Compliance and safety news for the propane industry


October 2024 

Regulatory Updates

A win for the industry! New equivalency makes bulk truck operations safer for drivers

After years of advocacy from the propane industry, efforts to make bulk truck operations safer for drivers has finally paid off. 

New Equivalency Certificate SH 14614 removes the need for drivers to crawl under the truck before and after deliveries to close a valve. It also permits leaving gauge and liquid level valves open, ensuring their functionality during bulk truck activities. 

As per Transport Canada, please note that the conditions listed in the equivalency certificate must be adhered to at all times. Subsection 31(4) of the Transportation of Dangerous Goods (TDG) Act, 1992 stipulates that non-compliance with any of the terms or conditions invalidates the certificate. Also, subsection 31(6) of the TDG Act, 1992 gives the Minister, or a designated person, the authority to revoke the certificate. Finally, all other requirements of the TDG Regulations must be complied with, unless it’s specifically listed on the certificate. 

Transport Canada: Newsletter for highway & portable tanks

Transport Canada has issued a newsletter on highway and portable tanks providing information to B620 facilities that modify or build bulk trucks.

MDIN & TCRN: What are they?

An MDIN is a manufacturer’s or modifier’s design identification number, issued by the facility. 

Which tanks require an MDIN? 

  • TC 406 
  • TC 406 Crude 
  • TC 407 (MAWP 240 kPa) 
  • TC 406 FRP 
  • TC 412 FRP 
  • TC 423 
  • TC 44 
  • TC 412 (MAWP 103 kPa) 
  • TC 407 FRP

A TCRN is a Transport Canada registration number, issued by Transport Canada. 

Which tanks require a TCRN? 

  • TC 331 
  • TC 338 
  • TC 341 
  • TC 407 (MAWP>240 kPa, or vacuum-loaded) 
  • TC 11 
  • TC 51 
  • TC 60 
  • TC 412 (MAWP> 103 kPa, or vacuum-loaded)

When is an MDIN or a TCRN required? 

  • Any TC highway tank or portable tank certified under the 1998 edition of CSA B620 or later must have either an MDIN or a TCRN. CSA B620-98 came into force on August 15, 2002. 

Where can I find the MDIN or TCRN marking? 

  • The marking is found on the metal identification plate and modification plate(s). 

Can multiple highway tanks have the same MDIN or TCRN? 

  • Yes, the same MDIN or TCRN may be used on multiple tanks certified to the same design. 

Is a new MDIN or TCRN required when modifying a tank? 

  • Yes, a different MDIN or TCRN must be issued for the modification design (Clause 7.6.6.1.1, CSA B620). There are exceptions to this, such as when a design review is not required for certain types of piping modification or remounts (Clauses 7.6.6.1 .3 & 7.6.6.2, CSA B620). 

Why are the MDIN and TCRN important? 

  • They provide traceability, by linking the tank certification/modification back to the design package that has been reviewed and approved, in accordance with CSA B620. 

If you require additional information, please contact Transport Canada at MOCRegister-Registrecontenant@tc.gc.ca  

Reminder: Transport Canada TDG database registration deadline – October 25

The deadline to register your company’s activities regarding dangerous goods activities on Transport Canada’s new Client Identification Database (CID) is fast approaching. Any company that ‘imports, offers for transport, handles, or transports dangerous goods in Canada’ must register before the deadline of October 25, 2024. For more information, click here.

BC: Companies with an approved Safety Management Plan can reduce fee costs

Technical Safety BC has released Information Bulletin: Propane Pressure Vessel Operating Permit and Fee Policy for alternative Safety Approaches Clients. 

The bulletin outlines TSBC’s new policy for propane tanks annual operating permits and fees for companies with an approved Safety Management Plan under the Alternative Safety Approaches (ASA) regulation.  

TSBC says its ASA program is designed to provide greater flexibility in regulatory compliance, and those with an approved Safety Management Plan may find advantages in terms of reduced administrative burdens and lower fees. 

Please note that there are no changes in the requirements to obtain operating permits and pay required permit fees for propane tank owners without an approved Safety Management Plan. 

You are encouraged to review the bulletin for details on the new fee structure and the associated benefits. For any questions, or need further clarification, email asa@technicalsafetybc.ca. 

BC: New Low Carbon Fuel Standard portal for 2024 compliance reporting

The Low Carbon Fuels Branch is transitioning from the Transportation Fuels Reporting System to the new Low Carbon Fuel Standard (LCFS) Portal for the 2024 compliance reporting period. The portal will become available in January 2025. 

No immediate action needed: All existing TFRS organization and user accounts will be automatically migrated to the new LCFS Portal. There is no need to take any action for current accounts to be transferred. 

But do plan ahead for minor disruptions: There may be minor disruptions during the transition period between November 2024 and January 2025. To avoid delays, plan accordingly for any credit transfers or reporting activity ahead of this period. 

Key updates in the LCFS Portal: 

  • Clearer descriptions of report components, including direct links for adding information. 
  • Files can be attached directly to compliance reports. 
  • Streamlined fuel supply reporting for volumes that have been allocated from other organizations, eliminating the need to submit a separate exclusion report. 
  • Final supply equipment registration (specifically for electricity reporters). 
  • Reporting for exported fuel previously marketed in British Columbia. 
  • Simplified submission process for compliance unit transfers 

Reporting deadline remains the same – March 31. Reporting, Initiative Agreement issuance, and credit transfers will continue to be managed through online submissions using the LCFS Portal for 2024 and beyond. Email submissions will not be accepted, except for exemption reports. 

The Transportation Fuels Reporting System will continue to function for late reporting and supplemental reporting for the compliance periods 2019-2023. Note that late reporting may be subject to discretionary administrative monetary penalties under section 38 of the Low Carbon Fuels Act. 

The Low Carbon Fuels Branch is planning to provide comprehensive guidance and support materials to help navigate the new LCFS Portal. For any questions, contact lcfs@gov.bc.ca or visit their website 

BC: Reminder – TSBC fee increases effective January 1, 2025

Technical Safety BC’s fees increase on January 1, 2025. Most fees will increase by 4% per the 2024-2025 fee schedule. 

View the fee schedules 

NS: New safety topics added to online resource

The Department of Labour, Skills and Immigration Safety Branch has added new safety topics and trusted resources to Nova SAFE.  

Nova SAFE is an online resource that offers Nova Scotian employers, supervisors, and workers access to important safety information. 

The following new topics were added to the site: 

  1. Noise 
  2. Respiratory Protection 
  3. Heat stress and Cold stress 
  4. WHMIS 

You can find helpful information, direct links to legislation, educational offerings and other resources on NovaSAFE.ca.

Upcoming CPA Committee Meetings

Saskatchewan Committee Meeting
Virtual Meeting
Date:
November 13, 2024
Time:
9:00 am – 10:30 am CT

British Columbia Committee Meeting
Virtual Meeting
Date:
December 12, 2024
Time:
10:00 am – 12:00 pm PT

Alberta Committee Meeting
Virtual Meeting
Date:
January 9, 2025
Time:
9:00 am – 10:30 am MT

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