UPDATE – ON: CPA restates industry's objections to TSSA initiatives

The CPA met with Technical Safety Standards Association (TSSA) executives on January 12, 2022, to restate the industry’s ongoing objection to several Authority initiatives that have resulted in increased costs and undue burden for Ontario propane operators. 

1. TSSA Fees: The CPA once again stressed that member analyses of the new fee regime imposed on May 1, 2021, costs the sector over 30 per cent more in TSSA payments and considerably more for some facility configurations. While the TSSA proposed to mitigate the impact for some of these categories for 2022 in their fall presentation to the Propane Advisory Council, the cost increases remain unjustifiably high as the CPA outlined in their November 30, 2021, response. The CPA is considering a variety of strategic options and avenues to have these fees reduced substantively in 2022. 
   
   
2. Underground Tank Application Process and Costs: The TSSA has reviewed the CPA’s letter of November 19, 2021, in which Ontario Director of Government Relations, Marcelline Riddell, wrote to the TSSA’s Statutory Director of Fuels, Sam Sadeghi, outlining industry concerns regarding the authority’s application process and fees for underground tank installations in the province.
   The Authority Having Jurisdiction for these installations moved from the manufacturer’s instruction to the TSSA and became effective February 8, 2021. 
   
   The letter stressed that since the TSSA added this Ontario-specific provision (section 1.16 – clause 7.8.1) to the Code Adoption Document amendments for Propane Storage and Handling, propane businesses wishing to install underground tanks for clients have been subject to an uncertain, costly and unnecessary application and approvals process: an average total cost of $1,200 per site. 
   
   It also highlighted the disparity these charges represent compared to other provinces, particularly Quebec, making it even more expensive to do business in Ontario, than elsewhere in the country. TSSA requested more information on Quebec’s processes and costs as part of their review. The documents were forwarded immediately thereafter, and Riddell will follow up directly with TSSA on remedies later this month, and report back to members. 
   
   
3. 10-year inspection requirement extensions: The CPA requested consideration of further extensions for 10-year inspection requirements to accommodate ongoing COVID-19 operating restrictions and address current service backlogs. The TSSA indicated the current timeline of December 31, 2022, will remain in place for the present, but did not rule out additional accommodation should the emergency management period continue. 

Members are asked to contact Riddell at marcellineriddell@propane.ca with any new information with respect to the need for more time in this regard.