Through the fall of 2026, the Technical Standards and Safety Authority is on track to launch a dedicated licence for the trucks that dispense diesel and gasoline straight into vehicles and equipment on a customer's site. The activity has been routine across Canadian fuel marketers for years; what changes is the regulatory frame around it — a discrete rule set inside the Liquid Fuels Handling Code, a per-truck-owner licence with an annual fee, and a written record of what the truck has to carry and where it can park to dispense. This article is the southwestern Ontario operator's plain-language reference, with primary sources and the draft-versus-final status of every number flagged.
If you operate a yard, a job site, or a fleet in southwestern Ontario and you have a fuel truck come to you instead of sending your drivers to a pump, this article is the regulatory chapter of how that service works — and how that chapter is about to be rewritten.
A short version, before the detail: the Technical Standards and Safety Authority — TSSA, the Ontario authority that regulates fuel-handling under the Liquid Fuels Handling Code — has consulted on a new appendix to that code, Appendix I, that gives mobile fuelling its own dedicated rule set for the first time. A second consultation paired with it proposes a discrete annual licence for the trucks that conduct the activity. The two pieces together, after consultation closed in early 2026, are on track for adoption with a licensing launch anticipated in fall 2026.
The activity itself is not new. On-site refuelling — sometimes called wheel-to-wheel or wet-hosing — has been part of how southwestern Ontario fleet, construction, and agricultural operators have run for decades. What changes this fall is that the activity gets its own named place in Ontario's regulatory map, with a written equipment list, written setbacks, and a per-truck-owner fee.
The numbers and clause references below are quoted from TSSA's published draft of Appendix I, accessed through the Environmental Registry of Ontario notices listed in the source blocks. Draft status applies throughout. The final adopted text may differ from what is quoted here; the proposed $652 annual fee may also change with inflation adjustment between consultation close and licensing launch. The article will be updated as adopted text lands.
Appendix I is a new section added to the Liquid Fuels Handling Code — the code TSSA enforces under Ontario Regulation 217/01 — that covers a single activity: the dispensing of fuel from a highway tank directly to a vehicle or, in a narrow case, to a watercraft that cannot be fuelled at a marina. That is the regulatory definition. In ordinary usage, this is the truck that pulls up to the yard at 5 a.m. and fuels the fleet before the drivers arrive.
The framing matters for one reason: the definition explicitly names licensed vehicles. Whether the discrete Appendix I licence extends to operators who exclusively dispense into off-road construction or agricultural equipment is the open ambiguity in the consultation text — those operations are governed by the broader Liquid Fuels Handling Code dispensing rules in any case, and Appendix I's setbacks, equipment, and training requirements apply to them, but the licence itself may or may not be required when there is no licensed vehicle in the picture. This is a known issue that industry participants are asking TSSA to clarify before licensing opens.
The two consultations that brought the appendix forward:
Both notices are public on the Environmental Registry of Ontario and remain the citation roots for everything below.
The licensing piece is the part most operators and fleet managers will register first. The headline numbers, as drafted:
The fee is per-owner of the dispensing highway tank, not per-truck and not per-customer. An operator that runs more than one tank truck applies once at the company level, under the current drafting; the question of whether multi-depot operators with separate corporate structures apply per depot or at the group level is one of the items industry has raised through the consultation responses.
The proposed audit cycle of three years is conventional for TSSA-licensed activity in adjacent categories — Private Fuel Outlets sit on a similar inspection-and-audit cadence under O. Reg. 217/01. The Appendix I licence, in other words, is being slotted into a workflow TSSA already runs, not invented from scratch.
What the licence does not change is the underlying compliance frame. Highway tanks were already subject to CSA B620 construction and inspection, federal Transportation of Dangerous Goods rules, the requirement for an Emergency Response Assistance Plan filed with Transport Canada, and Ontario's own highway-tank registration under O. Reg. 217/01 section 10.2. Appendix I sits on top of that frame; it does not replace any of it.
The substantive part of Appendix I that customers will notice the most quickly is the new prescriptive equipment list. Where the previous frame relied on general "good practice" language and the spill-response sections of the parent code, Appendix I writes the kit down to the number of pads.
| Item | Requirement | Clause |
|---|---|---|
| Fire extinguisher | Minimum 80-B:C rated | I.2 |
| Spill kit | 20 hydrophobic 45 × 60 cm pads, 2 spill socks (1 m), 5 disposal bags, 16 kg granular non-silica hydrophobic absorbent, 1 m × 1 m drain cover, dike putty | I.3 |
| Nozzle | ≤ 25.4 mm (1 in) with automatic shutoff; operator within arm's reach during transfer | I.4 |
| Hose | ≤ 61 m (200 ft), with a storing mechanism | I.5 |
| Beacon light | Operating during fuelling | I.6 |
| Anti-siphon pump | Required | I.7 |
| No-smoking signage | 10 cm symbol, displayed front and rear of the dispensing vehicle | I.8 |
A note for anyone who has worked with US mobile fuelling specifications under NFPA 30A: a breakaway coupling is not explicitly required by name in the draft Appendix I. This is a difference from the US-side regime and is worth flagging for any cross-border operator or any internal training program that was modelled on the NFPA frame. If the final adopted text introduces a breakaway requirement, the truck-side change is straightforward; the gap is in the draft language as currently written.
