Health and Safety
Executive / Commission
Local authority circulars
To: All Unitary and Island Councils; County Councils in England and Fire Authorities
For the attention of: Environmental Services / Trading Standards / Fire Authorities
This circular gives advice to Petroleum Enforcement Officers
1 The purpose of this circular is to advise Petroleum Enforcement Officers and site operators on the measures to control the fire and explosion risks when petrol is being dispensed into vehicle fuel tanks or portable containers at petrol filling stations. This circular updates and replaces the guidance given in PETEL 65/51 and 65/59.
2 The dispensing arrangements can operate in a variety of ways; from attended service, where site staff refuel customers' vehicles through to sites that are unmanned and where customers refuel their own vehicles without any on-site supervision or assistance from the site operator. Some filling stations now function on an alternating system where the site is operated as attended self-service at busy periods (i.e. day time and evening) and as unattended self-service during quiet periods when throughput is low (i.e. late evening and through the night).
1 The purpose of this circular is to advise Petroleum Enforcement Officers and site operators on the measures to control the fire and explosion risks when petrol is being dispensed into vehicle fuel tanks or portable containers at petrol filling stations. This circular updates and replaces the guidance given in PETEL 65/51 and 65/59.
4 Petrol should be dispensed only by means of dispensing equipment of an appropriate standard into the fuel tanks of internal combustion engines (i.e. on vehicles, motorbikes, boats, planes, mowers etc.) or into appropriately marked or labelled portable containers suitable for keeping petrol. The definition of a suitable container includes demountable fuel tanks and fuel retrievers as well as those containers defined by the Petroleum-Spirit (Motor Vehicle) Regs 1929 and the Petroleum-Spirit (Plastic Container) Regs 1982.
Note: The 1929 and 1982 Regulations do not apply to work activities. This means that an employer's risk assessment,
under the Dangerous Substances & Explosive Atmospheres Regulations 2002, may determine that containers of
a type and capacity different to those mentioned above are suitable for the storage (and transport) of petrol
in connection with a work process/activity.
5 Where portable containers are to be filled they should be removed from inside vehicles and be placed on the
forecourt and filled with the nozzle-operating lever held open manually. Containers should be securely closed
as soon as dispensing finishes. Pedestrian customers should be discouraged from bringing full containers into
the shop when paying for petrol.
6 As far as is reasonably practicable, persons under the age of 16 years should be denied access to petrol.
7 Engines of vehicles should be switched-off before dispensing starts. Dispensing equipment should be operated in accordance with the manufacturer's instructions (e.g. equipment designed to be operated by an attendant should be operated only by an attendant). Delivery hoses should not be kinked or stretched. After dispensing, nozzles should be firmly stowed in their housings to switch off metering pumps and dispensers or, in the case of centralised pump systems, to isolate hoses from sources of pressure. If appropriate, hoses should be draped to avoid damage by moving vehicles.
8 If any equipment develops a fault or if spills, leaks or other emergencies occur during dispensing, those operations should be stopped and the nozzles returned to their housings. The electrical supply should be isolated from faulty equipment. Dispensing should not be restarted until any faults affecting safety have been corrected or any incidents have been dealt with.
9 Irrespective of the mode of operation, forecourt attendants should not be under the age of 16 years and no one under the age of 18 years should be left in sole charge of a filling station.
Mobile Telephones
10 Generally mobile telephones are not designed and certified for use in explosive atmospheres. Their use can also create a serious distraction for people carrying out dispensing activities. Radio transmissions from individual mobile telephones are generally too low to induce dangerous electric currents in nearby equipment and the risk of incendive sparking from the battery is low, however, they should not be used in the hazardous areas that exist when actually dispensing petrol. Neither should they be used in the hazardous areas around the fill and vent pipes during petrol deliveries.
11 Rather than applying a total prohibition on the use of mobile telephones on petrol forecourts which has resulted in some anomalies and frequent abuse to staff, the following controls are recommended:
Mobile telephones should not be used by customers or forecourt staff whilst actually dispensing petrol into fuel tanks or containers;
During petrol deliveries mobile telephones should not be used on those parts of the site that have been designated as hazardous areas by the site operator or the driver;
Mobile telephones should not be used during other petrol handling operations or during the maintenance of petrol equipment unless a specific assessment shows the risks are negligible;
There is no need to restrict the use of mobile telephones, with respect to the safe keeping of petrol, at other times or in other areas of the forecourt. This includes in the shop, in motor vehicles parked on the forecourt or in other non-hazardous areas.
