refrigerator

[bvansnell]

Glenn:

I would guess that there is no clear regulation about running propane refrigerators while driving because of the lack of consensus about the danger, except in obvious cases where an open flame is not a good idea, such as at a gas station. There is lack of consensus because there have not been enough accidents, despite the risk. There are plenty of head on collisions which proved that seat belts are a good idea so we have a regulation for that, but even that took a long time to catch on. In the absence of clear regulations I think the reasonable thing for us to do about running propane refrigerators while driving is to consider the risks and make an informed decision we can live with. Several people have pointed out on other forums that smaller refrigerators which can run on 12 volts while driving provide an easy solution for some people to reduce propane risk. Works for me.

[GaryH]

We have always traveled with the propane off. Even on the hottest days in the interior, the insides of the fridge was still cool at the end of the day. It works like a big cooler. It also helps to have a 2l jug full of ice in the freezer part. It's never been a problem on the ferries either. I'll see if what i just said re the ferries is true in a couple of weeks when we go over to Haida Gwaii (6 hr. trip).

[gbaglo]

Hi Glenn:

Your question was forwarded to the Inspector Education and Public Awareness Division of the Transportation of Dangerous Goods (TDG) Directorate within Transport Canada for response.

The answer is yes, under the Federal Transportation of Dangerous Goods (TDG) Regulations the refrigeration system may be used while the RV trailer is in transit. However, we suggest that you contact the province in which you intend to operate your vehicle to verify if they have any additional requirements. For instance, you may not be able to operate your system in a tunnel or you may be limited to two cylinders. Also, you may face other limitations when you’re on a ferry. Finally, we suggest that you verify with your trailer manufacturer to verify their position on this subject.

Here is some background information that you may find useful.

The Transportation of Dangerous Goods (TDG) Regulations are comprised of 16 Parts and 3 Schedules and can be viewed by using the following link: http://www.tc.gc.ca/tdg/clear/tofc.htm

Most exemptions can be found in Part 1, between sections 1.15 to 1.48 and they are called "special cases".

Section 1.27 exempts dangerous goods (in your case propane) in a means of transport (RV trailer) from the TDG Regulations if the dangerous goods are required for the ventilation, refrigeration or heating unit that are necessary to maintain environmental conditions. However, you may wish to verify provincial legislation to ensure that there are no additional requirements prohibiting such an activity.

For your information, I have inserted section 1.27. Also, you may view it by using the following link: http://www.tc.gc.ca/eng/tdg/clear-part1-475.htm#sec127

1.27 Operation of a Means of Transport or a Means of Containment Exemption

(1) These Regulations do not apply to dangerous goods on a means of transport that are required for

(a) the propulsion of the means of transport and that are

(i) intended to remain on the means of transport until used, and
(ii) contained in a fuel tank permanently installed on the means of transport;

(b) the safety of individuals on board the means of transport;

(c) the operation or safety of the means of transport including, while installed in the means of transport and used or likely to be used for purposes related to transport, air bags, air brakes, flares, lighting, shock absorbers or fire extinguishers; or

(d) ventilation, refrigeration or heating units that are necessary to maintain environmental conditions within a means of containment in transport on the means of transport and are intended to remain with the units or on the means of transport until used.

(2) The exemption in subsection (1) does not apply to

(a) ammunition; or
(b) dangerous goods being delivered to a destination and from which a portion is drawn off during transport for propulsion of the means of transport.

Paragraph (b) is intended to exclude from this exemption dangerous goods that are in transport on a means of transport and from which a portion is used to propel the means of transport. An example is a tank truck delivering liquefied natural gas that uses part of that load of gas to propel the vehicle.

If you have any additional questions you may contact us at TDGTraining-FormationTMD@tc.gc.ca or you may contact a Transport Canada dangerous goods inspector in your region. They can assist you with any questions you may have. Below are the numbers for the 5 regional offices.

