The TSSA circulated a draft Advisory – Training Requirements for Refueling Propane Powered Vehicles for the Fuels Industry Certificates Regulation (O. Reg.215/01, amended July 2019) to Risk Reduction Group (RRG) members for comment on October 9, 2019. The Advisory outlines prescriptive requirements for training to fuel propane-powered vehicles, contrary to clause 55 (6) of the recently amended Regulation:
(6) A person is exempt from the requirement in subsection 3 (1) to hold a PPO-1 certificate, PPO-2 certificate, PPO-3 certificate or record of training for the activity of refuelling a propane powered vehicle at a cardlock/keylock facility or a facility that is a private outlet if,
(a) the authorization holder for the facility provides training to the person at least once annually;
(b) the training provided to the person is appropriate for the dispensing equipment and receiving equipment of the vehicle; and
(c) the authorization holder for the facility maintains a record of the training provided to the person. O. Reg. 195/19, s. 3.
The CPA believes this Advisory is unnecessary and negates the revised regulations for the Fuels Industry Certificates Regulation, which exempts personnel at propane cardlock/keylock facilities from holding a Propane Plant Operator certificate or maintaining a record of training to fuel a propane-powered vehicle. The CPA discussed its concerns with TSSA staff and submitted a written response to the regulator on November 5 to advocate against the prescriptive requirements.
The CPA will continue to advocate with the TSSA on the Advisory to ensure that prescriptive training requirements are not added.
For any questions, please contact Marcelline Riddell at 647-881-1483 or by email at MarcellineRiddell@propane.ca.