Regulatory Affairs
March 23, 2021

UPDATE – Federal: CPA pushing for modifications to cylinder requalification reports

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On February 18, 2021, the CPA announced that we had contacted Transport Canada (TC) after receiving reports from members that TC had been requesting information to provide 20lb cylinder requalification reports to new owners upon purchase of a container. (Read: Transport Canada request for cylinder requalification reports: Frustrating for CPA members.)

Members expressed their frustration to this new request from inspectors, stating that it is “beyond reasonable” for the public to keep a copy of a cylinder requalification report. TC indicated that it is not a new requirement, just that the enforcement was never part of their audits until recently.

While the requirement is reported to have been in the Transportation of Dangerous Goods Regulations (TDGR) for many years, members have indicated it has never been applied to 20lb cylinders and new application of this requirement is unrealistic without providing any added safety benefit.

Response from TC was that TDGR are written regulations applied generally to many chemicals, although it understands this specific requirement is “quite onerous”. TC also indicated that Part 5 of the regulation is currently under review, which may provide an avenue to include changes to this requirement.

In the meantime, TC has suggested bringing the concern back to CSA B339 to discuss amendments to the code, however, this would only satisfy half of the required process as the TDGR would still need to be modified.

It is interesting to note that this concern was also brought forward in 2010, however, TC indicates minutes of those meetings were not detailed as to what was decided during that review.

The CPA will continue to advocate for TC action to adapt the regulations to fit propane, while also bringing the request to CSA.

For any questions regarding this issue, please contact CPA Vice-President of Regulatory Affairs and Safety Robert Loenhart at


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