Transport Canada Publishes White Paper on TDG Training

Transport-Canada-Logo2Over the past several years, Transport Canada has held a number of consultations to determine to improve the quality and consistency of course ware used to train individuals on the requirements related to the Transportation of Dangerous Goods.  In 2016, Transport Canada published a White Paper to summarize the findings of their consultation and to develop a framework for moving forward.

To view or download a copy of this White Paper, click on the “Read More” button below.

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

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

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

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Transport Canada Proposes Changes to TDG Regulations Related to Propane Shipped on a Passenger-Carrying Ferry

Transport-Canada-Logo2Transport Canada has proposed amendments to the Transportation of Dangerous Goods regulations specifically related to transporting propane on passenger carrying ferrys. Most of the changes focus on travel distance variances between TDG regulations and international regulations.

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PRV Change Out Challenges

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

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

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

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

Three Basic Steps for PRV Replacement

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

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

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

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

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

Using a Flare Stack

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

Using Tank Rollers

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

TDG Requirements

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

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

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

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

The Magnitude of Meeting this Regulatory Obligation

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

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

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

Training Requirements

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

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

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

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

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

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

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

Update on Training

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

Purging the Propane Tank

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

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

Achieving Compliance Will be a Strain on Resources

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

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

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Truck-to-Truck Propane Transfers

This article, related to truck-to-truck propane transfers, first appeared in the January/February 2015 edition of Propane Canada magazine.

Bulk Truck on BargeThere are times when there is a need to transfer liquid propane from one propane transport vehicle to another.  Typical uses for truck-to-truck propane liquid transfers are where a smaller tank truck is attached to a barge for island deliveries and specialty off-road tank trucks used for remote deliveries in the oil patch and mine sites.  The other times would be in cases of emergencies such as when there is a power outage at the bulk plant or a tank truck or cargo liner tank needs evacuating due to an accident.

Regulatory Requirements

The actual loading, transportation, and unloading of cargo liners and tank trucks fall under the Transportation of Dangerous Goods Regulations (TDG).  The loading aspect falls under the task of “offering for transport”.  The TDG Regulations do not specifically address truck-to-truck liquid propane transfers but provide general requirements that must be met during the loading and unloading process regardless of where the transfer takes place.  Therefore, one must ensure that all of the requirements legislated under the TDG
Regulations are met.

The TDG regulations, through the adoption of the CSA B620 Highway Tank and Portable Tanks for the Transportation of Dangerous Goods standard stipulate that when loading or unloading a cargo liner or tank truck, you must, during the transfer process, use the fail-safe brake inter-lock system and chock blocks at the rear wheels of both units involved in the transfer to ensure that both units involved do not move.

The CSA B620 general requirements require that the following conditions must also be met prior to starting the transfer process:

  • Connections must be inspected to ensure the propane liquid will be transferred into the proper connection;
  • The space available in the receiving tank must be verified to ensure that it is sufficient to accommodate the quantity of liquid propane to be transferred;
  • When remotely opening the internal safety control valve (ISC) , you are to have an unobstructed view of the cargo liner tank, delivery hose, and tank truck being filled, to the maxi-mum extent practicable; and
  • The periodic inspection or test intervals for tanks involved in the transfer must be up to date.

During the transfer process:

  • The driver is responsible for the transfer and must have been trained in propane hazards and emergency procedures;
  • The driver is to remain alert, within easy access of the supply and receiving flow shutdown controls, and to the extent possible, with the hose and both tanks in clear view except for brief periods to operate controls or to check the receiving tank;
  • When equipped with an off-truck emergency shutdown system, the driver must be in possession of the control at all times the tank valve is open, within 150 ft. of the tank and 25 ft. of the hose;
  • The driver must control the quantity of propane liquid being transferred; and
  • Immediately after the liquid propane has been transferred, all valves on both the supply and receiving tank must be closed and secured.

Provincial Regulations

The 2010 CAN/CSA BI49.2 Propane Storage & Handling Code requires that when offering for transport or transporting propane that the requirements of the TDG regulations must be followed.

The 2015 edition of the CAN/CSA B149.2 Propane Storage & Handling Code, to be published in August of 2015, also speaks to this issue.  The code stipulates that the contents of a cargo tank or cargo liner may be transferred to the cargo tank on another tank truck or cargo liner in an emergency.

The transfer of propane from a cargo tank or cargo liner for any purpose other than an emergency shall only be per-formed when specifically approved by the authority having jurisdiction.

It should be noted that for the purposes of the above provision, emergency means a sudden, urgent, usually unex-pected occurrence or occasion such as a general power failure, plant mechanical failure, incident, or vehicle mechanical failure requiring immediate action to protect or reduce the hazard to public safety.

