By Bill Egbert, President,
Fuels Training and Consulting Inc.
Technical Safety BC
Last fall, the British Columbia Safety Authority announced it would be changing its operating name and identity to Technical Safety BC. According to their news release, the identity change comes following extensive consultation with clients and industry stakeholders. It reflects the move toward becoming a knowledge and data-driven organization that uses smart systems and processes, predictive analytics, education, and knowledge sharing to operate more efficiently, prevent incidents, and enhance safety. Technical Safety BC also launched a new and updated website. I spend a lot of time reviewing regulatory websites to watch for updates affecting the industry. I must say that Technical Safety BC’s new website is one of the easiest and logical regulatory websites I have encountered – congratulations!
Propane Facility Operations and Maintenance Procedures
As you may recall from previous articles in this column, the 2015 version of the CAN/CSA B149.2 Propane Storage and Handling Code included new requirements for the establishment of operation and maintenance procedures of propane facilities within Clause 7.22. The purpose of the new clause in the Code is to provide a minimum standard for the operation and maintenance of propane facilities and equipment. Because there are many variables, it is not possible for the Code to prescribe a set of operation and maintenance procedures that will be adequate from the standpoint of safety in all cases without being burdensome and, in some cases, impractical. Therefore, the clauses establish a baseline or minimum standard of care.
The Clause also places the responsibility to develop and implement procedures on the owner of the facility and to provide the appropriate training for those staff members who will be operating and maintaining the plant facilities.
In October 2017, Technical Safety BC issued a directive which clarifies the policies for the development and documentation of operating procedures for day-to-day operation, emergency procedures, and maintenance procedures of propane facilities operating in British Columbia – the first provincial authority to do so.
The directive also clarifies that operation and maintenance procedures apply to all facilities required to hold an operating permit as identified in the Provincial Gas Safety Regulations and includes:
• Container refill centres;
• Dispenser systems;
• Filling (bulk) plants;
• Tank heaters;
• Tank systems; and
• Vapourizers.
Detailed Manual Provided
With the directive, Technical Safety BC also issued a detailed manual which provides guidance for the development, documentation and implementation of operations and maintenance procedures. The manual assists owners and operators to establish procedures relevant to the size and complexity of their facility. The manual, prepared by Brad Wyatt, provincial safety manager – Gas, is an excellent tool providing clarity and definition. The manual contains several sample procedures as well as detailed definitions of the requirements.
Even if you operate outside of British Columbia, I would highly recommend you download and utilize the manual from Technical Safety BC’s website. While British Columbia may be the first jurisdiction to provide this level of detail, it’s important to remember that the requirements of Clause 7.22 of the CAN/CSA B149.2 Propane Storage and Handling Code are in force in all jurisdictions across Canada.
Training Requirements
The directive reinforced the training requirements of both the B149.2 and provincial regulations. Individuals conducting operating and maintenance procedures must be properly trained. Within the detailed manual, the operations and management program must include a process for developing competency requirements and enabling the training of employees and contractors responsible for the operation, inspection, maintenance, and repair of the facility.
Authorities Having Jurisdiction are becoming increasingly focused on ensuring employees and contractors are properly trained to operate and maintain propane facilities. This includes the transport vehicles hauling propane to and from propane plants which additionally fall within Transport Canada jurisdiction. I am still shocked to hear from some operators that they only focus training efforts in jurisdictions which are most likely to check for training records since it is cheaper to pay non-compliance fines than pay for training. With new additional training requirements outlined in clause 7.22 of the CAN/CSA B149.2 Propane Storage and Handling Code, it is going to be more problematic for organizations to claim that an individual “slipped through the cracks” in terms of training if the company does not have written policies and procedures that include how employees and contractors are to be trained and carry valid records of training.
Nova Scotia Recognizes Cylinder Truck Delivery Operations Training
Until October 2017, cylinder truck drivers had to write a provincial Fuel Safety exam in order to qualify for a Class C Operator’s License in Nova Scotia. In October 2017, Paul Fowler, chief fuel safety inspector, issued a Fuel Safety Bulletin removing the requirement to write the exam so long as the operator could provide proof of successful completion of an approved training course with their license application. Currently, the only approved training course for this class of gas operator is Fuels Learning Centre’s Cylinder Delivery Truck Operations course (TO03). Similar efforts are underway in other Atlantic Canadian provinces to recognize this training.
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