12 The use of radio equipment fitted on emergency vehicles and citizen band (CB) radios may create an ignition risk. These types of transmitting equipment do have a power out-put sufficient to induce dangerous electrical currents in nearby fixtures and they should not be allowed to be used at the dispensing points or in the vicinity of the road tanker when unloading. It should be noted that the radio equipment mounted on most emergency vehicles is under automatic interrogation from the base station. This means that radio messages are being received and transmitted without anyone speaking into a hand set. The Home Office has issued the emergency services with separate advice on the use of radios and CB equipment in the vicinity of filling stations.
Portable Credit / Debit Card Terminals
13 The introduction of high security chip and PIN credit/debit cards together with the requirement to provide equivalent services for disabled drivers has created a need for portable credit/debit card terminals to be used at the disabled driver's vehicle after it has been filled with petrol.
14 Portable credit/debit card terminals are not certified for use in explosive atmospheres. They may be used, however, on the petrol forecourt by trained attendants provided suitable procedures are established and adopted that will prevent the terminals from being taken into the temporary hazardous areas that will arise during petrol dispensing. The procedure will include the attendant ensuring that there are no petrol spillages in the area and that petrol is not being dispensed from any nozzles within 1 metre of where the terminal is to be used.
Management of the Forecourt
15 Whether the site adopts pre or post authorisation of the dispensers the site operator will need to ensure that proper supervision of the forecourt is achieved particularly during busy times or when the site is taking delivery of petrol or other provisions. In carrying out his assessment of the ability of staff to supervise the dispensing operations he will need to consider:
Appropriate staffing levels
Other duties expected of staff (ie. re-stocking shelves, sales, petrol deliveries) during times the forecourt is open for business.
Management of forecourt staffTraining of forecourt staff (see para. 17).
16 Where the forecourt layout gives rise to poor visibility of dispensers, additional methods of work will need to be introduced for the forecourt staff. It may be necessary to delay authorisation (or to cancel the pre-authorisation) of a specific pump until a temporary obstruction to vision has moved away or instructions may be given over the public address system for the customer to move to an alternative pump. When portable containers to be filled are out of the attendant's line of vision it may also be necessary to use the public address system to ask the customer to show the container, prior to filling, so that it can be identified as being suitable.
Training of Forecourt Attendants
17 It is a requirement of the Dangerous Substances and Explosive Atmospheres Regulations 2002 and the Management of Health and Safety Regulations 1999 to provide adequate training and relevant information for all employees involved in the storage and handling of any dangerous substances. It will, therefore, be necessary to identify the training and retraining needs of forecourt staff by an assessment of the risks relating to fire and explosion. Further general information can be found in Approved Codes of Practice6 to these Regulations.
18 Training in matters relating to the dispensing operation should include:
Procedures for activating and controlling dispensers;
Safe dispensing procedures;
Use of customer information systems, e.g. public address systems;
Safe filling of petrol containers;
Dealing with customers' enquiries on safety matters;
Spillage control and emergency procedures during dispensing including the practical use of the types of fire extinguishers provided;
Recognising the circumstances when it is not safe to authorise a dispenser and when pre-authorisation should be over-ridden; and
Understanding customer behaviour and unacceptable customer practices.
19 It is the responsibility of site management to instruct forecourt attendants not to authorise (or to over-ride the pre-authorisation of) a pump when a situation of poor visibility arises.
