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Call for Comments - Proposed Mandatory Certificate Upgrade Training: Petroleum Mechanics

The Technical Standards and Safety Authority’s (TSSA) Liquid Fuels program regulates certificates held by Petroleum Equipment Mechanics who install, inspect, service and maintain petroleum equipment and systems in Ontario. Mechanic certifications range from Petroleum Mechanics (PMs) Classes 1 to 4, Petroleum Mechanic Helpers (PMHs), and Site Operators (SOs). The main regulation that governs the scope of work for PMs, PMHs, and SOs is Ontario Regulation 216/01 (Certification of Petroleum Mechanics). O Reg. 216/01 lists the type of activities that each of the respective certificate holder categories are authorized to perform.

Every person in Ontario engaged in an activity, use of equipment, process or procedure involving the use of petroleum products as a fuel for motor vehicles or fuel oil, are required to abide by O. Reg. 217/01. PMs (from Class 1 to 4), PMHs and SOs, as the primary certificate holders certified to install, repair, service and remove petroleum equipment in the province, are expected to be knowledgeable of various requirements under O. Reg. 217/01.

The changes in the 2017 edition of the LFHC include, but are not limited to:

The Liquid Fuels Handling Code (LFHC), adopted under Ontario Regulation 217/01 (Liquid Fuels) serves as a codified set of requirements governing the detailed storage and handling of liquid fuels products at bulk plants, marinas, retail outlets and private outlets.

In 2017 significant changes were made to the LFHC. The revised code was a product of a consultation process with various stakeholder groups and regulated customers. Details around these changes can be found on TSSA’s Safety Exchange Blog.

From the LFHC changes, several recommended training changes emerged.


The major changes to the training requirements include:

  • All petroleum mechanic certificate holders will upgrade their knowledge of the code requirements and review the applicable regulations. Full details of this will be outlined in an October 1st Director’s Requirement document.
  • The Director’s Requirement will mandate that all petroleum mechanic certificate holders wishing to renew their certificates will need to submit proof of completion from a TSSA-approved training provider beginning April 1st, 2018. The training providers will be asked to document and track course participants in order to assist TSSA with the administration of the update.
  • The training will be available to all certificate holders until the end of March 2021. This deadline was set by calculating the absolute last day a petroleum mechanic could renew his/her license.
  • The training session will cover the changes to the 2017 LFHC and will also serve as a refresher on the code and the regulations. The update program will be available in both online and live seminar formats and is projected to cost between $200-$300

To provide comments on the proposed Mandatory Certificate Upgrade Training for Petroleum Mechanics, please fill this docket request form and email it to Natalie Yagelska at nyagelska@tssa.org

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The Ontario Fuel Oil Code Adoption Document (CAD) FS-219-16 was issued April 4, and will be effective July 1, 2016.

This CAD amendment revokes and replaces the previous amendment (FS-202-2012, dated November 1, 2012). It also adopts the new CSA-B139 Series-15, consisting of the following:

  • B139.1.0-15, General requirements for large installations
  • B139.1.1-15, General requirements for stationary engines
  • B139.1.2-15, General requirements for special installations
  • B139.2-15, Installation code for oil-burning equipment for residential and small commercial buildings

The remainder of this CAD amendment makes Ontario-specific revisions to the above codes. The major changes include:

  • New approval submission requirements for high pressure fuel piping to be consistent with the Boilers and Pressure Vessels Code
  • New approval submission requirements for installations that use an anti-siphon systems instead of a certified anti-siphon valve
  • Changes consistent with the Ontario Fire Code and National Fire Code
  • Only recognizing the use of Standards Council of Canada accepted standards

Special Buildings Inspections Pilot Program - Update

As part of its broad responsibilities, TSSA’s Fuels Safety team launched a pilot inspection program of retirement and long-term care homes to assess safety risks associated with fuel-burning equipment such as kitchen appliances, clothes dryers, HVAC equipment, and standby generators.