The customer-side implication of the equipment list is short and is the reason the list is worth quoting in this detail: the truck arrives kitted to this list as a regulatory requirement, and the customer provides none of it. The 80-B:C extinguisher, the prescribed pads, the drain cover, the signage — that package travels with the truck on every visit. A customer onboarding question that sometimes comes up is whether the yard needs its own spill kit for the dispensing activity; the answer under Appendix I is no, the regulated kit is on the truck.
The setbacks under Clause I.9.1 are the part of Appendix I that customers will notice on the second visit, when the driver positions the truck for the dispensing operation rather than for the drive-in. As drafted, dispensing is prohibited:
The 30 m setback from a watercourse is the longest and the one that matters most in rural southwestern Ontario, where a yard, a barn, or a job site can sit close to a tile drain, a county ditch, or a tributary. A tile drain that runs into a watercourse counts as a pathway under Ontario's spill regulations even when the spill itself does not reach surface water — that is a different rule (under the Environmental Protection Act Part X and Ontario Regulation 675/98), but it interacts with Appendix I in practice because the setback is the first line of defence and the EPA reporting trigger is the second.
The 3 m property-line and 4.5 m building-opening setbacks are the ones most commonly violated in practice on tight urban sites — downtown London, central Kitchener, dense suburban industrial parks where the yard footprint is small. On those sites, the setback question should be assessed at customer onboarding, before the first scheduled visit, because the fuelling position may need to move from where the equipment is naturally parked to a position that satisfies the geometry.
Clause I.9.2 provides a relaxation for the property-line, building-opening, and ignition-source setbacks if three conditions are met: the operator carries a spill pad on their person, uses an automatic-shutoff nozzle, and limits flow rate to 38 L/min for gasoline or 120 L/min for diesel. A storm or sanitary sewer cover within 3 m of the fill position is also required. The relaxation is the practical mechanism that lets the activity continue on tight urban sites; the unmodified setbacks would prohibit dispensing in most urban yards otherwise.
One of the structural features of on-site refuelling — and a reason the activity exists as a separate service line rather than as a variant of bulk delivery — is the regulatory load split. Appendix I does not change the split; it codifies a piece of it more explicitly than the previous frame did.
The marketer — the operator of the highway tank — carries:
The customer — the operator of the yard or site where dispensing happens — carries:
What the customer specifically does not need to hold, simply because on-site refuelling happens on their property:
The customer-side simplicity is one of the structural reasons on-site refuelling is the right answer on a yard that does not want to take on a Private Fuel Outlet's compliance load. A stationary tank above the 5,000 L Ontario Fire Code threshold puts the regulatory weight squarely on the customer's site; on-site refuelling keeps it on the marketer's side of the gate.
Clause I.14 of the draft Appendix I requires spill notification to the TSSA Director at 877-682-8772. That number sits alongside, not in place of, the notification obligation that has been on the books in Ontario for years under the Environmental Protection Act.
The EPA Part X reporting trigger is unchanged: a spill that has caused or is likely to cause an adverse effect on the natural environment, on property, on health and safety, or on the use and enjoyment of property must be reported "forthwith" — immediately upon knowledge — to the Ministry of the Environment, Conservation and Parks. The number is the Spills Action Centre, 1-800-268-6060, 24 hours a day, 7 days a week.
The two notifications are independent. A call to the Spills Action Centre does not satisfy the TSSA notification, and a call to TSSA does not satisfy the EPA obligation. A spill that meets both triggers requires both calls — and, under EPA section 92, also notification to the local municipality and to the property owner.
There is no minimum litreage below which a spill is non-reportable under EPA Part X. A 20 L release into a tile drain is reportable because the pathway is the trigger, not the volume. A 1,000 L release fully contained inside an intact secondary-containment dike, with no pathway to soil or water, is technically not reportable, though good practice is to report and document it anyway. The TSSA Fuels Safety notification carries its own volume thresholds — 100 L in a restricted-access area, 25 L in a public-access area — which apply alongside the EPA pathway trigger.
