperson
This person may be the incident manager, legal services member or a separate individual assigned to this task. The Media Spokesperson responds to calls from the media.

In conclusion, having an incident team in place enables you to manage an incident in the best interests of the company. Attending incident scenes and activating the team may absolve your company of any wrongdoing. However, it may be determined that your company does have some liability exposure. If so, you now know what that liability is and can move forward managing the liability to reduce the financial impact to your company.

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Unvented Heaters in Poultry and Livestock Facilities

Posted on August 31, 2013 by Bill Egbert

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

Introduction

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

Unvented heaters in poultry and livestock facilities

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

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

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

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

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

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

Unvented infrared brooder-style heater with standing pilot.

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

Unvented infrared tube heater.

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

Unvented direct-fired box heater.

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

Ventilation

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

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

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

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

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

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

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

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

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

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

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

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

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

Security

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

Conclusion

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

Regulatory Proposal

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

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

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

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

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

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

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Standard of Care

Posted on June 30, 2013 by Bill Egbert

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

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

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

Introduction to Standard of Care

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

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

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

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

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

Standard of Care – What Does it Mean?

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

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

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

Benefits of Implementing a Standard of Care Program

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

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

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

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

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

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

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

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

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

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

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

Basic Standard of Care Program

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

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

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

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

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

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

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

Development of a Standard of Care Program

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

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

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

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

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Bonding of the Gas System

Posted on April 30, 2013 by Bill Egbert

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

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

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

Key Definitions

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Ontario Adoption of Codes

Code Updates Referred to in TDG Regulations

Training Requires Updating

Status of publication of the 2015 series of CSA Codes and Standards

Introduction of the Fuels Learning Centre

Using Approved Appliances

Approval Labels from Recognized Testing Organizations

Use a Checklist as Part of Documentation

Ontario Adopts 2015 Code

Section 1 – Scope

Section 3 – Definitions

Section 5 – General requirements for propane and propane equipment

Section 6 – Cylinder Systems

Section 7 – Tank Systems, Filling Plants, and Refill Centres

Section 8 – Tank Trucks, Tank Trailers, and Cargo Liners

Section 9 – Vapourizers

Section 10 – Propane as an Engine Fuel

Section 11 – Installation of appliances, equipment, and containers on highway vehicles, recreational vehicles, mobile housing, outdoor food service units, and wash-mobiles

Annex M – Risk and Safety Management Plans (non-mandatory)

Section 2 – Reference Publications

Section 3 – Definitions

Section 4 – General

Section 5 – Pressure Controls

Section 6 – Piping and tubing systems, gas hose, and fittings

Section 7 – Installation of specific types of appliances

Section 8 – Venting systems and air supply for appliances

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Two factors affecting Employee Engagement

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CO Incident Guidelines for Dispatchers

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Investigation Process

When CO Levels are 70 ppm or higher

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Benchmark CO Levels

Managing Incidents

Benefits of Managing Incidents Correctly

Incident Management Team

Introduction

Unvented heaters in poultry and livestock facilities

Ventilation

Security

Conclusion

Regulatory Proposal

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Standard of Care – What Does it Mean?

Benefits of Implementing a Standard of Care Program

Basic Standard of Care Program

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