20 Spillages of petrol when dispensing activities are taking place are foreseeable events and control measures and equipment should be in place to deal with such occurrences. Experience has shown that spillages can be put into the following three general categories in the order of frequency: -
a. Blow-backs from the fuel tank or container when the liquid level is reaching full capacity. Due to the safety features designed into the dispenser nozzle, this type of spillage will normally only involve a small quantity of petrol; most of which will quickly evaporate on the forecourt surface;
b. A leak from a defective fuel tank of the vehicle being refuelled. This type of spillage can arise from the sudden and catastrophic failure of the fuel tank resulting in the full contents being discharged onto the forecourt. The quantity can be in the region of 50 litres if the failure occurs when the tank is full; and
c. The failure of a hose coupling or a leak from a hose that has been cut or stabbed by vandals. This is, potentially, the most serious type of leak as it can result in the customer being splashed with petrol. In a worst-case scenario, there is the possibility of a customer being 'showered' with petrol if, for example, there is a coupling or hose failure on a 'high hose' dispenser.
The types of spillages described in paragraphs 'a' and 'b' can be easily dealt with by trained staff using the dry sand or other absorbent material, which should be available. The likelihood of a customer's clothing or skin being contaminated with petrol in the circumstances outlined in paragraph 'c' should not be discounted. Staff should be trained in how to deal with such a situation and there should be facilities available for a customer to wash the affected parts of their body and remove contaminated clothing. Consideration should be given to keeping a supply of disposable cover-all suits for use by customers.
Attended Service Operation
21 Whenever an attendant service filling station is open for business, a trained attendant should be available to operate the dispensing equipment. The attendant should not allow customers to operate the equipment with or without supervision.
22 Trigger latching mechanisms are acceptable on petrol pump nozzles operated by an attendant. However, site operators should be aware that latched nozzles have been implicated in a number of forecourt fires. Static charge is able to build up on users if they let go of the earthed nozzle during dispensing and this can subsequently cause an incendive discharge when they make contact with the nozzle again to complete the transaction. Where trigger-latching mechanisms are installed the site operator should ensure that attendants are provided with, and wear, appropriate anti-static footwear whilst carrying out dispensing operations.
Attended Self-Service Operation (ASS)
23 At these sites control over the dispensing is exercised by one or more attendants located at a control point or points. The location and design of the control point should allow, as far as is reasonably practicable, the attendants a clear and unrestricted view of all the dispensers so that they can prevent unsafe practices and if necessary switch-off the dispenser, if for instance:
inappropriate containers are being filled with petrol, or containers are not placed on the forecourt when being filled with petrol (static discharge hazard);
sources of ignition are present (i.e. smoking, vehicle engine still running, radio transmitting equipment operating);
inappropriate use of the dispenser (i.e. devices being used to hold open the trigger mechanism on the nozzle, the hose being over-stretched/damaged due to the vehicle position; and
children (under 16) operating the dispenser or attempting to obtain petrol
Note: Latching mechanisms on nozzles should be removed or disarmed.
24 In practice the attendant will not always be able to observe all details of self-service operations even at well-designed sites. Observation of the nozzle actually being placed into the vehicle fuel tank or container will frequently be restricted because of the configurations of vehicles, dispensers and customers relative to the control point. The attendant often needs to make judgements of the customer's intentions based on what can be observed from the control point. What it is reasonable to observe from the control point will vary from site to site, from dispenser to dispenser, and from situation to situation and will not always include a complete view of various nozzle positions.
25 Knowledge that a customer is being observed from the control point is likely to ensure customer adherence to commonly accepted practices and instructions.
Other Aids
26 Mirrors may provide some improvement in vision at specific dispensers. Generally, however, their use will be restricted because the small and distorted image will not provide sufficient detail if installed with a total viewing distance (i.e. from control point to dispenser via a mirror) greater than about 10 metres. The effectiveness of a mirror to improve supervision can only be determined by practical trials at specific locations.
27 Supervision of the dispensing operation is likely to be improved as a result of a direct attendant service or by the presence of staff on the forecourt.
Use of Closed Circuit Television Equipment (CCTV)
28 CCTV should not normally be required at sites that are designed in accordance with accepted good practice to maximise the visibility of the dispensers from the control points. Such designs will include locating the control point so that an attendant can see the forecourt and dispensers clearly when no vehicles are present and also arranging the dispensers so they are aligned with the attendant's line of vision rather than at right angles to it. Additionally road tankers or other delivery vehicles properly parked for unloading should not obscure the view from the control point.
