Health and Safety
Executive / Commission
Local authority circulars
To: Directors of Environmental Health/ Chief Environmental Health Officers of London, Metropolitan, District and Unitary Authorities and Chief Executives of County Councils.
For the attention of: Environmental Services / Trading Standards / Fire Authorities / Other
This circular gives advice to local authority enforcement officers
| Health and Safety Executive | Operational Circular | |
| Field Operations Directorate | u OC 803/68 |
| Review Date | 17/07/2010 | Open Government Status | Open (LA version) |
|---|---|---|---|
| Version No & Date | 1: 17/07/2000 | Author Unit/Section | Engineering & Utilities Sector Birmingham |
SAFE REMOVAL OF PETROL FROM VEHICLES
| This OC reiterates the earlier recommendations about the use of proprietary fuel retrievers in motor vehicle repair. Alternative equipment and procedures for avoiding the hazards associated with removal of petrol may be acceptable. The revision of (free) leaflet IND(G)50 Safe handling of petrol in garages will be published shortly. |
1 Most fires directly associated with vehicle fuel systems occur during fuel draining operations rather than routine repair work on the fuel system itself. Removal of petrol from all or part of the fuel system is often required to effect repairs on the fuel system or, possibly other mechanical or certain bodywork repairs. However, the risk also arises during the removal of contaminated fuel from tanks following mis-fuelling, eg where a diesel vehicle has been fuelled with petrol. The Retail Motor Industry Federation (RMIF) recently estimated that there are at least 120,000 misfuellings (such that removal of the contaminated fuel would be required) each year. Appendix 1 gives a number of anonymised accident summaries, all derived from HSE investigations.
2 Many of the larger motor vehicle repair (MVR) companies have proprietary fuel retrievers either on site or accessible at other premises. In practice, correct procedures for use of the retrievers are often not followed or the equipment provided is not used and ad hoc methods are employed. Smaller garages are less likely to have a proprietary fuel retriever, relying instead on a variety of methods based on equipment available and type of vehicle involved. The safe storage of contaminated fuel prior to its removal from the premises must also be considered when considering the risks.
3 Transferring petrol from one container to another will result in the displacement of petrol vapour from the receiving container. Unless this vapour is captured it could disperse into the workplace and be ignited. Spillages of small quantities of petrol can generate large volumes of a flammable gas mixture. (One litre of spilt petrol can give rise to up to 15,000 litres of a flammable gas mixture and a petrol spillage can be ignited a long way from the site of the spillage due to the spread of the petroleum vapours.)
4 Even when using an approved fuel retrieval system, petrol removal must only be carried out in a well-ventilated area, preferably in the open-air, well away from pits or other openings in the ground, and from which all ignition sources have been excluded. Static electricity, a potential source of ignition, can be generated when petrol flows through pipework and into containers. In order to eliminate the possibility of an ignition from static discharge, both the vehicle chassis and the container used for the removed fuel should be earthed.
5 The use of a fuel retriever, plus adaptors where required for the range of motor vehicles anticipated, is the safest and most strongly recommended method for draining petrol. A proprietary fuel retriever incorporates a number of essential features:
1) one or more containers for temporary storage of different fuels;
2) a hand-operated pump for transfer of fuel to and from the retriever;
3) flexible hose(s) for access through the fuel filler neck;
4) earthing straps;
some models also include:
5) a level gauge on each container;
6) a flashback arrestor on each container; and
7) vapour recovery pipework.
6 Correct use of a proprietary fuel retriever eliminates spillage, minimises fugitive petrol vapour emissions and provides a suitable and stable container into which petrol can be drained. It also allows subsequent transfer to another container to be carried out safely. Furthermore, proprietary fuel retrievers include means, by way of earthing straps, to eliminate dangerous static discharge. Some retrievers also have vapour recovery pipework incorporated to prevent much of the displaced petrol vapour escaping into the atmosphere. Manufacturers' instructions should be readily available, and followed fully, particularly the correct use and maintenance of the earthing straps.
7 Using the correct adaptor, it should be possible to remove the fuel through the filler neck, though some vehicles may have types of 'anti-theft' or 'rollover safety devices' which may make it very difficult. Removal by way of fuel lines can usually be carried out safely, provided the appropriate adaptors are used and the recommended method in the vehicle workshop manual is followed.
8 Where a proprietary fuel retriever is not used the hazards must be fully addressed. In particular any area designated for fuel removal must meet the precautions given at para 4. A hand-operated syphon or independent manual pump may be acceptable provided that transfer pipework is securely positioned at both ends and the vehicle chassis and the container are grounded by the use of earthing straps. Petrol should be drained into a suitable container which can be securely closed after use. Except for quantities of less than 10 litres, which can be drained into plastic 'carry-cans', containers should be metal. The container should be stable or be held within a stable framework so as not to be easily knocked over.
9 When not being used a fuel retriever should be stored in a clearly designated area in the workshop from which ignition sources and combustible materials are excluded. It should not be kept on an escape route and a fire extinguisher suitable for dealing with flammable liquid fires should be close at hand. At the end of the working day the fuel retriever should if possible be removed from the workshop to a petroleum store licensed by the appropriate authority.
10 Sender unit devices will usually be found on top of the fuel tank, accessible from the car boot or under the rear seat. However on some vehicles they have been positioned near the bottom of the fuel tank. Fatalities and serious burns have occurred following the drenching of mechanics attempting to remove such sender units. A faulty unit may erroneously indicate an empty tank, and reliance should not therefore be placed on the reading from a fuel gauge. Removal of units located other than on top of the fuel tank should never be attempted unless the tank is verified as empty.
