By Bill Egbert
As the propane industry begins the 2017-2018 construction heating season, I realized it has been quite some time since we discussed the requirements related to using propane at construction sites in this column. The 2015 versions of both the CSA B149.1 Natural Gas & Propane Installation Code and CSA B149.2 Propane Storage & Handling Code are now fully in force, and with these versions, there are updated requirements – particularly in how propane cylinders are to be stored and used on the construction site.
Installation and Maintenance Requirements
Section 7.18 of the CSA B149.1 Natural Gas & Propane Installation Code addresses the installation and maintenance requirements for construction heaters and torches. The use of propane cylinders at construction sites is covered in Section 6.35.3 of the CSA B149.2 Propane Storage & Handling Code while the installation of larger systems utilizing ASME propane storage tanks must meet the requirements outlined in Section 7 of the code entitled “Tank systems, filling plants, and refill centres.” Don’t forget that mobile ASME propane storage tanks used at construction sites are subject to Transportation of Dangerous Goods regulations in terms of placarding, training and documentation.
Most jurisdictions require a permit for the installation of construction heaters and all jurisdictions stipulate the maintenance of construction heaters and its components be completed by a qualified installer. In British Columbia, Technical Safety BC also requires a valid temporary heater decal, valid for two years, to be applied by a gas fitter certifying its safety and operation.
Several regulatory authorities have issued Bulletins and Directives specific to construction heater use in their jurisdiction. I would recommend you visit your provincial authority’s website and download copies of these documents. They are also available from the Fuels Learning Centre’s Knowledge Base for your convenience. I have found the STANDATA Gas Safety Information Bulletin G-08-01-B149.1/B149.2 [Rev 2] issued by Alberta Municipal affairs provides a great summary of the regulatory requirements and encourage you to access a copy (also available on our website).
Propane Vaporizer Emergency Shutdown Systems
The 2015 version of the CSA B149.2 Propane Storage & Handling Code specifies that an emergency shutdown system shall be installed in any tank system supplying propane to a direct-fired vaporizer and that the shutoff system shall be located at least 25 feet from both vaporizer and tank(s). Due to the limited space on construction sites, it is not always possible to be in compliance with this requirement. The national CSA B149 Code Committee is already planning an amendment to the clause to address concerns at construction sites. In the meantime, several jurisdictions, including British Columbia, Alberta, and Saskatchewan have already issued variances which requires the 25-foot distance requirement to apply to only the vaporizer.
Use, Movement, and Storage of Propane Cylinders at Construction Site
The requirements for how propane cylinders are used, moved, and stored at the construction site were subject to several changes with the adoption of the 2015 version of the CSA B149.2 Propane Storage & Handling Code. The following are some of the primary amendments found within the 2015 version of the code:
• A cylinder properly connected for use in an approved manner in not considered “in storage,” although a cylinder not connected for use must be stored.
• The requirements for outdoor storage of propane cylinders have been modified to reflect the conditions on the construction site based on the hazards (gas accumulation, vehicular traffic, hoisting, clearances) rather than focusing on the location alone.
• Propane cylinders in storage at construction sites must be stored in an area that:
– provides protection from tampering;
– is free from vehicular or mobile equipment travel, or protected by barriers or the equivalent;
– has “NO SMOKING” signs which are prominently displayed;
– meets the cylinder storage clearance requirements specified in Table 6.3;
– be placed such that the relief valve on any cylinder is not less than 3 ft. (1m) horizontally from any building opening that is below the level of the relief valve discharge or not less than 10 ft. (3 m) on the horizontal plane from the air intake of any appliance or air-moving equipment.
• Moving a propane cylinder from one level to another level or the roof of a building may be done using a freight/service elevator or construction hoist. If moved in a public passenger elevator or escalator, only the person(s) involved with the cylinder shall be in the elevator or on the escalator. When moving a propane cylinder to or from the roof or one level to another of a building, each cylinder valve outlet shall be closed, plugged, and the valve protective cap or collar in place.
• A new clause permits propane cylinders to be stored on roofs and states that cylinders on building rooftops shall comply with the following:
– A propane cylinder shall not be on the roof of a building unless the cylinder is to be connected for work undertaken on the roof during the current or the immediately following work shift;
– The cylinder(s) weight shall not exceed the net load capacity of the roofing structure as specified by the building owner or management;
– The storage area shall be at least 10 ft. (3m) from the building edge or a change in elevation of more than 3 feet (1m);
– Cylinders shall be secured to maintain the cylinder in its proper storage position during inclement weather;
– All cylinders shall be removed upon completion of the work; and
– No more than 1,000 lb. (450 kg) of propane in total capacity shall be stored on the roof.
Training Requirements for Construction Heater Users
The requirement for users of construction heaters to be trained has been included in the CSA B149.1 Natural Gas & Propane Installation Code for many years and did not change with the 2015 version of the code. In most cases, construction heaters are provided by rental agencies, which is why the wording in the B149.1 focuses on “lessor” and “lessee.” Ultimately, it is the responsibility of the lessor of the construction heater to ensure the lessee is instructed in the safe installation and use of the construction heater and components. Additionally, it is the responsibility of the user of a construction heater to ensure they have been instructed in the handling and operation of the heater.
Training courses for the use of construction heaters must be approved by the authority having jurisdiction and must include the new requirements related to the use and storage of propane cylinders at the construction site. In 2016, the Technical Standards and Safety Authority issued detailed requirements for what is to be included in construction heater and torch training courses. While specific to Ontario, the prescribed content forms a great template for training courses used across Canada. Ask your Training Provider if the required content has been addressed in their course curriculum.
Also in Ontario, regulations specify that the Record of Training (ROT) certificate must display the ROT category code the training addresses (CH-02 for training on construction heaters with inputs of up to 400,000 BTUH or CH-01 for construction heaters of any input).
Based on recent conversations I have been having with industry and regulatory personnel, you should expect increased enforcement activity this season in all jurisdictions to ensure users of construction heaters
For the past 18 years, Bill Egbert has provided the propane industry with state-of-the art training programs and services. Bill is passionate about ensuring training programs reflect ever-changing national and provincial regulatory requirements and communicating those requirements to industry. If you have any questions, please contact Bill at bill.egbert@fuelslc.com.
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