Tag Archives: Training Requirements

PRV Change Out Challenges

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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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Impacts of Regulatory Changes for Construction Heater Lessors

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

Introduction

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

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

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

Training Requirements

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

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

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

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

Ontario Adopts Portions of 2015 Code

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

Once the Codes and Standards are adopted there will be an immediate training need for persons who perform work that is regulated by these documents.  In Ontario, this was October 1, 2014, which means training programs must reflect the latest regulatory requirements as of October 1, 2014, for Ontario and in other provinces later in 2015. Construction heater lessors should ensure their training providers have updated their programs to reflect the new requirements. The Fuels Learning Centre currently offers three programs related to the safe installation and operation of construction heaters and torches reflecting all the new regulatory requirements.

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

New Definitions and Clauses

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

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

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

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

Use of OPDs

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

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

Cylinder Requalification

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

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

Single-trip Type Propane Cylinders

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

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

Addition to Scope

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

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

Increase in Cylinder Size at Exchange Locations

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

Cylinder Storage Cages

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

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

Storage of Cylinders & Sources of Ignition

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

Cylinders Stored at Construction Sites

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

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

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

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

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

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

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

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

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

Movement of Propane Cylinders

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

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

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

Storage of Propane Cylinders on Roofs

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

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

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

These amendments provide the following benefits.

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

 

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Keeping Regulatory Training Current

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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 - TSSA Logo 01Ontario 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:

  1. Permitting press-connect fittings;
  2. Re-classifying clothes dryers in accordance with the certification standard;
  3. Adding a new section regulating unvented heaters installed in livestock or poultry facilities;
  4. 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
  5. 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:

  1. New definitions added for “construction site” and “cylinder exchange”;
  2. New requirements for cylinder storage, including storage at construction sites and rooftops;
  3. New requirements for cylinder exchanges;
  4. 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
  5. 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.

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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.

Fuels Learning Centre

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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Standard of Care

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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.

Compliance

Introduction to Standard of Care

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

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

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

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

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

 

Standard of Care – What Does it Mean?

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

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

Best Practice - LowRes - shutterstock_310757321Standard of care is often referred to as “industry standard of practice”, “best practices”, or “code of practice.”  Whatever name is used, they essentially have the same meaning and outcome – to have a program in place that provides a vehicle for the company to meet or exceed the regulatory regime under which it must operate and to monitor the level of compliance on an ongoing base.  The standard of care program provides the knowledge, policies, and procedures required by company personnel to meet everyday compliance requirements in the execution of their duties.

 

Benefits of Implementing a Standard of Care Program

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

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

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

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

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

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

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

Do It Right the First Time 02

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

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

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

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

 

Basic Standard of Care Program

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

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

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

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

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

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

Checked - LowRes - shutterstock_242884063It is, therefore, critical to the entire process that a monitoring program is put in place to continually provide feedback, identify problem areas and determine the compliance level the company is meeting.  It is a complete waste of time developing and implementing a Standard of Care Program without a monitoring component being put into place.

 

Development of a Standard of Care Program

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

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

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

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

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Fire Prevention and Fire Control at Propane Bulk Plants

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Fire prevention and control is key to minimizing risk at the bulk propane storage plant.  This article, which first appeared in the Nov/Dec 2012 edition of Propane Canada magazine discusses the various aspects of fire control and prevention that should be considered.

A client recently asked me, as part of their internal due diligence, to verify that appropriate fire prevention and fire controls were in place and operational at one of their propane bulk plants.  The audit looked at the physical aspects of fire prevention and control as well as related policies and procedures.  The following discusses the items that were addressed in the audit.

Site Security

Site security is the main factor in preventing unauthorized persons from entering the actual propane bulk tank storage yard.  Unauthorized persons may unwittingly provide a source of ignition by either smoking or in the type of clothing they wear.  Nylon outer clothing, shirts, jacket or pants can build up static electricity which can arc with sufficient energy to ignite propane vapours.

The yard must have a controlled entry point.  Gates are used to provide the controlled entry point and fencing around the perimeter of the yard provides the security.  Signage at the entrance to the fenced yard warns unauthorized persons not to enter.  Gates to the propane bulk tank storage yard must be closed and locked when the plant is not in use.

visitors-must-sign-log-sign-s-6763A visitors log is a good way to record who and when a non-employee enters the yards.  Do not let visitors enter the yard unless escorted by an employee at all times. The escorting of non-employees ensures that the visitor does not inadvertently wander into yard traffic areas or propane transfer areas without the benefits of the proper clothing and that the visitor can be led to the evacuation meeting place should an emergency occur.  These rules should apply to the general public as well as municipal, provincial or federal employees attending the facility as part of their work.

It is also important to control the vehicles entering the fenced yard.  Only allow essential vehicles to enter the fenced yard.  Do not permit customer vehicles or employee vehicles to enter or park in the yard area.  Provide parking spaces for customers and employees outside the fenced yard.  Bulk trucks and cargo liners which are stationed out of the facility must, when parked, be within the fenced yard area.