Currently, two provinces, British Columbia and Ontario, have issued specific enhanced requirements over and above the TDG requirements as to how truck-to-truck propane liquid transfers are to be carried out in their provinces.

Until such time that the 2015 Code is adopted in your province, you must follow the TDG requirements if your province has not issued additional requirements.

British Columbia

British Columbia - BCSAOn December 30, 2010, the BC Safety Authority issued Directive # D-G5 101230 1 which outlines the operating procedure that needs to be in place for the tank truck to tank truck transfer of liquid propane along with the required training of the personnel performing this procedure.

General Details:
Clause 8.13.3 of the CAN/CSA B149.2-05 allows the transfer of propane product from one tank truck to another tank truck. In order to perform this procedure, an Operating
Procedure accepted by the BCSA must be in place that describes in detail how, when, and where this activity will take place, along with the specific training of the personnel performing this procedure in accordance with accepted industry practice.

Tank truck – A truck chassis and tank assembly as a complete unit for the bulk delivery of propane.

Cargo Liner – A vehicle that is used to transfer propane in which the tank constitutes the main structural member and that is towed by a separate motor vehicle.  Note: For the purposes of this Directive, the terms “Tank Truck” and “Cargo Liner” are interchangeable.

Filling Plant (bulk plant) – A facility, the primary purpose of which is the distribution of propane.  Such plants have bulk storage and usually have container filling and vehicle transfer facilities on the premises.  Bulk plants are considered part of this category.

Specific Details:
The above described Operating Procedure must be developed and delivered to the Provincial Safety Manager – Gas for acceptance.  Although Clause 8.13.3 of the CAN/CSA B149.2-05 allows for the transfer of propane from one tank truck to another, this activity shall not be performed by any individual who is not following an accepted Operating Procedure.

The only exception is when a propane emergency exists and where it is decided this practice will reduce the risk of accident or severity of an incident.  In this case, a Remedial Measures Advisor from the Liquefied Petroleum Gas Emergency Response Corporation must be in attendance and permission from the Provincial Safety Manager or their designate must be received.

Guideline To Required Operating Procedure:
The following are intended as the minimum requirements:

Filling plants must meet the operating requirements described in section 28 of the Gas Safety. Regulation (GSR) and comply with the CAN/CSA B149.2-05.

Tank trucks or cargo liners must comply with all requirements as contained in the CAN/CSA B149.2-05.

Tank truck to tank truck transfer must be performed only by personnel trained in the Operating. Procedure, qualified as required by section 5.2.10f the CAN/CSA B149.2-05, and authorized in accordance with section 4(1)(d) of the GSR.

The facility complies with all Local Government requirements.

Required clearances and related clauses as stated in the CAN/CSA B 149 .2-05 are adhered to during the transfer process:

  • The aggregate amount of propane contained in any offloading tank truck and the approved stationary tank(s) shall not exceed the maximum storage capacity of the stationary tank(s).
  • A designated filling plant (bulk plant) used to transfer propane from one tank truck to another tank truck shall be approved by the Local and Provincial authorities having jurisdiction.


Ontario - TSSA Logo 01The Ontario Code Adoption Document FS-211-14, which became effective on Oct. 1, 2014, states that:

The contents of a tank on a tank truck or a cargo liner shall not be transferred to the cargo tank on another tank truck or cargo liner unless the operation is carried out at a filling plant.

Except for an emergency such as a loss of power due to unexpected natural weather, the transfer of propane from a cargo tank to another tank truck or cargo liner at the filling plant shall be approved.

TSSA will consider the following before granting an approval to transfer propane from a cargo tank to another tank truck or cargo liner at a filling plant:

  • The filling plant shall hold a valid license.
  • The filling plant shall have a permanent licensed storage capacity of at least the largest tank truck, or the amount of the truck to truck transfer shall be specifically approved by TSSA.
  • The transfer shall be performed by a Propane Truck Operator (PTO) certificate holder.
  • The risks associated with the operation, including mitigation measures and emergency procedures in place.
  • Sufficient space to accommodate both tank trucks without blocking any emergency exits shall be maintained; and
  • All requirements and minimum clearances of CSA B149.2-10, including emergency shutoff valves shall be complied with.

Protective Clothing

In closing, remember you are handling liquid propane that can cause serious freezer burns and injury if the liquid comes into contact with your skin. You must, therefore, wear the proper protective clothing and gloves when connecting and disconnecting propane hoses during truck-to-truck transfers.

Neoprene_Gloves_Orange Safety Goggles

Training Available

To address your training needs, the Fuels Learning Centre’s “Loading & Unloading Propane Cargo Liners (TO01)” and “Loading and Unloading Propane Tank Trucks (TO02)” courses include the latest requirements for truck to truck liquid propane transfers by providing the specific TOG and provincial requirements.

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