The Technical Standards and Safety Authority (TSSA) is asking propane fuel suppliers to inspect and advise customers that non-compliance with unvented propane barn heaters in some Ontario agricultural facilities will lead to a termination of fuel supply. While the CPA and its members are at the forefront of promoting safe practices in the handling of propane, the Association believes that asking propane suppliers to threaten to refuse vital propane heating fuel to Ontario farmers as leverage to enforce these safety measures goes too far.
The CPA believes that propane suppliers should not be responsible or required by this TSSA advisory to enforce these “compliance measures”. To communicate industry concerns effectively, the CPA is seeking members’ input on the impact and implications of this requirement on their business practices. Please send your response to Marcelline Riddell marcellineriddell@propane.ca by June 3, 2019. After discussing with members, the CPA will send a letter to the TSSA indicating a position.
BACKGROUND: In 2018, the TSSA’s Risk Reduction Group (RRG) discussed the issue of barn ventilation with unvented propane barn heaters in some Ontario agricultural facilities. To ensure compliance with the requirements outlined below, the TSSA is asking propane fuel suppliers to advise customers that non-compliance with these requirements will lead to a termination of fuel supply.
Livestock ventilation systems with propane and natural gas appliances must meet Natural Gas and Propane Installation Code CSA-B149.1. The most recent amendment to the Gaseous Fuels Code Adoption Document became effective July 2017. This regulation has been revised as of July 2017 and producers must ensure that their barns have the required verification posted.
Specifically, code requirements are:
7.37 Unvented heaters installed inside a building housing livestock or poultry
7.37.1 Unvented heaters installed inside a building housing livestock or poultry shall comply with the following requirements:
a) infrared heaters of unvented type interlocked with ventilation system shall comply with clause 7.23.1;
b) portable infrared heaters not interlocked with ventilation system shall comply with clause 7.23.2;
c) infrared or other heaters of unvented type not interlocked with ventilation system shall comply with clause 7.37.2;
d) infrared or other heaters of vented type discharging flue gases inside the barn shall comply with clause 8.24.5.
7.37.2 Heaters of unvented type not interlocked with ventilation system shall be:
a) exempt from clauses 7.23.1, 7.23.2 and 8.24.5;
b) protected against physical damage;
c) provided with mechanical or natural ventilation when the heaters are operating at a volume sufficient to maintain a minimum of 300cfm/100,000Btuh;
d) located in a space where the maximum input of the appliances does not exceed 20 Btuh/ft3 (0.2 kW/m3) of the space in which the appliance is located;
e) provided with combustion and ventilation air compatible with item (c);
f) not be installed in a pedestrian exit passageway or stairway within 8 ft (2.5 m) measured horizontally from an exit door; and
g) provided with clearance from combustible material as certified and indicated on the appliance;
h) Items (c) and (d) shall be verified by calculations, completed by a PEO licence holder, and the calculations prominently displayed in the entrance area to each building housing livestock or poultry.
7.37.3 On moveable heaters, hoses used to connect the heaters to the fuel supply shall be installed so that the hose does not come into contact with the heater’s exterior surfaces.
7.37.4 Heaters installed prior to October 1, 2014 shall comply with section 7.37 as follows:
(a) by July 1, 2019 when total building area housing livestock or poultry on the premise is over 25,000 square feet;
(b) by July 1, 2021 when total building area housing livestock or poultry on the premise is up to and including 25,000 square feet;
(c) Heaters installed prior to October 1, 2014 are not required to comply with clauses 7.23.1, 7.23.2 and 8.24.5 and their predecessor clauses in prior codes relating to interlocking with the ventilation system or approval for indoor venting.