Health and Safety
Executive / Commission
Local authority circulars
To: All Unitary and Island Councils; County Councils and Fire and Rescue Authorities in England
For the attention of: Environmental Services / Trading Standards / Fire Authorities
This circular gives advice to Petroleum Enforcement Officers
1. Initial and periodic surveys of autogas installations (at petrol filling stations) by Fire Safety Officers and LA Inspectors can only, for practical reasons, encompass the following features:
Certain parts of the installation may be inaccessible when unannounced inspections are carried out, as the site operator may not hold the keys to dispenser and access chamber covers.
At sites where the storage vessels are buried/mounded, other than the dispenser(s), there will be little to inspect.
2. Under the Dangerous Substances & Explosive Atmospheres Regulations 2002 (DSEAR)a the site operator has the responsibility for the operation of the installation, including the maintenance even other duty holders may carry out the maintenance work. For example on some sites it is not unusual for there to be other duty holders involved by virtue of the storage vessels and the installation being owned by separate companies.
3. The Written Scheme of Examination required under the Pressure Systems Safety Regulations 2002 (PSSR)b is very specific and Section 8 requires that ‘The Written Scheme’ must cover the periodic examination of:
The term “danger” in the context of PSSR applies only to the release of pressure;
The Written Scheme may or may not be held by the site.
4. PSSR, DSEAR and Provision & Use of Work Equipment Regulations 1998 (PUWER)c require that maintenance be carried out. This may be carried out independently from or as part of the work required by the ‘Written Scheme’. As the operator is responsible to ensure this work is carried out, then there should be suitable records available. If they are not kept on site then they should be readily available from a specified location; e.g. a head office.
5. Liquefied Petroleum Gas Association (LPGA) Code of Practice (CoP) 20 includes recommendations for the maintenance of Autogas installations on which the notes in following table are based. The Code also recommends that the site operator should be carrying out routine checks of the main parts of the installation, especially those parts that could affect customer safety. e.g. nozzle, hoses, pullaway coupling, dispenser condition and emergency shut down system.
6. The following tables also give an indication of what should be included in the installation checks carried out by the site operator or specialist contractors.
| Electrical Installationd | ||
|---|---|---|
No. |
Item |
Notes |
1 |
Electrical inspection schedule and/or maintenance records available. |
See LPGA CoP 1 & 20 and Blue Book |
| Mechanical Installation The maintenance record should include the following information. It may be possible for some of the information to be verified by an inspector during a visit. |
||
| Storage Vessel Compounds | ||
No. |
Item |
Notes |
2 |
Storage type |
Above ground/Mounded/Buried |
3 |
Chamber gas sensors |
Confirm installed (for buried installations only). Although not mandatory, sensors are installed at many sites. |
4 |
Means of escape from vessel compounde. |
Two outward opening, lockable, gates on opposite sides of the compound. See LPGA CoP 1 (para 2.6.1) |
5 |
Condition of compound and base including security fencing and any radiation wall(s). |
Fence and/or radiation wall to be no closer than 1.5m. |
6 |
Vessel surroundings clear of flammable materials and excessive vegetation. |
|
7 |
Condition of paint/external surface protection of vessels. |
Confirm no significant external corrosion started |
8 |
Presence and legibility of signs on vessel/compound |
Should be clearly legible when viewed from the limits of the relevant separation distance. |
9 |
Emergency telephone number displayed and is correct |
Required by emergency services. Should be clearly legible when viewed from the limits of the relevant separation distance. |
10 |
Condition of all valves, pipework and fittings |
Confirm no evidence of damage or severe corrosion. Moderate surface corrosion may be expected on some fittings and earth bonding points without impacting on overall integrity. |
11 |
Condition of pump(s) and motors |
Confirm no damage or severe corrosion |
12 |
Emergency (pump) isolation switch(s) installed in the compound. Fitted with a suitable sign |
For use by the tanker driver or engineer working in the compound. |
| Pipework & Ducting | ||
No. |
Item |
Notes |
13 |
Condition of flexible (under dispenser) pipe |
Confirm no evidence of mechanical damage. See PETEL 65/54a. Check there are no leaks mechanical damage or corrosion. |
14 |
Buried pipework – inspection strategy. |
Confirm that there is a strategy in place that covers the buried/concealed pipework with the necessary checks and tests to establish continued integrity, the intervals between checks/tests and the rationale supporting the strategy. See LAC No 52/18 |
15 |
Condition of seals in ducting. |
Effectively sealed with mechanical or compound seals. See PETEL 65/54a. Builders (PE) expanding foam not sufficient on it’s own |
16 |
Location of buried pipework |
Should be marked on the forecourt or shown on a site plan available to contractors and the emergency services. |
| Dispensers | ||
| No. | Item | Notes |
17 |
Shear couplings |
Visual survey to confirm brackets are in place and secure. Check the thinned section to confirm no cracking |
18 |
Dispenser hoses |
Hoses should receive daily visual check (by the site operator) and an annual leak test at operational pressure |
19 |
Pullaway |
Many manufacturers recommend testing every 6 months. The period between testing should not exceed 12 months. |
20 |
Nozzles (general) |
Nozzles should receive daily visual check (by the site operator). In addition they must be checked by a competent person for correct and safe operation at least once every 12 months. Replace nozzle if any evidence of mechanical damage or leaking during normal operation.