Initial inspections focused on locations in the London and Ottawa areas. A preliminary analysis of those inspection results indicates greater diligence is required in the maintenance and servicing of fuel-fired equipment to ensure the safety of building occupants from risks of fuel leaks and spills, and in particular carbon monoxide poisoning.

In order to further assess the safety risks associated with fuel-burning equipment at special buildings and develop appropriate risk mitigation strategies, TSSA will continue the Special Buildings Inspections Program (SBIP) in 2015.

For more information about the SBIP, including photos and FAQs, please see our blog post, Special Buildings Inspections Pilot Program to Continue

Certificate Requirement Eliminated for Retail Assembly of Portable Outdoor Fuel Appliances

With BBQ season here, the timing is excellent. Ontario’s Ministry of Government and Consumer Services  introduced amendments to the regulatory requirement that retail employees assembling propane and natural gas BBQs and other outdoor fuel appliances be TSSA-certified.

Effective immediately, retailers such as supermarkets, hardware stores, BBQ specialty shops and big box stores providing assembly services for BBQs, patio heaters and other portable outdoor fuel-fired consumer appliances will  be required to have their staff receive training through an in-house or third party training program.

“These changes revise a regulatory requirement that imposed a high safety requirement for a low risk activity,” said John Marshall, Director of TSSA’s Fuels Safety Program. “By introducing a training requirement in lieu of a TSSA Fuels Certificate, public safety is ensured while the regulatory burden on businesses is reduced,” added Mr. Marshall.

For more information and FAQs, please see our blog post, Certificate Requirement Eliminated for Retail Assembly of Portable Outdoor Fuel Appliances.

Northern Ontario Compliance Strategy

Recent consultations held with northern Ontario stakeholders have highlighted a number of unique operating conditions in northern Ontario including a shortage of certified fuels contractors, a short construction season to undertake equipment repairs and upgrades, and the seasonal nature of many operations in the north that can make complying with some major orders on strict timelines difficult.

In response, TSSA has revised its compliance strategy to provide additional flexibility for northern Ontario gas station and marina owner/operators with orders related specifically to underground piping and sumps.

As long as owner/operators are willing to work with our inspectors to develop compliance plans to effectively manage safety and environmental risks, regulatory requirements related to upgrading, removal and replacement of single walled underground piping and sumps will be subject to a revised, more flexible process. 

For more information, please see our blog post:

Northern Ontario Compliance Strategy – Gas Stations and Marinas

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Regulatory Amendments to Ontario Regulation 211/01- Propane Storage and Handling

On October 30, 2014, following extensive consultations with TSSA technical and safety experts, industry representatives and consumer groups, the Government of Ontario enacted regulatory changes to further enhance the safety of propane transfer facilities and reduce administrative burden on propane operators. 

A list of frequently asked questions related to these changes (FAQs) appears below the summary of regulatory amendments.

Summary of the Regulatory Amendments

There are four changes to O. Reg. 211/01. The first two will enhance the safety of propane transfer facilities:

1.  Moving from Annual Inspections to Risk-Based Inspections

    This change removes the requirement for annual inspections of propane transfer facilities to enable TSSA to fully implement its risk-based inspection-scheduling model. A risk-based approach leads to a better use of regulatory resources by targeting inspections at facilities that present the greatest risk, thereby enhancing safety.

    2.  Setting Minimum Insurance Requirements as a Condition of Licensing

      This change requires a minimum level of commercial general liability insurance as a condition of licensing for propane transfer facilities. For small facilities (Level 1), the minimum insurance amount is $1 million per occurrence. For large facilities (Level 2), the minimum insurance amount is $5 million per occurrence. This change enhances safety by giving both the insurer and the insured an incentive to work together to minimize safety risks.

      The remaining two changes seek to minimize burden on business by enabling greater administrative efficiency and simplifying requirements:

      3.  Aligning the Decision Making Authority for Risk and Safety Management Plan Guidelines

        This amendment places the authority for the Level 1 Risk and Safety Management Plan (RSMP) guideline with the Director of Fuels under the Technical Standards and Safety Act (the Director), aligning it with that of the Level 2 guideline.  This enables the Director to update the Level 1 guideline to incorporate enhancements or remove elements that are no longer needed. This authority is consistent with the Director’s safety oversight expertise and responsibilities.