29 CCTV can be used as a supervisory aid at existing sites in order to overcome visibility problems at specific islands. For example CCTV may have applications in the following circumstances when alternative solutions have been explored and found not to be practicable:
When the dispenser cannot be viewed directly from the control point. For example, a building, car wash or a large stanchion obstructs the view; or
Large multi-hose dispensers are installed so that their long side is at right angles to the line of vision from the control point; or
Following change of use from attendant to self-service operation where the dispensers are not easily seen from the control point; or
For dispensers installed at the extremities of very large sites that cannot be easily seen because of their distance or angle of vision from the control point.
30 New or redeveloped sites that have been designed without adequate visibility of the dispensers will require CCTV as an aid to supervision. These sites include those where the control point is located at the rear of a convenience store and the presence of customers, goods on display or the distance of the attendant from the viewing panel restricts vision of the forecourt. The CCTV system will require high-resolution equipment providing sufficient definition so that the activities occurring at the dispensers can be clearly identified. In addition the monitors should be interlinked with the control panel so that each dispenser is automatically displayed on the screen before it can be authorised by the attendant. It is recommended that a touch-screen system be adopted so that the attendant has to look at the actual screen before authorising the pump.
Pre-authorisation of dispensers
31 In certain circumstances dispensers may be pre-authorised (i.e. removing the need for the attendant to authorise the dispensers for each transaction). The decision to operate the site with the dispensers pre-authorised, should only be taken after a risk assessment has been carried out and it can be demonstrated that the monitoring exercised by the forecourt staff will maintain the same level of vigilance as would be the case if the dispensers had to be authorised for each transaction. The attendants will still need to be vigilant to the customers' actions at the commencement of and during the dispensing activity. In order to restrict children from access to petrol and minimise misuse pre-authorised dispensers should only be activated by a credit/debit card payment facility.
32 Other additional control measures for pre-authorisation of dispensers include:
Limiting devices on each pump set to prevent the continuous operation for more than 3 minutes and a continuous outflow of more than 75 litres;
Removal of any latching mechanisms fitted to nozzles;
Readily accessible and conspicuous emergency pumps isolation switch. This may be of the 'push button' design or, if provided, interlocked with the door of an emergency cabinet. More detailed guidance on emergency isolation switches is given in clause 14.6.4 of the Blue Book3;
Risk Assessment
33 The decision to operate a site on an USS basis for the whole or part of the business hours must be preceded by a risk assessment. The risk assessment should be carried out on a site-specific basis and should be undertaken in two phases:
Phase 1 should be an assessment of the risks of damage being sustained to the dispensing and safety equipment by the actions of vandals and other persons of an unruly nature. Sites where vandalism has occurred or is likely to occur (if it is open for business without any supervision) should only be considered suitable for USS where effective control measures can be employed to deter damage to equipment.
Phase 2 should comprise a more detailed assessment that covers the following points:
a. The site's location to determine if any incidents arising during dispensing can be contained within the curtilage of the site.
b. The number and the position of the dispensers. The number of dispensers should not normally exceed two allowing up to four vehicles to be refuelled simultaneously (but see para c. below).
c. Identifying any additional measures to those listed in paragraphs 34 to 38 for sites where more than two pumps are required or where the throughput of fuels is high during the period of time that the site is in USS operation. Such sites will need special consideration to ensure that the control measures are adequate and the larger numbers of customers that will visit the site do not compromise safety. This may necessitate a trained person being immediately available to deal with any incidents that may arise.
d. The range and location of equipment/facilities and a response procedure to deal with foreseeable emergency incidents.
e. Proposed 'management' and 'engineered' control measures including those built into the installed equipment.
f. Road tanker deliveries, but only in respect of deliveries that may take place when the site is in USS operation.
34 Typically engineered control measures for unattended sites include: -
Limiting devices on each pump set to prevent the continuous operation for more than 3 minutes and a continuous outflow of more than 75 litres (or the equivalent monetary amount);
Removal of any latching mechanisms fitted to nozzles;
Adequate illumination of the dispensing area and the position(s) of the emergency equipment.
Restricting the sale of petrol to credit/debit card transactions only in order to limit access to children and minimise misuse;
Displaying a notice detailing the restrictions on the types of containers that can be filled with petrol.