The Auditor General of Ontario's 2021 Value-for-Money Audit: Hazardous Spills — restated in the 2023 Annual Follow-Up, Section 1.21 — found that between 2016 and 2020, 3,746 of 40,349 reported spills, or about 9%, were not reported until the following day, and 505 spills took more than 10 days to report. Late reporting is itself a regulatory offence under EPA section 92. The practical instinct that the call comes first and the documentation follows is the right one.
The driver's role under Appendix I is to stop the source, contain with the truck's prescribed spill kit, make the notification calls when the thresholds and pathways trigger them, and document the event. The customer's role is to cooperate on site access, provide any information needed for the call, and not to interfere with the response.
Three Ontario instruments touch the activity at once, and it is worth naming where each one applies so that "the regulation" doesn't become a single ambiguous reference.
Ontario Regulation 217/01 — Liquid Fuels Handling is the parent regulation. It is the instrument that gives TSSA the authority to enforce the Liquid Fuels Handling Code, including the new Appendix I. The retail mobile fuelling activity sits within its scope, and the new licence is a creature of the same regulation.
The Liquid Fuels Handling Code, LFHC-17, is the document the regulation adopts and enforces. Appendix I is a new section of that document. The existing sections of LFHC continue to apply — the dispensing rules, the tank construction rules, the installation requirements — and Appendix I sits as a dedicated chapter for the mobile-dispensing case.
The Ontario Fire Code, O. Reg. 213/07, governs the customer's site itself in a general sense. Its definition of a "fuel-dispensing station" is narrow — it captures fixed equipment, not a visiting mobile truck — so the dispensing activity on a customer's yard is largely deferred to the Liquid Fuels Handling Code under TSSA's jurisdiction. The Fire Code still applies to the customer's site in the general sense: no smoking, ignition-source control, fire department access, and the secondary containment threshold for any stationary tank the customer does keep on the property.
The practical implication for an operator who has been navigating these instruments separately is that Appendix I clarifies which body of rules governs the mobile-dispensing case. The previous frame was a patchwork of LFHC dispensing language, Fire Code general provisions, and the TDG transport rules; the new appendix gathers the dispensing-specific rules into a single named chapter.
The two ERO notices closed in early 2026 with a number of substantive comments from industry, trade associations, and individual marketers. The questions that came up most often and that are worth tracking through the period between consultation close and adoption:
None of these are reasons to expect Appendix I to change in its substantive structure between draft and adoption. The clauses on equipment, setbacks, training, and notification are written tightly enough that small numerical changes are more likely than structural ones. The point of tracking the consultation responses is to know which numbers may move and which will not.
The activity is not changing this fall; the regulatory frame around the activity is. The truck that pulls into the yard at 5 a.m. in November 2026 is the same truck that pulled in at 5 a.m. in November 2025 — kitted to the same equipment list (which has always been good industry practice and is now codified), arriving with the same driver certifications (TDG, Class AZ), dispensing under the same setback discipline (which was operating-norm and is now written).
What is new for the customer is:
What is not new is the underlying split: the marketer carries the regulated load; the customer carries access, ignition control, and cooperation. The Appendix I licence is the most visible piece of this fall's change, but it is the one with the smallest customer-side implication. The customer-side implications live in the setbacks and in the spill notification path, both of which were good practice already and are now written down.
For an operator who is choosing between on-site refuelling, cardlock, a stationary yard tank, or a fuel cube, the Appendix I change does not push the answer in any particular direction. It tightens the description of what one of the four options is. The decision drivers — fleet size, equipment mix, daily volume, yard footprint, where the trucks are at 5 a.m. — sit in the same place they did before. The on-site refuelling page walks through how to read those drivers for a southwestern Ontario operation; this article is the regulatory chapter behind it.
Adopted text of Appendix I is expected to publish before the licensing launch in fall 2026. When it does, the quoted clauses above will be reconfirmed against the final language and any divergence will be flagged in an updated version of this article. The $652 fee will also be reconfirmed at that point, including any inflation adjustment.
The Environmental Registry of Ontario continues to publish updates on both ERO notices, including responses to consultation, regulatory impact analysis, and any subsequent decision documents. TSSA's own announcements on the licensing portal go out through the TSSA Client Portal and the Fuels Safety bulletin list, both of which are the right channels to watch through summer 2026.
If you are receiving on-site refuelling service in southwestern Ontario, no action is required on the customer side ahead of the fall launch — the licensing obligation sits with the marketer, and the equipment, setback, and notification rules either describe what has already been good practice or are short customer-side adjustments at the fuelling position. The right time to walk through what changes at your specific yard, if anything does, is the next site visit.
A named rep takes the call, not a queue. Tell us about your operation — we’ll sort coloured diesel, clear diesel, propane, and DEF in one conversation.
Standing routes across nine regions. Same rep year-round; off-hours emergency dispatch through the same number.
Marketing Intelligence by Candid