Directive: Filling of propane cylinders at unattended card/key lock only locations



Reference number
Revision Number
Revision 2

This Directive is being issued by a provincial safety manager pursuant to section 30 of the Safety Standards Act.

General details

This directive is issued to clarify the requirements for propane dispensing at card/key lock only locations.

The filling of propane cylinders by unqualified individuals at card/key lock only locations is a hazardous practice and is not permitted. All propane cylinders (including forklift, industrial truck and ice maintenance equipment fuel cylinders) must be filled by qualified individuals utilising safe filling practices and dispensing equipment approved for cylinder filling.

Card/key lock only installations were designed for dispensing propane to automotive propane tanks only and are not equipped for cylinder filling. Cylinder filling is not permitted at automotive card/key lock only installations.


CSA B149.2 Code - means the Propane Storage and Handling Code

Cylinder - a container designed and manufactured in accordance with a cylinder specification

authorized for the containment and transportation of propane under the Transportation of Dangerous Goods (TDG) Regulations of Transport Canada.

Float gauge - a variable-liquid-level gauge constructed with a float inside the container resting on the liquid surface that transmits its position to a pointer and dial outside the container.

Fixed –liquid-level gauge - a type of liquid-level gauge that uses a small bleed valve and is

designed to indicate when the liquid level in a container being filled reaches the point at which

the gauge or its connecting tube communicates with the interior of the container.

Filling density - the percentage ratio of the weight of the propane in a container to the weight of water the container will hold at 59°F (15 °C).

Specific details

The Gas Safety Regulation (the Regulation) and CSA B149.2 Code requires any individual transferring propane from a tank and dispensing it to another container (tank or cylinder) be trained on the operation of the dispensing equipment and safe filling practises.

Section 28 (8) of the Gas Safety Regulation states that an individual must not transfer liquefied petroleum gas from one container to another unless the individual has successfully completed a training course that has been approved by a provincial safety manager and holds a certificate issued following that training course.

Clause 5.2.1 of CSA B149.2- requires any person transferring propane to hold the appropriate certificate recognized by BC Safety Authority and Clause 5.2.4 stipulates that the owner of a card/key lock only refuelling outlet is responsible to ensure that any individual operating propane dispensing equipment at a card/key lock only facility complies with the certificate requirements or restrictions.

Clause 6.4.2 of CSA B149.2requires a cylinder to be filled by weight or by volume when the cylinder is equipped with a fixed-liquid-level gauge designed for the cylinder.  Float gauges or dispensing meters are not to be used to determine maximum cylinder filling density.

Filling of cylinders at card/key lock only installations is an unacceptable use of an automotive card/key lock system. Automotive card/key lock only systems are equipped with automotive propane dispensing equipment for fuelling vehicle tanks only.  Automotive card/key lock only systems do not have measuring devices to prevent overfilling such as the equipment needed for filling cylinders by weight. Individuals that have been trained and qualified on dispensing propane, from a card/key lock only system for vehicles only, do not have the additional mandatory certificate of qualification for the dispensing of propane into cylinders.

Safety risks when filling cylinders at automotive card/key lock only facilities may include; over filling, an uncontrolled release of propane from cylinders that are not equipped with double back check valves, the maintaining of required clearances to potential sources of ignition, cylinders being filled in unventilated conditions and unsecured cylinders  overturning or upsetting during filling. 

All individuals filling propane tanks on vehicles shall have completed a training course on the use of automotive propane dispensing equipment that has been approved by a provincial safety manager and hold a certificate of course completion. The holder of a certificate must at the request of a safety officer produce the certificate or appropriate wallet card.

The owner of a card/key lock only automotive refuelling facility shall ensure that all individuals having access to the refuelling facility have completed a training course approved by a provincial safety manager and hold a certificate of course completion. 

The owner of a card/key lock only automotive refuelling facility shall ensure that prominently displayed “NO CYLINDER FILLING” signs are installed at all entrances to the card/key lock only facility and within the facility such that they are visible from the operating position of all propane dispensing equipment. Lettering shall be a minimum of 4 in (100 mm) high and shall be red on a white background. Symbols shall be a minimum of 7-1/2 in (300 mm) in diameter. Effective: September 17, 2015, BCSA will enforce this requirement if signage is not found at card/key lock only installations.



Brad Wyatt
Provincial Safety Manager, Gas 



Safety Standards Act
Gas Safety Regulation
CSA B149.2 - Propane storage and handling code