        4.  Adjustment to the Record of Training Requirement

          This change simplifies the current regulatory requirement for an officer, director, partner, or the sole proprietor of a business to hold a record of training. This ensures that the senior management of a business understand the safety requirements of their propane operation without undue administrative burden.


          Q1.  What prompted the project to consider changes to the Propane Storage and Handling Regulation?

          A1.  The proposed amendments were based on the outstanding Propane Safety Review (PSR) recommendations from 2008 and submissions previously made by members of the propane industry and fire services to MGCS to enhance public safety and reduce administrative burden.

          MGCS and TSSA co-chaired a series of in-person roundtable meetings between September 2013 and November 2013 to seek input and feedback on proposed amendments to O. Reg. 211/01.

          Q2.  Who was involved in the consultations?

          A2.  MGCS and TSSA established a roundtable of industry, fire services and consumer representatives. Roundtable members’ input and expertise helped MGCS and TSSA develop these proposals for broad consultation.

          Q3.  How many proposals were put forward for consideration?

          A3.  There were six proposals discussed by the roundtable.

          1.  Moving from annual inspections to risk-based inspections
          2. Setting minimum insurance requirements as a condition of licensing
          3. Aligning the decision making for Risk and Safety Management Plan (RSMP) guidelines
          4. Simplifying the record of training requirement
          5. Licensing propane distributors
          6. Licensing offsite propane storage locations

          Proposals 5 and 6 did not have sufficient incident and technical data and as a result, were not advanced beyond the roundtable level.

          Q4.  What other, if any, public consultations were undertaken besides the roundtable group?

          A4.  The final package of four proposed amendments (listed below) to O. Reg. 211/01 was posted to the Regulatory Registry on February 4, 2014 for a forty-five day period to solicit public comment.

          1. Moving from annual inspections to risk-based inspections
          2. Setting minimum insurance requirements as a condition of licensing
          3. Aligning the decision making for Risk and Safety Management Plan (RSMP) guidelines
          4. Simplifying the record of training requirement


          Q5.  How is moving from annual inspections to risk-based inspections safer?

          A5.  An inspection cycle based on risk means that higher-risk facilities will be inspected more frequently than those identified as lower-risk.A risk-based approach leads to a better use of regulatory resources by targeting inspections at facilities that present the greatest risk, thereby enhancing safety.

          Q6.  How has TSSA determined what inspection frequency is appropriate for my facility?

          A6.  The Propane Safety Review panel recommended that TSSA continue to inspect facilities annually as required until it had gathered the required data to develop a risk-based approach. TSSA has now gathered sufficient data and has built a rigorous model for risk-based inspection scheduling to determine the appropriate inspection frequency for each facility.

          Instead of annual periodic inspections for all facilities, TSSA will schedule periodic inspections based on risk, from six months to three years depending on a facility’s risk score. For most licensees this change will reduce inspection costs.

          Q7.   How credible is risk-based scheduling? Is it used anywhere?

          A7.  TSSA has been using risk-based inspection scheduling for elevating devices in Ontario since 2010, and has been awarded a patent for its model in both Canada and the United States.

          Q8.  What is the advantage of using risk-based inspection scheduling?

          A8.  TSSA’s risk-based inspection scheduling model offers facility owners transparency and predictability by providing evidential basis for inspection frequency decisions.

          Q9.  How does the risk-based inspection schedule model work?

          A9.  The model consists of two steps:
          1. Determining a facility’s risk score, which is a combination of its location residual risk and operational risk; and,
          2. Determining the window of time within which a facility should be inspected to keep its risk within acceptable limits, based on a facility's risk score and the overall occurrence rate in the propane sector.

          Q10.  Is it possible for a facility currently classified as higher-risk to be re-categorized?

          A10.  Yes. While facilities with high-risk rating would be inspected more frequently, there is a focus on continuous compliance improvement. Demonstrating a strong safety and risk management culture could positively influence a facility’s risk score going forward.

