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Filling portable LPG cylinders at Autogas refuelling stations

Health and Safety Executive/Local Authorities Enforcement Liaison Committee (HELA)

Local Authority Circular

  • Subject: Liquefied Petroleum Gases
  • Open Government Status: Fully Open
  • LAC Number: 52/20
  • Publication Date: 18/11/2010
  • Review Date: 01/11/2013

This circular gives advice to all visiting staff including local authority enforcement officers.

Introduction

1. HSE has received reports of members of the public using purpose made adaptors to fill portable LPG cylinders at refuelling stations dispensing LPG for automotive use, commonly referred to as ‘Autogas’.

2. The filling of portable LPG cylinders is a potentially highly hazardous activity, the 'safe' filling of portable LPG cylinders requires a number critical safety measures. Automotive LPG filling stations incorporate safety measures to make filling vehicles 'safe', they do not include all of the specific measures for filling portable LPG cylinders.

3. UKLPG Industry Information Sheet No.28 ‘FILLING OF USER OWNED, PORTABLE  REFILLABLE LPG CYLINDERS AT AUTOGAS REFUELLING SITES’ explains the reasons why transportable cylinders should not be filled at stations designed for filling vehicles. The guidance is freely available from the UKLPG website.

Inspection expectation

4. Currently HSE have no records of incidents and no knowledge of faults in the adapters and this issue should not be used to trigger additional inspection activity at stations dispensing LPG for automotive use.

5. The purpose of this note is to make officers aware of the UKLPG guidance that is available on this issue.

6. If during your normal inspection activities you identify any incidents or problems related to this issue can you please pass them to HSE so we can continue to monitor the situation.

Enforcement expectation

7. LPG is not subject to the Petroleum (Consolidation) Act 1928, However the Petroleum Licensing Authority may take its presence into account in determining the conditions on any licence that may be issued under the Act. This can result in overlapping responsibility between the Petroleum licensing officer and the EHO dealing with health and safety.  Care should be exercised to ensure that any conditions imposed by one regulatory frame work do not conflict with the other.

8. Enforcement action by EHOs should be based on application of the Enforcement Management Model (EMM) i.e.

  1. the organisation fails to complete a risk assessment
  2. the risk assessment is inadequate, or
  3. the organisation is failing to take reasonable steps to address any issues that are identified in the risk assessment.

9. Examples could be:

  1. no consideration of what measures are required to inform/control the behaviour of members of the public so their use of the automotive LPG filling facility poses an unacceptable risk, or
  2. there is indication of a pattern of failure to provide sufficient supervision and/or instruction in the automotive LPG dispensing area.
Updated 2013-09-13