Propane Risk & Safety Management Plans

My facility has propane on site, do I need a licence and an RSMP?

Only facilities that fill cylinders, vehicles, sell propane in bulk to end users or transfer propane in bulk are licenced and must submit RSMPs. Locations that have propane tanks or cylinders connected to and supplying heating systems are considered to be consumer applications that do not require a licence or an RSMP.

Are sites with propane tanks or cylinders that are used exclusively for heating purposes required to have a licence and RSMP?

Sites that only consist of propane tanks or cylinders connected to heating systems are considered to be consumer applications, which do not require a licence or an RSMP.

If the dispenser owner lives next to the dispenser but on a separate lot (different address than dispenser) is the owner's residence now considered a public residence?

Yes, the owner's residence is a public receptor since it is off site.

What is the definition of the "mobile capacity"?

Total "mobile capacity" is the total capacity of all trucks and trailers parked on the site for a period longer then it takes to load or unload. 

Are consumer/heating tanks to be included in total storage capacity? 

Consumer tanks and cylinders connected for use do not have to be included in the total storage capacity for the purposes of licensing and determination of whether or not a site qualifies to submit Level 1 or Level 2 Risk and Safety Management Plans. 

How is the total capacity defined for the purpose of Level 1 and Level 2 RSMP and TSSA licensing?

Ontario Regulation 440/08: Propane Storage and Handling defines total capacity as "the total volume of fixed, portable, mobile and all other transient storage at a retail outlet, filling plant, cardlock/keylock, private outlet or container refill centre, including the total volume of all cylinders or tanks in which propane is stored and any tanker trunks or rail cars that stay at the retail outlet, filling plant, cardlock/keylock, private outlet or container refill centre for longer than it takes for the propane to be transferred". 

What process needs to be followed and what information is required by the TSSA for a change of owner of a filling plant? 

When a filling plant changes ownership the new owner must submit the following to the TSSA within 15 days of the change of ownership:

• Application form
• Fee
• Proof of valid Ontario business (e.g. Corporate Profile, Business Registration etc.)
• Copy of Record of Training (ROT) wallet card
• Letter on company letterhead naming the officer/director/partner/sole proprietor/senior management person
• A senior management person who is designated by the applicant for the purposes of that subsection, if there is no officer, director, partner or proprietor of the applicant or if there is no officer, director, partner or proprietor of the applicant present in Ontario.
• Certificate of insurance
• Municipal approval - 27(3)(c)
• Level 1 or 2 Risk and Safety Management Plan (120 days later)

What changes are required to be reported to TSSA?

All physical and procedural changes that affect any part of the RSMP or the site licence information must be reported to TSSA within 15 days of being put into effect. 

Are medical centres (medical clinic with doctor's offices) considered sensitive institutions or a commercial building?

Medical centres would be considered commercial. In comparison, hospitals are considered 'sensitive' because many patients have mobility issues and may be unable to recognize physical danger. This is not the case in a medical centre.

Are school yards (school building is not within the hazard distance but part of the yard is) considered sensitive institutions or a park?

The school yard is considered a sensitive institution because it is part of the school and will be occupied by children. 

If a dispenser owner rents a building on the site to another person to operate a vehicle repair garage, is this garage now considered a public commercial building?

The garage would be considered a public commercial building since the public will now have access to it (similar to a Canadian Tire Store beside the dispenser). The purpose of Major Industrial Accidents Council of Canada (MIACC) is to protect the public.

Is there information about safe distances to keep away from a propane filling station tank if it catches fire?

For information about safe distances for locating other buildings in the town around the propane facility, you need to calculate the Hazard Distance for the facility. Refer to Page 12 of the Guidelines for the Implementation of the Risk and Safety Management Plan to learn about calculating Hazard Distance.

For information about safe distances for fighting a fire at a propane facility, the Office of the Fire Marshal may have guidelines. The National Fire Protection Association (NFPA) Hazmat Emergency Response standards (NFPA 471, 472 & 473) may also provide more information.

A propane storage/handling facility is located in an industrial area. The neighbour to the south wants to sever his industrial lot into two lots. Would this be allowed under the Propane Regulation?

