Transfer of Propane Requirements Not Consistently Applied in Canada

It is the CPA’s view that safety requirements should be consistently applied to different types of transfers, which is not currently the case between Federal and Provincial facilities.  Provincially regulated facilities require extensive approvals and regular inspections.  Federally regulated facilities do not require the same level of safety.  For example, the following are key requirements that are contained in the CSA B149.2 – Propane storage and handling code but not in the Transportation of Dangerous Goods Regulations:

• Defined setbacks and clearances
• Electrical equipment classification
• Specific safety protection on transfer systems (e.g., shear point)
• Fencing and barrier protection (e.g., posts, guardrails, barriers)

A recommendation was made to and rejected by Transport Canada as it was deemed outside of their jurisdiction.  Given the CSA B149.2 Technical Committee and the Interprovincial Gas Advisory Council also deemed they did not have jurisdiction, the question of who has jurisdiction needs to be answered and then the requirements harmonized.

The CPA forwarded two letters on this matter, as well as a document providing a detailed comparison of the requirements in the CSA B149.2 Code versus the requirements in the Transportation of Dangerous Goods Regulations, to Transport Canada.

The CPA is preparing a letter to be sent to the chair of the National Public Safety Advisory Committee and will follow up with a strategy, if required, to ensure appropriate measures are adopted for the safe transfer of propane from rail to truck on federal facilities.