The CPA has requested permanent provision of the ‘hours of service’ (HOS) extension. Currently, an HOS extension must be requested each time one is required, which is ineffective during emergency situations and slows down the application process. A working group was created to identify the specifics of the HOS extension, and the initial request has been submitted to Transport Canada. The CPA will follow up with TC in the next few weeks.

The CPA continues to request that Transport Canada address the concern that temporary transloading does not have a process that would ensure temporary transload locations have proper systems and safety measures in place, including first response notification during these temporary operations.

Neither TC nor the provincial authorities are owning the responsibility of approval for these operations. TC has recently officially responded that these sites do not fall under their scope; the CPA has been redirected to provincial authorities who have previously indicated that this is federal and not part of their jurisdiction.

Unfortunately, it appears that unless something serious happens, neither federal nor provincial authorities will not take ownership and these operations will continue to take place without any involvement with AHJs nor with local first responders being aware of what is taking place in their area of operations.

The CPA recently requested TC provide an exemption for the transportation of containers that have been prepped for service with the addition of a small percentage of methanol.

The equivalency was requested through the typical process considering the small amount of methanol used to prepare the container for service as well as the size and robust nature of the large-pressure container itself. The container should be viewed as the equivalent of being empty.

However, some regional inspectors have suggested that the CPA should consider these containers as if they contained greater amounts of methanol and prepare TDG documents in order to transport them. This request is unrealistic and difficult to achieve because of the restrictions on how much methanol can be transported simultaneously with propane. The other issue is that each tank has a very small amount of methanol in each which is impossible to verify as it is in a sealed tank.

The CPA will monitor the request and provide further information once the response is received from TC.

Transport Canada recently reopened the commentary period on their new fee proposal for the registration of container requalification facilities. After receiving member feedback, the CPA commented that the new fees will adversely affect smaller facilities by making it too costly for them to continue to provide necessary requalification services that help maintain the circular use of cylinders in Canada. These fees could limit the number of locations in remote and rural areas, making it harder for consumers to find a place to return their cylinder or have it requalified. It may encourage consumers to either abandon a reusable cylinder or place it in a landfill which could also remove it from the recycling process.