ECCC has provide the following clarifications:
- ECCC has clarified reporting and E2 plan threshold requirements. If your total quantity onsite is above 4.5 tonnes then you must report the volumes to ECCC using Schedule 2, even if the container systems are remotely segregated. If your largest container system is above 4.5 tonnes, then you must prepare an E2 plan.
- The definition of the container system specifies any receptacle or network of receptacles that is used to contain a substance—including any connecting pipelines or piping—except any part of that network that is automatically or remotely segregated from the rest of the network by shut-off valves, or other mechanisms, in the event of an environmental emergency. ECCC has clarified that segregation must not be through manual valves, however, they have not specified a valve or technology required.
- Public notification is required for members of the public that may be affected by the emergency. This could include, but not limited to, community associations, public safety authorities (i.e., firefighters and police) and local residents.
The CPA is planning a meeting with ECCC to discuss the regulatory burden this regulation causes for the propane industry. If you have any questions or concerns, please contact Rebecca Keeler at
rebeccakeeler@propane.ca or 613.799.0935.