Compliance and safety news for the propane industry


May 2024 

Filling tanks on RVs safely

RVs and propane go together like campfires and smores. However, ensuring safety during RV refuelling is crucial to avoid fire hazards. 

As we enter RV season, it’s important to be aware that these vehicles often carry multiple sources of hidden ignition, including appliances like fridges, furnaces, water heaters, and generators that may be operational upon arrival at the refuelling location. 

Take the time to remind your filling attendant staff of these hazards, and that they must ensure that the appliances are turned off before filling. Educate them on how these appliances look and sound like, and provide guidance for new workers. Attendants must also understand their responsibility to minimize releases of propane from open spit valves and when disconnecting the filling nozzle.  

Clean Fuel Regulations Updates

CATS User Guide

The Low Carbon Fuels Division has posted updates to the previous version of the CATS User Guide for Primary Suppliers, Registered Creators, Foreign Suppliers, and Carbon Intensity Contributors, as well as the CATS User Guide for Verification Bodies. 

These changes reflect the March update of the Credit and Tracking System (CATS).

The Summary of Changes section of the User Guide provides an overview of changes compared to the previous version. These updated PDF versions (v4.0) can be found on the Clean Fuel Regulations Google Drive, in folder 10.  

As of March 18, 2024, an updated fourth version of CATS is available that will allow applicable users to create and submit new reports:  

  • Credit-Adjustment Report,  
  • Compliance-Credit Balance Report, 
  • Compliance-Credit Revenue Report and 
  • Complementary Compliance Report. 

This version of CATS will also allow for the Compliance-Credit Clearance Mechanism to occur as applicable. For the added reports, the verification functionality is enabled as applicable. More functionalities are expected in future releases.  

Environment and Climate Change Canada’s Credit and Tracking System (CATS) is a secure, web accessible platform that must be used for registration, reporting, credit creation and use under the Clean Fuel Regulations.  

An organization’s account in CATS must be created by an authorized agent as defined in the Clean Fuel Regulations, who also completes and submits the registration report.  An organization may have only one authorized agent who must also submit authorization and identity verification documents, as applicable, in order to gain full access to CATS and on-board subsequent account users. Registration reports may be submitted prior to submitting these documents.   

For verification bodies, their designated authorized agent can create an account, register their organization in CATS and oversee the acceptance of verification assignments and the submission of verification reports.  As part of the registration process, verification bodies must provide information on their organization including the organization’s accreditation certificate and/or scope of accreditation document.  

For more information on using CATS, please consult the FAQs and CATS User Guides.   

CATS may be accessed at this webpage.

For inquiries related to accessing and using CATS, contact the CFR Operations Office at cfscats-scscncp@ec.gc.ca. 

For questions about the Clean Fuel Regulations and their requirements, email: cfsncp@ec.gc.ca. 

Planned observation of witness assessments by ECCC

The following is an information bulletin on verification body accreditation for the Clean Fuel Regulations (CFR).  

Background   

According to section 137 of the CFR, the verification of any application or report must be conducted by an accredited verification body (VB). 

Accreditation  

Accreditation is a process that ensures that the VB has achieved an appropriate level of organizational proficiency and that it has reliable mechanisms in operation to continually improve the quality of services it delivers, according to standards developed by impartial organizations such as the International Organization for Standardization (ISO). Essentially, accreditation serves to demonstrate that the VB has the necessary infrastructure, procedures, and people (i.e., competence) in place to conduct verification.  

Designated Accreditation Organization 

Accreditation organizations are designated by Environment and Climate Change Canada (ECCC) and include the Standards Council of Canada (SCC) and the ANSI National Accreditation Board (ANAB). These organizations develop their CFR-specific accreditation programs according to International Standard ISO/IEC 17011.  

Witness assessments 

Witness assessments are a common practice and requirement in the accreditation of third-party verification bodies. The purpose of a witness assessment is to assess the compliance of a VB (when delivering verification services) with the applicable requirements contained in the standards and other criteria included in the scope of its accreditation. These assessments are conducted by experienced assessors, working for the accreditation body, who are qualified to carry out this type of mandate.   