Atlantic Region 1-866-814-1477 or TDG-TMDAtlantic@tc.gc.ca
Quebec Region (514) 283-5722
Ontario Region (416) 973-1868 or TDG-TMDOntario@tc.gc.ca
Prairie & Northern Region 1-888-463-0521 or TDG-TMDPNR@tc.gc.ca
Pacific Region (604) 666-2955


Inspector Education and Public Awareness / Formation des inspecteurs et sensibilisation du public
Compliance and Response Branch / Direction de la conformité et mise en application
Transport Dangerous Goods (TDG) / Transport des marchandises dangereuses (TMD)
Transport Canada / Transports Canada
330 Sparks Street, 9th Floor / 330, rue Sparks, 9ième étage
Ottawa, ON K1A 0N5

TDGTraining-FormationTMD@tc.gc.ca

[escape artist]

Hi: gbaglo...Glenn Thanks for clarifying that!!! So it's Nationally yes unless Provincially no. YMMV but Local regs. may apply too. Alf
escape artist N.S. of Lake Erie

[Jim Bennett]

I heard back from the Yukon, and it is a go there too. It was a very short, but direct answer. So, AB and YK have replied as well as Transport Canada, still a few to go.

________________________


Mr. Bennett

Thanks for your question regarding use of propane while driving RV's. It is permissible to operate a propane refrigerator in an RV while in transit.

Linda Dixon
Executive Assistant to Minister Archie Lang
Minister of Community Services
Minister of Highways and Public Works
867 667-8643 phone
867 393-7400 fax
Linda.Dixon@gov.yk.ca

[Jim Bennett]

It seems I made someone in Saskatchewan do a bit of work, but their reply too indicated they could find nothing on the books that says you can't use propane while traveling in an RV.

_________________________________________

Hi Jim

I contacted the Federal Dangerous Goods office and they told me that Section 1.27(d) applies to your situation

1.27 Operation of a Means of Transport or a Means of Containment Exemption

(1) These Regulations do not apply to dangerous goods on a means of transport that are required for

(a) the propulsion of the means of transport and that are

(i) intended to remain on the means of transport until used, and

(ii) contained in a fuel tank permanently installed on the means of transport;

(b) the safety of individuals on board the means of transport;

(c) the operation or safety of the means of transport including, while installed in the means of transport and used or likely to be used
for purposes related to transport, air bags, air brakes, flares,
lighting, shock absorbers or fire extinguishers; or

(d) ventilation, refrigeration or heating units that are necessary to maintain environmental conditions within a means of
containment in transport on the means of transport and are intended
to remain with the units or on the means of transport until used.

As for using the propane while traveling, we can't find anything in legislation that says that you can't have the refrigerator operating on propane while traveling. Normally you would switch the fridge over to electric / battery power before moving.


If you have any more questions, please let me know


Annette O'Neill, Investigator
Transport Compliance Branch
Ministry of Highways and Infrastructure
Saskatoon, SK
(306) 933 - 5381 Phone
(306) 933 - 5276 Fax

Your day may not be good, but there is something good in everyday that you can look for

[Hokie Escape]

Originally Posted by Jim Bennett

I heard back from the Yukon, and it is a go there too. It was a very short, but direct answer. So, AB and YK have replied as well as Transport Canada, still a few to go.

________________________


Mr. Bennett

Thanks for your question regarding use of propane while driving RV's. It is permissible to operate a propane refrigerator in an RV while in transit.

Linda Dixon
Executive Assistant to Minister Archie Lang
Minister of Community Services
Minister of Highways and Public Works
867 667-8643 phone
867 393-7400 fax
Linda.Dixon@gov.yk.ca

Just don't forget to turn it off when you pump gas!

[Jim Bennett]

From PEI.
It seems to be unanimous so far. Still, common sense should always prevail where the open flame could be a concern.

_____________________

Good Morning Jim:
Prince Edward Island subscribes to the Federal Transportation of Dangerous Goods Act and Regulations.

To address your question, recreational vehicles can operate on the highway with the propane valve open (fridge operating), with the exception being while on a car ferry. While on a car ferry, the propane valve must be in the closed position.
Hope this answers your question.

best regards,

Doug MacEwen
Safety Coordinator
Highway Safety Division
Department of Transportation
and Infrastructure Renewal
(p)902-368-5219
(f) 902-368-5236

[gbaglo]

Given how long this issue has been discussed on web forums with no conclusion, it seems it has been almost too easy to get an answer from authorities.

baglo

[Jim Bennett]

I have to wonder if people even tried, or just went by what they had heard here or there. I have not heard from any other provinces yet though.

