Past changes to the code requirements forced provinces to create a deadline to complete PRV replacements. The code states that tanks greater than 2500 USWG must be replaced every 10 years, while the tank requirements for those less than 2500 USWG must be completed every 25 years.

The following are province-specific deadlines for when industry must be up-to-date on these replacement activities.

British Columbia:  Directive: Propane storage tank pressure relief valve servicing and inspection intervals | TSBC

• January 1, 2024, for vessels greater than 2500 USWG;
• January 1, 2024, for vessels 2500 USWG or less (excluding cylinders as defined by
  CSA B149.2) with an external PRV; and
• January 1, 2027, for vessels 2500 USWG or less (excluding cylinders as defined by
  CSA B149.2) with an internal PRV.

Alberta: Servicing of Pressure Relief Valves on Propane Storage Tanks| ABSA

• The notice establishes that each owner should develop a compliance plan by December 31, 2015 to come into compliance by May 31, 2024. The compliance plan should establish the priority for PRV servicing or replacement. PRVs should be serviced or replaced as per the plan. Compliance audits will be carried out by Gas Safety and ABSA.

Saskatchewan: Propane tanks – Servicing Intervals for Pressure Relief Valves on Tanks 2500 USWG and Less |TSASK

• All 2500 USWG or less pressure vessels in LPG service governed by CSA B149.2 shall comply by May 31, 2024.

Manitoba: Servicing Intervals for Pressure Relief Valves on Tanks 2500 USWG and Less |ITS

• Propane storage tanks with a volume of 2500 USWG or less must meet all requirements of the legislation and shall comply with CSA B51-14 Table 5 before May 31, 2024.

Ontario: Propane Code Adoption Document Amendment |TSSA

• 7.2.8 Tanks greater than 2,500 USWG shall have the relief valves rebuilt/certified or replaced every 10 years. All overdue relief valves shall be rebuilt/certified or replaced by May 1, 2024.
• 7.2.9  Tanks of 2,500 USWG or less shall have the relief valves rebuilt/certified or replaced every 25 years. All overdue relief valves shall be rebuilt/certified or replaced by May 1, 2027.

Quebec: InfoC3H8-2 février 2024 (cyberimpact.com)

New Brunswick, Nova Scotia, and Newfoundland and Labrador expect industry to be current as per the B51 regulatory requirements.

Environment and Climate Change Canada has provided information about the forthcoming reporting timelines for the 2024 compliance period as it pertains to the submission of agreements to create credits and provisional credit creation, as outlined in sections 21 and 22 of the Regulations.

As per section 21 of the Regulations, a registered creator may, before they have created any provisional compliance credits, enter into an agreement to create compliance credits during a compliance period for one or more credit creation activities with:

• a person carrying out a CO₂e emissions reduction project described in section 30,
• a person carrying out the production of low-carbon-intensity fuel under subsections 94(1), 95(1), 96(1), or 100(1), or
• a person supplying fuels or energy sources to vehicles under subsections 98(1), 99(1), 101(1), 102(1) or 104(1).

A section 21 agreement to create credits on behalf of another party may be submitted via the Clean Fuel Regulations Credit and Tracking System (CATS), upon submission of a registration report in CATS, or, after submission of a registration report. As per section 22, provisional credit creation by a registered creator for an activity subject to a section 21 agreement is eligible to start as of the day after the agreement is submitted, or at the start of the compliance period if an agreement is submitted within the first 60 days of the compliance period.

• 22 (1) A registered creator who enters into an agreement referred to in section 21 must submit the agreement to the Minister and, subject to subsection (2), must not create provisional compliance credits under the agreement until the day after the day on which it is submitted
• 22(2) If the agreement is submitted to the Minister during the first 60 days of the compliance period to which the agreement relates, the registered creator may create provisional compliance credits under the agreement as of the first day of that compliance period unless the agreement provides for a later date.

As a result of submitting a section 21 agreement, it is important to note that the registered creator will be the entity to create compliance credits for the credit-creation activity(ies) specified in the agreement and not the other party to the agreement who undertakes the credit-creation activity(ies). The registered creator who submits a section 21 agreement is therefore responsible for all requirements related to those credit creation activities. This may include the submission of CO₂e Emission Reduction Project Applications, CI Applications, Credit Creation Reports, and ensuring 3^rd party verification is completed, as required.

Important Notice

Section 21 – Agreement to Create Credits for 2024

As per the Regulations, a section 21 agreement is only valid for one compliance period as identified in the signed agreement. This allows entities that have entered into an agreement to review and/or update the information submitted under the Regulations via CATS.

