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Clearing Up the Misconception About Propane Installations and Permits in Pennsylvania

jar546

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For years, building officials in Pennsylvania, myself included, were taught that propane (LPG) installations inside buildings were exempt from permitting and inspections under the Propane and Liquefied Petroleum Gas Act (Act 61 of 2002). This belief, though widespread, was built on a misinterpretation that made no sense. Why would installations involving a flammable, combustible fuel gas like propane not require the same level of oversight as natural gas or electric systems? The answer is simple: they do. It’s time to put this misinformation to rest.

The root of this problem lies in how the Propane and Liquefied Petroleum Gas Act was taught, particularly by instructors in Pennsylvania. Section 15 of the Act preempts municipalities from regulating LPG facilities—defined as distributors, bulk plants, and industrial users—beyond zoning restrictions. However, this preemption applies only to external facilities and has no bearing on LPG appliances, gas piping, or related installations inside buildings. Despite this, many were incorrectly taught that building officials had no authority over propane installations, even within structures. This created widespread confusion and, more importantly, unsafe practices.

The Pennsylvania Uniform Construction Code (UCC) governs internal installations, including those involving propane. Whether it’s natural gas, electric, or propane, building code officials are required to permit, inspect, and regulate these systems. The Pennsylvania Department of Labor and Industry (PA L&I) clarified this issue to ensure consistency and safety statewide: the Propane and Liquefied Petroleum Gas Act does not exempt internal propane installations from UCC oversight. Any claim to the contrary is misinformation rooted in flawed instruction from the past.

This is a call to action for Pennsylvania’s building officials, plans examiners, and inspectors. It’s time to forget the misinformation of the past and get up to speed. Our responsibility is to ensure the safety and compliance of all systems inside buildings, and propane installations are no exception. Misunderstanding this issue has already caused enough confusion, and it’s critical to move forward with accurate information.

Let’s stop perpetuating outdated myths and reaffirm our commitment to public safety. Ensuring that propane systems are properly inspected and permitted is just as important as any other aspect of our work. The safety of the people who live and work in these buildings depends on it.
 
Since publishing the original article in December 2024, I’ve continued to encounter inspectors who still believe that propane systems inside buildings are exempt from permitting and inspection under the UCC. Some claim that Act 61 of 2002 removes this authority altogether, while others say they were taught early on that propane was “hands off” for building departments. Both claims are wrong, and it is time to confront this issue head-on again.

There is no language in Act 61 that prohibits code officials from inspecting interior propane systems. The act focuses on external LPG storage and distribution facilities. Section 15 of the act clearly preempts municipalities from regulating those facilities beyond zoning controls. It does not override or interfere with the Pennsylvania Uniform Construction Code as it relates to interior building systems.

Under the UCC, the International Fuel Gas Code is adopted by reference, and its scope is unambiguous: it applies to fuel gas piping systems, appliances, appliance venting, combustion air, and connections — regardless of whether the fuel is natural gas or liquefied petroleum gas. The code does not carve out an exception for propane, and neither does the state statute.

The Department of Labor and Industry has already issued clear guidance that internal propane systems are subject to the UCC. Inspectors certified in mechanical, residential mechanical, or building categories under §401.7 are not only authorized but required to inspect these systems. Failure to do so is a dereliction of duty, plain and simple.

The notion that inspectors cannot inspect propane piping or connections to appliances like water heaters, stoves, and dryers is not only incorrect, it’s dangerous. Propane poses the same risks as natural gas — and in many cases, greater risk due to its heavier-than-air properties and more volatile ignition characteristics. If anything, oversight of propane systems should be tighter, not more lax.

It is time for inspectors and code officials across Pennsylvania to stop repeating bad information that was taught years ago and start enforcing the UCC as it is written. Propane is a fuel gas. The UCC regulates fuel gas. If you are certified and working under the UCC, you are obligated to inspect these systems. There is no exemption. There never was.
 
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