|
21 |
Nozzle adaptors |
Does the site operator have a policy on the use of adaptors? |
22 |
Emergency isolation valves (ROSOVs) |
The system should be checked at least once a year to confirm correct operation. |
23 |
Signs on dispenser |
Warning signs plus instructions on how to use the type of nozzle fitted. |
| Fire Precautions | ||
| No. | Item | Notes |
24 |
Separation distances being maintained between autogas installation and other site features. |
See LPGA CoP 20 |
25 |
Hazardous area classification |
See LPGA CoP 1 & 20, Section 3 Blue Book (2nd edition) and DSEAR |
26 |
Water supplye |
See LPGA CoP 1 |
27 |
Fire extinguisherse |
See LPGA CoP 20 & Blue Book (2nd edition). |
| Documentation | ||
| No. | Item | Notess |
28 |
Instructions for operations, maintenance and emergencies |
DSEAR, PUWER, LPGA Codes of Practice.
|
29 |
Installation details and test certificates. |
Test certificates may be held elsewhere especially if the vessels are owned by another organisation. |
30 |
Hazardous area classification |
See LPGA CoP 1 & 20, Section 3 Blue Book and
|
31 |
Records of staff training |
Relevant staff should have received training on the hazards, safe handling and emergency procedures for LPG. |
32 |
Incident reporting |
Are records kept or reporting procedures for any leaks of LPG or incidents of customers or staff receiving cold burns. |
| Enforcement Allocation at a Petrol Filling Station | |
|---|---|
Legislation |
Enforcing Authority |
DSEARa |
PLA |
PSSRb |
LA (Environmental Health Dept) |
PUWERc |
LA (Environmental Health Dept) |
Electricity at Work Regulations 1989d |
LA (Environmental Health Dept) |
Fire Precautions (Workplace) Regulations 1997e |
Fire & Rescue Service |
HSWA |
LA (Environmental Health Dept) |
| Schedule for Equipment Maintenance. | |||
|---|---|---|---|
Equipment |
Annually2 |
Every 5 Years2 |
Every 10 Years2 |
Base and steelwork |
Visual |
||
Vessel*1 |
Visual |
Test |
|
Vessel signs1 |
Visual |
||
Vessel fittings*1: - fill liquid out liquid return vapour return relief valve* pressure gauge drain |
Test Test Test Test Visual Visual Visual |
- - - - Change - if mild steel springs - - |
Change Change Change Change Change Change - |
Filter |
Test |
Change |
|
Pump4 Internal bypass valve External bypass valve |
Test Test Test |
- - - |
Change Change Change |
Hydrostatic relief valve* |
Visual |
- |
Change |
Test point valves |
Test |
Change |
|
ROSOVs |
Test |
||
Dispenser: - filter measure overall |
Test 5- Test option4 Visual |
- - |
- - - |
Hoses6 |
Test |
Change |
- |
Pull-away coupling |
Test |
- |
- |
Safe-break coupling |
Visual |
- |
- |
Nozzle |
Test |
Change |
- |
Underground pipework |
See item number 14 in check list. |
Notes:
Those items marked * should be included in the “Written Scheme of Examination”. (WSE)
1Vessel maintenance is often carried out by the gas supplier. Some suppliers have a 20 year period between major overhauls.
2For guidance only, the intervals for each installation should be specified by the competent person drawing-up the Written Scheme of Examination and maintenance schedules
3Vessel signs should be changed if they are faded and/or cannot be read from the separation distance.
4The periods between pump and/or bypass valve changes will depend on the performance of the installation
5The periods between cleaning/changing depend on the performance of the dispenser and the type of filter.
6The BS for hoses requires a test at periods not exceeding 12 months for hoses >25mm inside diameter. Most autogas installations will have hoses with internal diameters of <25mm.
Procedures for testing for measure should take into account typical volumes dispensed and the flow rate applicable for the installation under normal conditions.
ROSOV: Remote Operated Shut-Off valves (Emergency Shutdown valves.)