[bvansnell]

This investigation has turned up some interesting pieces of information:

1. Most (all?) provincial regulations seem to permit propane refrigerators to be run while traveling, except while fueling or on ferries, where propane must be shut off at the tank
2. Transportation of Dangerous Goods (federal) does not seem to apply to use of refrigerators while traveling -- they are exempt from this regulation
3. Guidelines from some authorities are inaccurate or misleading -- for example the Propane Association of Canada says that in most provinces propane refrigerators cannot be run while traveling, and BC Travel says that TDG does apply to propane refrigerators, so it is no wonder there is some confusion.

If we want to add more clarity, perhaps we can ask the Propane Association of Canada and BC Travel to amend their guidelines.

4. Regulations spell out whether it is permitted to use a propane refrigerator while traveling. Since there is still a hazard in running propane while traveling, some people may still choose to not run a propane refrigerator while traveling, and there is nothing wrong with that.

[escape artist]

Hi: All... "Adding clarity" could be like poking a hornets nest!!! You might get BIT!!! Alf
escape artist N.S. of Lake Erie

[Jim Bennett]

Brian, it seems that all places that say that it is not allowed are either sites that offer hints or produce guidelines, where it is really the opinion of the writer, not really what is written in law.

I have not noticed at a fuel station where it has said to turn off propane while refilling. Is this common, and I just am not paying attention. This can happen . It would be a real reach for a dense enough vapour cloud from the pump nozzle to reach a flame in an RV. It would likely dissipate real fast unless indoors. I would also think sparks from the the starter motor, or even static charges would be of more concern.

[Jim Bennett]

I heard back from New Brunswick late last week. They are a little late to reply, but there are a couple provinces who still have not.

__________________________________________________ _____________

Good Afternoon

In response to the inquiry concerning the Transportation of Dangerous Goods Act, transporting propane on a recreation vehicle it is exempt from this Act as long as the propane is contained in a cylinder not greater than 46L in capacity and that the total quantity does not exceed 150 kg.


I hope this is of some help

Regards


Alan Killam
Licensing Officer
Motor Vehicle Branch
Tel506) 453-2410
Fax506) 453-7455
E-Mail:alan.killam@gnb.ca

[Hokie Escape]

'course, they didn't say if the propane was on or off (not trying to cause trouble or anything ... mine is on if I'm going any distance and it's hot outside ... off if it's a "not too far" trip and it's not too hot).

[Jim Bennett]

Dan, I had asked them all the same question, was it permissible to operate the propane refrigerator while in transit.

On this past 5 day trip, I traveled up to 6 hours at a time, and never ran the fridge on propane. It was cool enough out that the trailer never got too hot at all. When I got home, things were still very cool, not real cold, but this was also because the fridge was much emptier than when taking off.

[Roger C H]

This guy places cold packs in his freezer when powered, and in the refrig when not powered:

http://www.fiberglassrv.com/files/checklist8.pdf

[Jim Bennett]

Holy crap, that is quite the check list, maybe just a wee bit overboard, no? Most of it is kinda obvious. It is like someone I know who will make a todo list up, and include stuff he has already done because it looks more impressive.

The cold pack idea is a good one, but it is not really necessary to move them unless you have a separated freezer compartment, and all the Escape ones have the freezer section inside the refrigerator unit.

edit: In hind sight my post appears a bit harsh, I meant no ill intent towards the person who wrote the list.

[escape artist]

Hi: All...Our trip to Indiana was the first time I've tugged with the fridge running on propane!!! It was sooo hot and time spent in Mary Maxims wool mart shop, plus Wallow Mart for essentials, made the trip longer than expected!!! I must say I didn't notice a difference so I don't know if the fridge stayed lit or not. I do know the garlic sausage I brought made it smell . Alf
escape artist N.S. of Lake Erie p.s. If you don't think you need A/C in your trailer don't visit Shipshewana Indiana in the summertime!!!

[Sandra L]

Would it be easier to run the fridge on the battery when driving, then unplug the connection to the car when stopped temporarily? I would imagine that if it wasn't opened, everything would be OK for an hour or two. And as there is supposed to be a visual check and testing prior to take-off, then the unplugged connection shouldn't be forgotten. Has anyone utilized that methodology?