Propane RSMPs FAQs

Propane RSMPs

• 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.

• What is the definition of “mobile capacity”?

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

• Should consumer or heating tanks be included in the total storage capacity? 

  Consumer tanks and cylinders connected for use do not have to be included in the total storage capacity for licensing and determination if a site qualifies to submit Level 1 or Level 2 RSMPs. 

• How is the total capacity defined for 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 changes to an RSMP 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. 

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

  Upon request, the TSSA releases (or makes available to the public) the emergency response procedures set out in the Level 1 RSMP or the evacuation procedures set out in the Level 2 RSMP. Everything else contained in Level 1 or Level 2 RSMPs is considered to be confidential and will be treated as such by the TSSA Access and Privacy Codes. 

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

  Industry-wide emergency response plans or mutual assistance arrangements are not required to be reported, as long as the risk assessment and mitigation controls do not take credit for such plans. Page 6 of Level 1 RSMP provides a place to describe “any other measures in place at the facility that exceeds the minimum Code and Standards requirements” which could be used to capture this information and convey it to the local emergency responders and officials. 

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

  Although not required by Ontario Regulation 211/01: Propane Storage and Handling, the local fire service and municipal organizations may require these documents to be sealed. 

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

  Level 2 RSMPs will be accepted by TSSA for small propane facilities. It is important to note the following: • Level 2 RSMPs require longer and more detailed reviews and will result in higher fees being charged to the applicant. • Level 2 RSMPs must be approved by the local fire service.

• 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 signed by a professional engineer registered in Ontario.

• Which RSMP is required for cylinder exchange facilities?

  RSMPs are not required for cylinder exchange facilities since there is no transfer of propane. For these facilities, TSSA issues a Cylinder Exchange licence. However, if the facility is already licensed as a refill centre, the cylinder exchange program is covered under that license type. 

Completing a Risk and Safety Management Plan

• What hazardous materials and quantities should be reported on Page 4 of a Level 1 RSMP?

  
  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 “lockout procedure” on Page 10 of a Level 1 RSMP?

  The “lockout procedure” is the method used to lock the facility and control access to the propane storage, dispensing and transfer location when it is not open for business or is not attended. 

• What will TSSA accept as a map of the surrounding area as required on Page 12 of a 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.

• Who qualifies as a “municipal contact” on Page 5 of the Level 1 RSMP? 

  Usually, a municipal contact is the City Clerk or a Secretary Treasurer of the Planning Board. 

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

  Yes, the answers are mandatory. Both yes and no answers will be accepted by TSSA. 

• 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 around a propane facility, you need to calculate the Hazard Distance for the facility. Refer to Page 10 of the Guidelines for the Implementation of the Risk and Safety Management Plan (pdf) 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.n.

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

  A person listed in the Articles of Incorporation as an Officer or Director. If there are no officers or directors listed living in Ontario, an Officer/Director of the Corporation may designate a senior official in Ontario to meet this requirement.