The accreditation programs developed by both the SCC and the ANAB require periodic witness assessments for any VB to be accredited for the CFR.  The assessments confirm the VBs’ ability to undertake verification activities in a competent manner under each of the four applicable accreditation technical scopes listed under subsection 140(1) of the Regulations: 

  • the production, import, distribution and delivery of fossil fuels, including hydrogen that is produced from such fuels; 
  • the production, import, distribution and delivery of low-carbon-intensity fuels, other than hydrogen; 
  • the production and distribution of electricity and any transactions related to electricity; 
  • the production, import, distribution and delivery of hydrogen from renewable sources.

Witness assessment selection is the prerogative of the accreditation organizations and is determined based on risk as well as the type of verification. 

To facilitate enabling witness assessments to occur, International Standard ISO/IEC 17029, the standard governing how verification is undertaken and that applies to every accredited VB, includes a clause (10.2.3) that stipulates that the VB shall provide information and update its clients on its requirements for the client to make provisions, where applicable, to accommodate the presence of observers such as accreditation assessors. Those requirements are most often included in the contracts signed between the VB and its client. 

Cooperation among parties 

ECCC urges cooperation between all parties involved in the accreditation process for the CFR, including the accreditation organization, the VB, and the regulated parties. We encourage each party to support the accreditation process, in a manner that satisfies the requirements of the accreditation programs and any contractual arrangements.  

Outreach session May 9, 2024

ECCC’s Low Carbon Fuels Division will hold an outreach session on the Clean Fuel Regulations on May 9, 2024, from 1:00 – 3:00 pm ET.  See Webex meeting details below.  

During this session, the Low Carbon Fuels Division will be providing information on the following topics:  

  • The new version of the Fuel Life Cycle Assessment (LCA) Model and other related documents will be published in June 2024.  
  • The requirement to submit new CI applications after July 1, 2024, using the new version of the Fuel LCA Model, including a verification report.  
  • Clarification for new pathway applications.  
  • Summary on credit adjustments.  

IMPORTANT NOTES  

A new version of the Fuel LCA Model will be published in June 2024. All CI applications submitted on or after June 30, 2024, must be verified by an accredited verification body.   

Please note that CI applications that were submitted before July 1, 2024, for CI values determined using input data for 24 consecutive months (Final CI), and that do not get approved by July 1, 2024, will not be approved, given the new version of the Fuel LCA Model will then be available.   

These applicants will be required to submit a new CI application using the new version of the Fuel LCA Model.  

Due to the large number of CFR CI applications currently being reviewed by ECCC, applicants that are considering submitting a CI application in the next two months are encouraged to wait until after July 1, 2024, to submit a CI application using the new version of the Fuel LCA Model.  

ADDITIONAL INFORMATION  

The Regulations allow registered creators to adjust the number of compliance credits created following updates to the CIs used for credit creation. Please consult the factsheet on the Clean Fuel Regulations Google Drive 

All final CIs approved by ECCC before July 1, 2024 (determined using a version of the Fuel LCA Model published before June 2024), cease to be valid on December 31, 2025, as per subsection 86(9) of the Regulations. All registered creators, CI contributors or foreign suppliers requiring a CI must submit a new CI application after July 1, 2024, using the new version of the Fuel LCA Model. The CI application must be verified by an accredited verification body in accordance with section 130 of the Regulations. The approval of the new CI is required to request a credit adjustment based on CIs.   

The earliest date for a credit adjustment based on CIs would be in the annual credit-creation report or the credit adjustment report submitted in 2025 (with respect of the 2024 compliance period).   

It is strongly recommended to submit a verified application for approval of a final CI, using the new version of the Fuel LCA Model, as early as possible after July 1, 2024, to allow for adequate time for approval.   

After July 1, 2024, approved new pathways may continue to be used until the new elements (e.g. a new feedstock such as rye) get added to the Fuel LCA Model. ECCC will advise applicants on a case-by-case basis if the changes to the Fuel LCA Model necessitate updates to specific new pathways.   

Meeting WebEX Details  

 For feedback and questions related to the Regulations and supporting documents, please contact the Low Carbon Fuels Division at cfsncp@ec.gc.ca.   