Tank Protection

To prevent the release of propane from a damaged propane container or piping system, propane bulk storage tanks, as well as transient tanks and cylinders, must be protected from physical damage by either their location or barriers such as concrete filled posts, steel guard rails, and post or New Jersey concrete turnpike barriers.

Signage

No smoking signs, turn off ignition signs, and UN1075 placards, as well as the company name and logo, stenciled on the propane bulk storage tanks, bulk trucks and cargo liners can act as a constant warning as to the product stored and transferred at the plant.

Dispenser Warning Signs 01 - Original

Training

A key component of fire prevention is training.  Trained and certified personnel must only be allowed to drive bulk trucks/cargo liners, load and unload and to operate the facility.  Ensure that employees have the correct training and level of certification before allowing them to perform any functions within the plant.

Clothing

It is essential that persons working within the propane bulk storage yard wear the appropriate clothing.  Clothing can be cotton or blends of material as long as it does not build up a static electric charge.

Control of Ignition Sources

When looking at controlling ignition sources one must consider the installation of the bulk storage tanks, ongoing maintenance of the grounds and components, leak control and propane released during the transfer process.  Ignition sources are controlled within a propane bulk plant by incorporating employee training, wearing appropriate clothing, and by:

  1. Ensuring that distances listed in the Code are initially provided and maintained from tanks and points of transfer, property lines and buildings.
  2. Ensuring the area around and under the bulk storage tanks gravel or asphalt are free of vegetation or material storage.
  3. Having all electrical components rated explosion proof Class 1, Group D.
  4. Using hose end valves at unloading and loading bulkheads which are designed for limited liquid propane release on disconnect.
  5. Equipping Liquid and vapour openings in all tanks with Internal Safety Control Valves (ISC) that are closed when the plant is not in operation.
  6. Unloading of cargo liners and loading of bulk trucks is through bulkheads equipped with Emergency Shut-off Valves and back check valves.
  7. Having a grounding system in place at all unloading and loading bulkheads to prevent the buildup of static electricity.
  8. Using CSA certified hose assemblies used to transfer propane in and out of the plant which are inspected and tested annually in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.
  9. Permitting only cargo liner tanks and bulk truck tanks which are built, inspected and tested in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.

Fire Control

Fire control relies on the physical plant design, components, and internal and external resources. The following is a list of items that one would expect to be in place to control a fire within a propane plant.

  • Nitrogen or air activated valves with emergency shutdown stations located around the plant. As a minimum, shut down stations would be at each loading and unloading bulkhead and a safe area outside of the fenced yard.
  • Air actuated Internal Safety Control Valves (ISC) and Emergency Shut-off Valves (ESV) which close on loss of nitrogen or air pressure. Nitrogen or air pressure is supplied by plastic tubing that melts if exposed to temperatures generated by fire or radiant heat causing a loss of air pressure within the system resulting in the automatic closure of all ISC and ESV valves.
  • Plants equipped with cable operators which have fusible links that melt if exposed to temperatures generated by fire or radiant heat causing the cable to separate which allows the ISC or ESV to close
  • Hand-held fire extinguishers must be placed strategically around the facility to help control possible fire situations. Fire extinguishers must also be inspected and tagged annually by a company that specializes in maintaining fire extinguishers. Part of the monthly plant inspection must provide for fire extinguisher inspection to ensure the fire extinguisher is actually in place and properly charged.
  • Since the local fire department (which may be a volunteer force) responds to calls at the facility, it is important to meet with the fire services and obtain a listing of the equipment that can be used to respond to a fire at your facility. This is also an opportune time to have the fire services visit the site.
  • Sufficient space maintained in the yard to maneuver fire trucks for position to fight fires.
  • Provincial or local fire services may also request additional fire suppression systems to be installed with a dedicated water supply to cool tanks and provide protection for emergency response personnel.
  • It is a prudent exercise to look at the fire prevention and fire control systems and processes at your propane bulk storage plant on an annual basis to ensure that the correct policies and procedures are in place, all components are maintained and operate as required and that employees know what to do in the case of an incident.

emergency-response-plan_emergency-plan-highlighter

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Third-Party Contractors

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Many propane retailers rely on third-party contractors to conduct work on their behalf. This article, which first appeared in the May/Jun 2012 of Propane Canada Magazine, discusses what you can do to minimize risk and liability arising from the actions of your third-party contractors.

In previous articles I have written about policies and procedures, preparing for emergencies, installer responsibilities, and installing approved appliances and equipment. In this third article for 2012, I will continue the due diligence theme of how a company can meet its regulatory obligations while using independent third party contractors and possibly avoid being caught up in litigation due to an incident.

Many fuel distributors use third-party persons (independent contractors) to deliver propane or fuel oil to their bulk plants, deliver cylinders to cylinder exchange cages, and install propane and fuel oil appliances and equipment.  The question I am asked is “As a fuel distributor what are my regulatory obligations with respect to using third-parties to perform services on behalf of my company?”  While you can have contractual arrangements which define the business relationship it is important to understand that when it comes to third parties conducting operations on your property and doing installations on your behalf, you also have obligations to ensure that the technical work is being done in accordance with the Acts, Regulations, and Codes.

