Sale of Propane Vapour on the Basis of Measurement
Measurement Canada (MC) has become aware of an industry practice in which organizations are using meters to measure propane vapour retrieved from a propane tank when selling propane to more than one customer. Some organizations are converting this measured volume into liquid litres and issuing billing invoices for propane supplied on the basis of liquid litres. Additionally, recent metering-related dispute investigations have established that some propane retailers may not be:
- using approved and verified meters for this measurement;
- maintaining required records; or
- effectively implementing many of the requirements of the Electricity and Gas Inspection Act (EGIA)and the Electricity and Gas Inspection Regulations (EGIR).
Legal Metrology Requirements
Organizations selling gas (propane vapour) on the basis of measurement are responsible for complying with the requirements of the EGIA and implementing processes which support this outcome. In this regard, all the applicable documents are available on the MC website. Where clarification is required, organizations are advised to consult with the local MC office.
It should be noted that the volume-based metering units recognized under the EGIA for the sale of a gas in Canada are required to be established at standard conditions. Under these conditions at standard pressure and standard temperature, propane is in a gaseous (vapour) state. Although the charge for the gas supplied shall be based on the permissible units of measure (i.e., standard volume), organizations may also state the liquid equivalent as supplementary information.
Organizations that utilize a meter to measure propane in its vapour state are required to be registered as contractors under the EGIA. The meters used for establishing the basis of a charge for propane vapour supplied are required to comply with all applicable requirements of the Act (i.e., type approval, verification, reverification and sealing).
Where an organization is found to be in non-compliance with the applicable requirements, it will be required to develop and implement a corrective action plan to achieve compliance. In recognition that many organizations may not have been previously aware of the statutory requirements in this regard, and that corrective action plans will need to be implemented in an efficient and cost-effective manner, propane vapour retailers are being provided with a corrective action implementation period to effect the necessary changes.
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