35 Emergency equipment made available for customers to use when the site is USS operation will include the following items: -
Petrol pumps isolation switch. This may be of the 'push button' design or interlocked with the door of the emergency cabinet. More detailed guidance on emergency isolation switches is given in clause 14.6.4 of the Blue Book3.See note below;
A means for communicating quickly and directly with site personnel and the emergency services. An adjacent notice should display the site's name and address and emergency telephone number. Where a blanking plate is fitted to the telephone to permit the use of selected buttons with pre-set memories only, the '9' button should not be covered by the plate so that in the event of a memory loss to the pre-set buttons, it will still be possible for the emergency services to be contacted in the conventional way;
Notice displaying the actions to be taken in case of emergency;
An appropriate number of dry powder fire extinguishers and a container of dry sand or other absorbent material to deal with small spillages. See note below.
Notes:
At sites which alternate between ASS and USS, there should be no need to install an additional petrol pump isolation switch if the existing external isolation switch is conspicuously marked 'PETROL PUMPS SWITCH OFF HERE', is of the push button type and in a position that is clearly visible from the dispensing position(s) of the USS pumps.
When a site is in AS or ASS operation there should always be staff available that are trained in the use of extinguishers, therefore, the number of extinguishers provided should be in accordance with Table 4.3 of the Blue Guide3. The same will not apply when a site is in USS operation and the likelihood that at the time of fire there is a customer or passer-by being on hand who is trained in how to use an extinguisher is remote. For this reason, there should normally be no need to make available more than 2 x 4.5kg dry powder extinguishers when a site is in USS operation. The preference being given to dry powder extinguishers because of their effectiveness when used by untrained persons.
36 The location of the above equipment should be conspicuous so that it can be seen from the dispensing areas. It should also be at a safe distance from the potentially wetted areas should any spillages or leakages occur when the dispensers are in use.
37 If the equipment is located in a cabinet, the enclosure should be clearly marked to indicate the equipment it contains. Alternatively, the door could be fully glazed so that the customers can see the equipment. The method of securing the door to cabinet should not impede immediate access in the case of an emergency.
38 Consideration should be given to providing an additional telephone (to the one installed for emergency use) for customers to seek non-emergency advice or to notify the site operator of any instances of equipment not working properly etc.
39 Management Control Measures for unattended self-service sites would, typically, include: -
The site operator or a trained member of staff being on-call whenever the site is open for USS operation;
An emergency procedure for responding to incidents and assisting customers (See paragraphs 40 to 42);
A procedure for carrying out inspections whenever the site is open for USS operation. At sites alternating between ASS and USS operation, this procedure should be carried out at the changeover time;
40 The extent of management controls will need careful consideration to ensure that any emergencies or incidents are effectively and quickly dealt with. When determining the level of management control measures to put in place, two important points must be borne in mind. The first is that any incident may involve a customer being in a state of distress and in need of personal assistance. The second point is that the emergency services, especially the fire and rescue service, should not be relied upon to deal with minor incidents; this is the responsibility of the site operator.
41 A procedure must be in place for a trained person to attend the site (within a realistic time period) to deal with any reported incidents. Consideration can be given to installing a remote CCTV monitoring system with direct two-way communication with the forecourt as this will provide an immediate response to advise a person in difficulties and an initial assessment of the severity of the incident can be made and relayed to the person available to attend the incident. However, remote supervision of the site should not in all instances be considered as a pre-requisite to USS operation as the primary control measure is the response to the site by a trained person.
42 Incidents of sudden coupling and hose failures are a foreseeable event that can result in the customer becoming splashed/sprayed with petrol. The consequences of such an incident occurring when a site is in USS operation has to be addressed in the risk assessment so that effective control measures, to mitigate against serious personal injury, can be put in place. See paragraph 20.
1 PETEL 65/51 Petrol Filling Stations - Dispensing Control Measures (withdrawn).
2 Management of health and safety at work. HSE L21 ISBN 0 7176 2488 9.
3 Guidance for the Design, Construction, Modification and Maintenance of Petrol Filling Stations. IP/APEA ISBN 0-85293-217-0.