Certification

shutterstock_392416306Provincial regulations require that persons operating cargo liners and installing fuel oil and propane appliances and equipment must be certified to perform those functions. The certification can be a provincially issued certificate or a Record of Training (ROT) recognized by the Authority Having Jurisdiction such as the Fuels Learning Centre.  Your due diligence as a fuel distributor is to ensure that all third parties performing work for you are certified for the work to be performed.

This means that you should have a copy of each person’s certificate or ROT on file so you can verify that they are certified and that the certification is for the degree of work for which you are retaining their services. The verification of certification will be an ongoing request as certificates and ROTs have expiry dates and the file must contain the currently valid certificate or ROT.

Licensed Contractor

For third-party contractors doing fuel oil and propane appliance and equipment installation, the next file should include any provincially required registered contractor licenses indicating the contractor is licensed to act as a contractor in your province. Again, contractor licenses have an expiry date and the file must be kept up to date with the current license.

Operations on your site by third-party contractors

Cargo liners and tank trucks delivering fuel oil or propane must be constructed and maintained in accordance with Transportation of Dangerous Goods Regulations (TDG). Some provinces conduct separate inspections and actually issue a license to transport. The TDG regulations require that propane cargo liner tanks undergo an annual leakage test and a 5-year inspection. If you receive fuel oil or propane from a third-party, independent contractor then as part of your due diligence process you should be asking for copies of inspection certificates for the cargo liners and tank trucks that deliver fuel to your site. Retain the inspection certificates in a file. This will also be an ongoing process as the file should contain the most current inspections.  It is not in your company’s best interest to allow equipment on your bulk plant site that is not well maintained and or does not meet current regulatory requirements.  Failure to ensure this opens the door to potentially being implicated in an incident that may not be your fault.

If you lease a portion of your bulk plant property for other third-party activity such as cargo liner parking, installation contractor or cylinder exchange storage, past experience has shown that it is best to physically separate the third party from your bulk plant activity. Ensure that the third party is independently licensed to operate, not connected to your license to operate a bulk plant. It is important that you have an understanding of the activities conducted by third parties on your property.

With respect to cargo liner and tank truck parking, and cylinder storage, arrange with your tenant to walk around on a regular basis to make sure what you have agreed to is actually occurring and to take care of any potential issues such as quantities stored, storage configuration, fire service access etc.  Also, the third-party staff working at your site should be included in your emergency evacuation plan. Keep a file of your visits and any activity conducted as a result of those visits.

Audits

warranty-iconSome provincial jurisdictions perform appliance and equipment installation contractor audits to ensure the contractor is certified and is doing the work in accordance with the Act, regulations, and codes. However, a reasonable due diligence process on your part is to conduct and document your own audits on work performed by independent contractors working on behalf of your company.

The audit process does not have to be onerous in nature in that you can audit a small percentage of the installations. If you find issues of non-compliance then you may have to increase the number of audits to provide a comfort factor that the installations are being done correctly. Use the inspection forms you would normally use for supplying propane to a new customer as your audit guide. Retain a copy of the documented audit in your independent contractor audit file. I find if you keep these files separate from the customer file it is much easier to locate the audit documents if an issue arises.

Company Policies and Procedures

When a third party contractor is performing work on behalf of your company, it is critical they follow your company’s policies & procedures. This ensures that the contractor and you are both working from the same set of guidelines and that regardless of whether it is your direct employee or an independent contractor the interaction with your customer and the work performed is consistent and meets your company’s standard of care. Again, as part of your due diligence process, provide a copy of the company’s policies and procedures manual to the contractor and obtain a signature from each individual working for the contractor stating that they have read the manual and agree to abide by the manual’s requirements.

Policy and Procedures 01 - LowRes - shutterstock_310886999

Training

Responsibility 01 - LowRes - shutterstock_293155331A certificate or ROT indicates that a person has reached a certain skill level. There are jobs which require immediate additional training for the person to complete the task safely and efficiently.  For example, once a cargo liner driver receives a ROT to indicate they have taken the training and successfully passed the examination to operate a cargo liner there is a need for site specific training prior to that person making a delivery to the site.

Third party cargo liner deliveries can occur outside of regular business hours where the driver is the only person at the site. Therefore, it is imperative that the driver not only fully understand how to safely unload at the plant, but what emergency response procedures are to be carried out by the driver if an incident occurs. This type of training should also be documented and retained on file.

Another type of training beyond the certificate or ROT is specific manufacturer’s training. If your company is involved in manufacturer training, offer the training to your third-party contractor as well. Document and retain all training activities.

Conclusion

In conclusion when working with third-party contractors make sure the company is registered to conduct the business, the employees are certified and have received any additional training to perform the tasks for which they have been retained, provide your company’s policies & procedures, perform some type of audit to ensure that the work is being performed in accordance with the Act, regulations, and codes and, finally, ensure you properly document the terms and qualifications of your third-party contractors.

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