          Q11.   Is there a structure for risk-based inspections?

          A11.  Yes, inspection cycles will fall into one of four categories.
          • Every three years
          • Between six months and two years
          • Annually
          • Once every six months

          Q12.   Do you have details relating to the number of sites in each category?

          A12.  Yes. In general:

          • 85% of sites will be inspected every three years
          • 4% between six months and two years
          • 6% annually
          • 5% once every six months

          Q13.  How will you implement the change from annual inspections to risk-based inspections?  How will I know what cycle applies to my facility?

          A13.  The implementation of risk-based inspections will require the notification of propane license holders of their new inspection cycle (which is based on the facility’s individually assigned risk score).

          To find out your site-specific inspection frequency, please contact our Propane Licensing Department:

          Phone:  416-734-3587 / toll free 1-855-734-3587
          Email:   propanelicensing@tssa.org

          Q14.  When will my first risk-based inspection take place?

          A14.  The date of the first risk-based inspection following implementation of this amendment will be based on the date of the last annual inspection.

          Q15.  The fee payment structure was aligned with a facility’s annual periodic inspection and license renewal. What can I expect with respect to costs and billing frequency?

          A15.  License renewal will continue to be based on an annual cycle. The license renewal invoice will no longer incorporate a pro-rated inspection fee. You will only be billed for your inspection after it has been completed.

          Q16.   Is there a financial advantage to this change?

          A16.  The overall yearly cost of inspections to the propane industry as a whole will decrease from an estimated $525,930 to $313,960 as a result of moving from an annual to a risk-based inspection cycle.


          Q17.  What does setting minimum insurance requirements as a condition of licensing have to do with safety?

          A17.  Insurance as a condition of licensing gives both the insurer and the insured an incentive to work together to minimize safety risks by establishing an additional layer of oversight on the business. 

          Q18.  What are the minimum insurance requirements?

          A18.  The proposed minimum amounts are based on similar requirements in other jurisdictions and consultation with industry representatives.

          Type of Facility    Minimum Insurance
          Level 1$1,000,000 per occurrence
          Level 2$5,000,000 per occurrence

          Q19.  Why is this minimum insurance requirement not applicable for another year (i.e. January 1, 2016)?

          A19.  The Ontario Government wanted to ensure that operators were given ample time to make any necessary arrangements to comply with this requirement.


          Q20. What does “aligning the decision making authority for Risk and Safety Management Plan (RSMP) guidelines,” mean to me as a facility operator?

          A20.  While the Director of Fuels has the authority to make changes to a Level 2 RSMP, he has no such authority for a Level 1 RSMP. The regulations refer to a specific document as the guideline for the contents of a Level 1 RSMP. Any update to this document requires the government to change the regulation.

          Alignment of approval authority for both Level 1 and 2 guidelines, with both adhering to a specific process for change, as set out in the Level 2 guideline, is appropriate and consistent with the Director’s safety oversight expertise and responsibilities.

          Following government approval, TSSA would remove the requirement to report the number of cylinder-fills and motor-fills, and the ten highest throughput days from the Level 1 RSMP.

          Q21.  Why is the Director being given authority over the RSMP template?

          A21.  This change addresses the regulatory anomaly that currently exists – i.e. the Director has the authority to incorporate enhancements or remove elements no longer needed for Level 2 RSMP, but not Level 1. This authority is consistent with the Director’s safety oversight and responsibilities.


          Q22.  What exactly does “adjustment to the record of training requirement (ROT) mean?

          A22.  A corporation now has the flexibility to designate the appropriate senior management to hold the required record of training. The senior management person must be responsible for oversight of the corporation’s propane operations, i.e. an attestation/acknowledgment by the required ROT holder that:
          • propane must be handled in accordance with the Technical Standards and Safety Act and its regulations
          • all staff that handle propane must have at all times the training specified in the regulations
          • a propane-related incident has the potential to cause catastrophic harm to people and property
          • This enables businesses to comply within their various organizational structures.
          It does not alter the ROT requirements for persons who handle propane directly.

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