Anhydrous ammonia industry left out of consultations on Transport Canada’s changes to tank design and testing
With the implementation date for new NH3 tank regulations vague and parts of the new rules in abeyance, it could be a long time before Canadians are able to buy new tanks.
“There currently is no design and construction standard for ammonia tanks used for field application. There will be no new ammonia tanks constructed or imported in Canada until Transport Canada resolves this,” says Delaney Ross Burtnack, chief executive officer of the Canadian Association of Agri-Retailers (CAAR).
Transport Canada, in conjunction with the Canadian Standards Association (CSA), decided in 2012 to make major changes to regulations governing all new and existing NH3 tanks in Canada.
The problem was that the CSA B620 Technical Standards Committee didn’t tell the anhydrous ammonia industry. CAAR wasn’t informed about the proposed changes until Glenn Dickson, an independent consultant on the technical standards committee, warned it in an email in 2015.
Although CSA and Transport Canada are independent of one another, Dickson said Transport Canada is responsible for all movement of hazardous goods by road and calls the shots on the committee.
“The fertilizer sector was not part of the discussion leading to the 2012 decision. Representatives were not present for the vote and are not believed to have been consulted,” says Burtnack.
“So the Canadian Association of Agri-Retailers and Fertilizer Canada joined the committee late in 2015. We quickly saw that our concerns were justified because on Jan. 26, 2016, we uncovered pending changes, which would have a significant impact on the anhydrous ammonia industry.”
TC51 is a standard for the design and manufacture of nurse tanks and applicator tanks. Transport Canada struck it from the code and has not yet issued a replacement. Without a building standard, new tanks cannot be constructed in Canada or imported from the United States.
“That presents a huge issue for anyone looking to purchase a new tank this year. Manufacturers don’t have a standard they can build to and which would be approved by Transport Canada for ammonia, so obviously they can’t build new tanks.”
Burtnack says another issue is that the testing cycle has tightened up for existing tanks. It’s being changed from a five-year interval to a three-year interval. These are the hydrostatic tests where all NH3 is removed, the tank is filled with water, then pressurized to 150 percent of maximum allowable working pressure. It is done to ensure the integrity of the tanks. As well, the detailed visual inspection has dropped from three years down to annually.
“All this came as a shock to the industry. We assume this decision was made (by Transport Canada) with the idea of increasing the safety of these tanks, but it didn’t make sense with respect to what we were seeing in the field. The tanks appeared to be performing well in terms of safety. The industry was not consulted in any of these 2012 decisions.
“We presented Transport Canada with our data showing these tanks have a pass rate well over 99 percent in the hydrostatic tests on the five-year cycle. So it was a tremendous surprise they wanted to increase the frequency. In gathering our data, we worked closely with Fertilizer Canada and ammonia retailers.”
Burtnack estimates 10,000 to 12,000 NH3 tanks exist in Canada, 95 percent of which are approved by the ASME (American Society of Mechanical Engineers).
Canada’s TC51 regulations imposed further criteria beyond the ASME requirement. Canadian standards are geared toward highway travel, requiring components such as lighting and rear crash protection.
Whether it’s built in Canada or the U.S., every Canadian NH3 tank since 1991 must have a Canadian registration number designating that it meets the criteria.
“We think the regulations that had been in place were doing a great job. We have a number of tanks operating since the 1970s. They’ve been tested according to the TC51 standards, and they continue passing.
“The problem right now is manufacturers do not have a new standard for design and construction. The government has not yet established what the TC51 replacement standard will be. Because TC51 pertains to a highway transport tank, it doesn’t always work well as an application tank in the field. So whatever new standard they develop must address both uses.”
To compound the situation, no implementation date has been announced. The standards adopted in 2012 without industry input have been published, but they haven’t yet been adopted as Transportation of Dangerous Goods Regulations. Burtnack hopes this will happen early in 2017, but there’s no guarantee.
“The committee recognizes there’s been a significant oversight and they’re working through it.”
CAAR plans to meet with the technical standards committee Jan. 17-18 .