A new section 21 agreement must be submitted for each compliance period, to ensure that all activities in an agreement are still online and operational. As such, any section 21 agreements submitted in 2023 must be submitted again in 2024; otherwise, the activities listed under the agreement will no longer be eligible for provisional credit creation in 2024 by the registered creator who submitted the agreement in 2023.

Please note, for section 21 agreements undertaken with a person carrying out the production of low-carbon-intensity fuel (subsections noted above) and/or a person supplying fuels or energy sources to vehicles (subsections noted above), only activities that are online and operational (or close to, i.e. within the compliance period) should be listed in a section 21 agreement for said compliance period. The registration report (or update thereof) and associated section 21 agreement(s) cannot be submitted for activities that are envisioned to come online at a future date.

Provisional Compliance Credit Creation Start Date – 2024

In order to be eligible to create provisional compliance credits via a section 21 agreement(s) as of January 1, 2024, the signed agreement(s) must be submitted to ECCC via CATS by the registered creator by March 3, 2024, as per subsection 22(2).

If a section 21 agreement is submitted after March 3, 2023, provisional credit creation for the activities listed in the agreement will be eligible to begin on the day after the agreement is submitted, as per subsection 22(1).

Cancellation or modification of a section 21 agreement:

A registered creator may cancel a section 21 agreement at any time by sending a notification to the Minister via CATS. Should information change pertaining to a section 21 agreement for compliance year 2024, the registered creator is responsible to ensure the information is updated and valid for ECCC reporting as per the requirements under the Regulations.

Register and Upload a section 21 agreement to CATS:

To register as a registered creator, and submit a section 21 agreement to CATS, please refer to the User Guide available on the Clean Fuel Regulations Google Drive. Sections 2 and 3 provide more information on CATS, the process of creating an account, submitting a registration report, and section 21 agreement (s).

Transport Canada has reported that they are finding non-compliance with the placement of requalification marks on cylinders not having a permanent collar.  

To stamp the requalification mark directly on the shoulder/head of any cylinder, requalifiers must first ensure that the cylinder meets the thickness requirement of 2.2 mm (0.0866 inches).  

Markings must be as per CSA B339 24.6.1.1(a) BUT ONLY IF clause 15.13 “applicable specifications thickness requirement of 2.2 mm (0.0866 in)” is met.

Cylinder Requalifiers must verify that the cylinder shoulder has adequate thickness to allow stamping of the cylinder in this location. 

Health Canada has issued a safety notice affecting certain gas fireplaces manufactured by CFM Inc. due to the risk of glass failure. Affected models include Insta-flame or Northern Flame (Models FSDV22, FSDV30, FSDV32, D222 and D232 Series). The relief dampers may not function properly, causing the excess gas to ignite and then the glass to explode when lighting the fireplace, posing a serious risk to the safety of Canadians. Retailers and distributors should stop the sale of these fireplaces immediately and customers should stop using them immediately. 

Technical Safety BC’s boiler, pressure vessel, and refrigeration code adoption consultation is now open for comments. They are interested in understanding how ready industry is to use the latest editions of the boiler, pressure vessel, and refrigeration codes. Your feedback will help TSBC develop a recommendation to the province on adopting the codes for use in BC. For any questions about this consultation, please email Meryl Howell-Fellows, advisor, Insights & Engagement at engage@technicalsafetybc.ca. 

Dr. Michael Rensing has provided a guide for CPA members reporting propane under the BC Low Carbon Fuel Standard (LCFS). This document provides compliance reporting background and instructions for propane suppliers who have sold propane in B.C. for transportation uses up to December 31, 2023, and who do not wish to rely on the default carbon intensity, or who have not acquired their propane with an approved carbon intensity under an exclusion agreement.   

The Greenhouse Gas Reduction Act and the Renewable and Low Carbon Fuel Requirements Regulation, known collectively as British Columbia’s low carbon fuel standard (LCFS), was introduced to reduce the carbon intensity (CI) of fuels used in the province. The Act requires an annual compliance report for propane that has been supplied in B.C. for transportation use and requires that the suppliers comply with the carbon intensity requirements for that fuel. Note that beginning January 1, 2024 there will be new regulatory processes that will implement the same policy but with updated values and procedures.  

CPA members may also use the GHGenius report for B.C. propane (prepared for the CPA in January 2024) for their reporting purposes.   

Dr. Rensing will be presenting the guide at the next BC Committee meeting on March 7. Please review the guide before the meeting and come prepared with any questions you may have.   

The Propane Training Institute, in collaboration with the PTI Trainer Committee, is currently evaluating the training materials for Propane Pump Attendants. Trainers deliver this material regularly and as the PTI undergoes updates, your insights will greatly contribute to the evolution of its training resources. 

If you have any suggested changes or feedback, please email the PTI team at training@propane.ca. Your contributions are instrumental in shaping the quality and relevance of PTI’s training programs.