There is nothing in the Propane Regulation that would prevent someone from splitting an industrial lot into two lots. This is strictly a zoning or land use issue. 

Will TSSA accept tanks with missing or unreadable nameplates?

TSSA cannot and will not accept tanks or cylinders with missing or unreadable nameplates or markings as these are the only evidence available to confirm that a tank or a cylinder is safe to use. When encountered, tanks and cylinders without the required markings must be emptied and be taken out of service immediately. 

What documents need to be signed and sealed by a professional engineer?

A letter confirming that an RSMP has been prepared by a professional engineer referring to a specific site and a specific RSMP version/date shall be stamped and shall be signed by a professional engineer registered in Ontario. 

Do Level 1 RSMPs require approval by the local fire service? 

Level 1 RSMPs do not require approval from the local fire service but the local fire service must be given an adequate opportunity to review the plan and comment on the emergency response and preparedness procedures. 

Section B (Page 9 and 10) shall be completed in consultation with the local fire services. 

Section B (Page 11) requires signature of the local fire services. 

How long will fire service require to review RSMPs? 

Will TSSA process Level 1 RSMPs that are not reviewed and signed by the local fire service?

Yes, as long as the local fire service has been provided an opportunity to review the plan and visit the site. This must be documented by a letter, an affidavit or courier receipt, confirming that the local fire service was given an opportunity to review the RSMP and visit the site. 

Will TSSA approve Level 2 RSMPs that are not approved by the local fire service? 

What hazardous materials and quantities should be reported on Page 4 of Level 1 RSMPs?

Instead of listing the chemical on Page 4 of Level 1 RSMPs, sites that maintain Materials Safety Data Sheets (MSDS) may report the location of the MSDS records.

What is the "lock out procedure" on Page 10 of Level 1 RSMP?

What will TSSA accept as a map of surrounding area required on Page 12 of Level 1 RSMP?

We accept any document, such as a topographical map, municipal zoning map, picture or a sketch of the surrounding area, provided that the document contains all the required information that would normally be captured on an aerial map listed as items 7 to 14 on Page 12 of Level 1 RSMP.

The Facility Site Plan and the Map of Surrounding Area may also be combined in one document, as long as they contain all of the required information. TSSA will not complete processing of Level 1 RSMPs unless a map of the surrounding area is also submitted.

Who is the municipal contact on Page 5 of Level 1 RSMP? 

Do all questions on Page 10 of Level 1 RSMP need to be answered? 

What information contained in Level 1 and Level 2 RSMPs is publicly releasable?

Are industry-wide emergency response plans or mutual assistance arrangements required to be reported in Level 1 or Level 2 RSMPs?

Are Level 2 RSMPs required to be sealed by a professional engineer before fire service review or approval is granted? 

Can a small propane facility prepare and submit Level 2 RSMPs to TSSA?

However, it is important to note the following:

• Level 2 RSMPs require longer and more detailed review and thus will result in higher fees being charged to the applicant
• Level 2 RSMPs have to be approved by the local fire service

What is a Record of Training?

ROT stands for Record of Training, such as PPO-1, PPO-2 PPO-3, PTO. These records of training are issued by TSSA accredited training providers.

Who are the accredited training providers?

What is the level of training/ROT required for a given facility?

What documents are required along with the name of the person holding the required ROT? Is this a licensing renewal requirement question?

All requests for licences must be accompanied by the following:

1. Proof documentation that the business is registered in Ontario and that it is an active business. Please contact the Ministry of Government and Consumer Services Companies Helpline at 1-800-361-3223 to obtain an up-to-date Corporate Profile or Business Name Report and forward it to TSSA.
2. A letter on company letterhead naming the "Officer or Director" in the case of a corporation, "Partner" in the case of a partnership or "Proprietor" in the case of a Sole Proprietorship who holds the ROT. Where no Officer/Director resides in Ontario, an Officer/Director of the corporation may designate a Senior Representative in Ontario to meet the ROT requirement.
3. A copy of the ROT certificate.
4. Certificate of insurance

These required documents are identified in the covering letters sent to all applicants. 

What is the definition of an officer or a director who is required to hold an ROT for the purposes of Level 1 or Level 2 RSMP? 

Which RSMP and what TSSA licence is required for cylinder exchange facilities