Manitoba Inspection and Technical Services (MITS) recently issued Gas Equipment Bulletin ITS 22-002, which affects the propane industry and the requirements respecting the responsibilities for installing propane tanks with a capacity of more than 10,000 USWG (L) total aggregate water capacity.
The CPA has identified several concerns associated with this bulletin.
First, the province’s intent was to provide clarification to the gas industry on the requirements to provide a risk and safety management plan (RSMP). The CPA, in concert with Manitoba members, have identified that this clarification is in fact, a new requirement and not something that was previously required before any installation.
The new requirement states that the RSMP must be prepared by qualified personnel, and include all four primary elements: hazard analysis, risk assessment, risk mitigation and control, and emergency response and preparedness of the CSA B149.2 Propane storage and handling code. The bulletin stated the RSMP shall be submitted to the Inspection and Technical Services Gas and Oil Inspection Program Manager for review and approval prior to starting any installation.
Secondly, the bulletin claims that an RSMP is a requirement of the CSA B149.2 code, when in fact annex L entitled Risk and Safety Management Plans clearly indicates “this annex is not a mandatory part of this code”.
Lastly, the CPA is seeking clarification from Manitoba on the meaning of “total aggregate water capacity”, as the bulletin does not describe whether the aggregate capacity means “of a tank on site”, or “all tanks located on site”.
The CPA has requested a meeting with MITS to discuss these concerns. For more information, please contact CPA’s Senior VP of Regulatory Affairs and Safety Robert Loenhart.