New guidance material

ECCC’s Low Carbon Fuels Division has posted a new guidance document on the Clean Fuel Regulations Google Drive: 

For projects carried out in Canada, subsections 35(3), 36(3) and 37(6) of the Regulations indicate that the number of provisional credits created by the carrying out of a recognized project for each compliance period is determined: 

  • in accordance with the applicable quantification method for the project – based on the proportion of the quantity of crude oil or liquid fossil fuel that is not exported from Canada and that has a reduced carbon intensity as a result of the activities carried out for the project. 

ECCC’s Low Carbon Fuels Division has prepared this guidance document to provide additional information on the determination of the volume of gasoline and diesel that is not exported, in the case of a project that reduces the CI of fossil fuels at a refinery in Canada. This volume is required to ultimately determine the number of provisional compliance credits created in a given compliance period. Instructions on the determination of the volume of crude oil that is not exported can be found in the final version of Clean Fuel Regulations – Guidance for Determining Crude Oil and Bitumen Quantities Produced and Used in Canada under Compliance Category 1.”  

Please refer to 0 – CFR Google Drive – Contents  for a table of contents of the material available on the CFR Google Drive.  

 If you have questions about the Clean Fuel Regulations, please email: cfsncp@ec.gc.ca.

Provincial Updates

BC: TSBC 2025 Design registration fee consultation

Technical Safety BC is consulting on proposed fee changes to understand how they will impact your business. The proposed changes affect gas, elevating devices, and boilers, pressure vessels and refrigeration design registration applications for 2025. Consultation is open from May 8 – June 14. To view the full list of changes and take the survey – click here.

AB: New Standata for buildings and fire extinguishers

ON: Provide your feedback on new TSSA fees – deadline May 21

The Technical Standards and Safety Authority is consulting with stakeholders on its proposed new late-payments and inspection cancellations fees.  

The TSSA says introducing these fees will encourage customer compliance, improve safety and efficiency and expedite delivery of customer-initiated inspection services. It will review and consider stakeholder feedback and follow up with respondents on the consultation outcome.   

Take the survey. The deadline to provide feedback is Tuesday, May 21, 2024. For more information, view the TSSA Newsroom. 

NB: Spring weight restrictions removed

Spring weight restrictions were lifted from highways in southern New Brunswick on April 28 and in the northern region, on May 5. View more information here.

Upcoming CPA Committee Meetings

Saskatchewan Committee Meeting
In-person Meeting
Date:
June 5, 2024
Time:
2:30 pm – 4:30 pm CT
Location: 
2107 E Truvey Road
Regina, SK S4N 3W1

Alberta Committee Meeting
In-person Meeting
Date:
June 13, 2024
Time:
1:00 pm – 3:00 pm MT
Location: Propane Training Institute
715-5th Avenue S.W, Suite 2700
Calgary, AB T2P 2X6

British Columbia Committee Meeting
In-person Meeting
Date:
June 20, 2024
Time:
9:00 am – 11:00 am PT
Location: Fairfield By Marriott Kelowna
1655 Powick Road
Kelowna, BC V1X 4L1
Click here for more details

Regulatory Affairs Committee Meeting
Virtual Meeting
Date:
June 25, 2024
Time:
1:00 pm – 3:00 am ET

.

.

.

.

.

.

.

.

.

.

 

Visit Maxquip

CPA Events - SAVE THE DATES!

Canadian Propane Association Leadership Summit 2024

When: May 14-16, 2024
Where: Ottawa Marriott Hotel
100 Kent Street, Ottawa, ON

Register here

CPA Atlantic Seminar & Golf Tournament 2024

When: June 5-6, 2024
Where: Rodd Brudenell River Resort
86 Dewars LN, Cardigan, PE
.

Register here

Saskatchewan: Special event for CPA members

When: June 6, 2024
Where: Double Tree Regina
1975 Broad St, Regina, SK

Learn more

CPA Ontario Seminar & Golf Tournament 2024

When: June 19-20, 2024
Where: Sheraton Fallsview
5875 Falls Avenue
Niagara Falls, ON L2G

Register here

CPA 2024 Alberta Seminar & Kandlelighters’ Golf Tournament

When: September 6-7, 2024
Where: Red Deer Resort & Casino
3310-50 Avenue, Red Deer, AB 

More details

CPA 2024 BC Seminar & Golf Tournament

When: September 17, 2024
Where: Pitt Meadows Golf Club
Pitt Meadows, BC

More details Calendar - Events