Safety & Compliance

Documentation Review

[Presenter Name]

[Organization]

The Current Reality

• The vast majority of marketers do not obtain, document and report all the safety and inspection information that is required by law, insurance underwriters or best practice

• There is no system specifically designed to electronically store and retrieve important safety information

Why The Change?

• Propane compliance laws and best practices are changing all the time.

• Changes put in place today are put in place for YOUR safety and the homeowner’s safety.

• What one technician or company representative is documenting, another is writing something completely different.

• Creating a “company standard” is the only way to learn and be held accountable.

In the Eyes of the Law…

• “If it’s not documented, it didn’t happen”

• Incorrect documentation can cost a company hundreds of thousands of dollars and can result in job termination

• Examples

Why?

• Between 10-60% of all propane safety documentation is completed incorrectly

It Makes Sense

• No one has the time to audit 100% of leak checks, safety inspections (Gas Check), cathodic protection inspections, regulator date codes, DOT tank requalification dates and more!

• We are relying on technicians doing things the way they should be done…

Common Mistakes We See

• Confusion regarding critical propane safety terminology (Leak Check, Pressure Test, Leak Test, Gas Check)

• A small but critical piece of data is missing – leak check hold time or pressure reading, regulator date code

• Leak check and flow and lock up testing is not recorded when replacing a regulator

• Leak check uses incorrect test procedures

• Run outs (interruption of service ) are not documented correctly

Common Mistakes We See

• Cathodic protection testing results are non compliant

• Improperly bonded CSST is not recorded, tracked or followed up

• DOT tanks in the field are past their requalification dates

• System to track point of transfer violations could be improved

• Jurisdictional account tracking could be improved

What are you worried about with respect to propane safety?

Common Mistakes We See

• Technicians do not understand the intent of some of the forms

Common Mistakes We See • Leak Check Pressure Loss or Hold Time Is Insufficient

Common Mistakes We See

• Leak Check is incomplete – results are not written in for each stage. Sometimes this is the result of the form being used.

Common Mistakes We See • Leak Check has an incorrect test procedure

NFPA 54 Annex C - Suggested Method of Checking for Leakage as listed below.

For systems serving appliances that receive gas at pressures of ½ psi or less, a leak check can be conducted by inserting a water manometer or pressure gauge into the system downstream of the final system regulator, pressurizing the system with fuel gas to a test pressure of 9 in. w.c. +/- ½ in. w.c., and observing the device for a pressure change.

What Can Go Wrong • The Installation Was Inside The Fireplace!

CUSTOMERS COMMENTS:

Don’t worry, I was told that propane is heavier than air and will not go toward the fireplace. Besides, I only use it when it’s cold outside. The other gas company said it was ok!

What Can Go Wrong

What’s Wrong With This Installation? Gas Line Across Ground & Lots Of Unions

What Can Go Wrong

You Can’t Make This Stuff Up

What Can Go Wrong

Keltie’s Blast Shows Dangers of Propane On July 28, 1997, when an explosion leveled Keltie’s Bum Steer, a popular restaurant on Route 121 in Brewster, NY.

Propane explosion in Wisconsin after undocumented leak check resulting in loss of life and a seven-figure settlement

A propane accident occurs causing multiple fatalities. The marketer says they provided Duty to Warn but can’t prove it and settled for a large confidential sum.

Marketer has documentation on file but regulator is past replacement date: the marketer pays a substantial sum to settle the case.

The Hurdles

• It’s not easy to remember all this stuff!

• It’s not easy to change your ways

– “I’ve been doing it this way for years.”

• Employees/Technicians:

– Are not always trained by the same people

– Retain information differently

– Learn things through “on site” or “in the field” training

Safety Inspection Form

• When it’s used:

– New account sign up, new appliance installation, new container installation

• Review form

Initial Duty To Warn

• When it’s used:

– New account sign up

• Review form

Customer Agreement

• When it’s used:

– New account sign up

• Review form

Work Order/Interruption of Service

• When it’s used:

– Current company policy

• Review form

Cathodic Protection Survey

• When it’s used:

– Within 180 days of initial installation

– Again within 12-18 months after initial survey

– Each additional test cannot exceed 36 months (3 years) from that point forward

• Review form

Important Takeaways

• Correct terminology is extremely important to you, your company, and your customers’ safety

• If you aren’t sure, be afraid to ask someone!

– It’s okay to ask questions, as there are no dumb questions when it comes to propane safety.

– When you ask questions you learn, when you don’t, you create a bad habit

Important Takeaways - Documentation

• When documenting a leak check, be sure to write the test results the appropriate amount of times (ie: You must prove you ran it on the entire system)

– Example: two stage system = 2 documented results

• When documenting a leak check using PSI, be sure to document the initial tank pressure, and document the “start” pressure after bleeding the system by a minimum of 10 PSI.

Important Takeaways - Documentation

• Regulator Date Codes are very important, if you can’t see it/find it…notate that in comments section

• DOT Cylinder Requal Dates are very important

– Notate if it was a 5 year Visual or put the date of manufacture if it’s within the first 12 years

Important Takeaways - Documentation

• Jurisdictional Accounts

– “check unknown” if it is indeed “unknown”

– See packet

• One printed per location

P3 - System Operating Tests

Analysis of leak checks, pressure tests, flow tests, and lock-up tests

• Was sufficient pressure maintained?

• Was the test duration sufficient?

• Was the initial tank pressure reduced by a minimum of 10 PSI prior to performing the leak check (PSI only)?

P3 - Technician Inspection Reporting

• Are my technician results in line with company expectations?

• Do my technicians understand how each form should be filled out?

• Are my technicians recording information correctly?

• Which technicians need follow-up?

Questions

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[Organization]

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