11 Complete removal (where required) of fuel from the tank of some types of vehicle may require a combination of methods. For example the main volume of fuel may be removed using a fuel retriever with adaptors via the filler neck. Remaining fuel may require removal via a fuel feed line for a carburettor system or via the return feed line for a fuel-injected system. Complete fuel removal may not be achieved from vehicles with fuel tanks in front of the rear wheels or where the tanks are saddle shaped to allow sufficient clearance for exhaust pipes. In such tanks about 3.5 litres is likely to be left unretrieved in the bottom of the fuel tank on the side remote from the filler neck.
12 All significant UK vehicle manufacturers and importers have been approached to remind them that adequate guidance should be available, for both current and earlier models, for work on vehicle fuel systems. They may be also be able to provide details of suppliers of fuel retrievers and required adaptors for their particular models.
13 Suppliers/manufacturers of proprietary fuel retrievers (and adaptors where necessary) may be located by contacting the Automotive Distribution Federation Ltd (ADF), Garage Equipment Federation Ltd (GEA) or Society of Motor Manufacturers and Traders Ltd (SMMT). See Appendix 2 for address details.
14 Any accumulated contaminated petrol must be stored in suitable containers in a designated area outside the workshop. The quantities involved will normally require licensing, by the appropriate authority, under the Petroleum Consolidation Act 1928. The employer should be referred to their licensing authority for advice on the safe storage of petrol.
Note: the current review of petroleum storage legislation, resulting from the Chemical Agents Directive, proposes removal of the licensing requirement and transfer of storage enforcement to HSE/local authorities except for retail filling stations. The current proposal is that this will occur in May 2001.
15 Inspectors should strongly recommend that drained petrol and waste oil are not mixed together. There have been several serious incidents at oil recovery companies which may have been linked to petrol contamination of waste oil. Contaminated petrol or diesel should be stored in dedicated sealed containers and a clear description of the nature of the material provided when consigned to waste.
16 Due to the comparatively small proportion of time during which garages are actually involved in petrol draining, inspectors will rarely be in the position of being able to observe this activity at routine inspection visits. Therefore, when premises involved in MVR (mechanical or bodywork repair) are visited, enquiries should be made to ascertain whether petrol draining has been carried out and more importantly whether such work might be carried out in the future (see para 1). If such work is likely to be undertaken then sufficient information should be obtained to form a judgement regarding the occupier's approach to the control of the hazards.
APPENDIX 1
(para 1)
A selection of investigated accidents at motor vehicle repair premises involving fire and explosion during work on vehicle fuel systems between April 1986 and March 1998. These have been widely used in press releases and trade magazines in recent years.
1 During the removal of a faulty sender unit in a fuel tank, the vehicle was raised on a hoist and 2 men were soaked in petrol when the unit was removed. The tank was nearly full and petrol ignited by a gas fire about 5 metres away. Both died in the resulting fire.
2 Four people were in a small railway arch garage with the door closed. Petrol ignited while being drained from a car tank. Two died and 2 received severe burns.
3 Labourer used vacuum cleaner to blow air into petrol tank of hire vehicle as a means of speeding the flow of petrol being drained from the tank (customer wanted his petrol returned to him). Petrol vapour ignited and vehicle destroyed.
4 Employee suffered severe burns (62 per cent) when petrol leaked from the tank while he was changing the sender unit. Tank not pumped out before work commenced and petrol ignited by hand lamp. Fire caused extensive damage to premises.
5 Mechanic contained petrol leak from car in watering can. Can was picked up by another (thinking it contained water) and taken to washroom for horseplay. When splashed around, the vapour ignited and three people were burnt in the explosion and fire.
6 Deceased was changing a sender unit, working on the vehicle in a small inspection pit. He drained some petrol from the tank into a plastic bucket. The petrol vapour in the pit ignited. Source of ignition thought to be a light fitting.
7 Burns to hands/arms/legs of employee when 6 gallons of petrol spilled from vehicle tank being removed. Proprietor had thought tank was nearly empty and that it could be removed without emptying the residue. Garage destroyed by fire.
8 Deceased was a director at a small garage. He was draining petrol from car tank into container in vehicle pit and was last seen kneeling by the car petrol filler.
9 Using employer's vehicle hoist over a weekend, a mechanic was replacing petrol tank sender unit for a friend. When sender unit loosened, several gallons of petrol poured out, soaking mechanic and was then ignited by a battery charger. He suffered 70 per cent burns.
10 A mechanic was draining car petrol tank in a workshop. Another employee was welding outside the workshop about 20 metres away. Petrol vapour ignited and flashed back to tank. The workshop and showroom were destroyed.
APPENDIX 2
(para 13)
AUTOMOTIVE DISTRIBUTION FEDERATION LTD (ADF), GARAGE EQUIPMENT FEDERATION LTD (GEA) AND SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LTD (SMMT)
Automotive Distribution Federation Ltd
68, Coleshill Road
Hodge Hill
Birmingham
B36 8AB
Tel 0121 784 3535
Fax 0121 784 4411
Web site http://www.adf.org.uk
Garage Equipment Association Ltd
2/3, Church Walk
Daventry
Northamptonshire
NN11 4BL
Tel 01327 312616
Fax 01327 312606
Web site http://www.gea.co.uk
Society of Motor Manufacturers and Traders Ltd
Forbes House
Halkin Street
London
SW1X 7BS
Tel 0207 235 7000
Fax 0207 235 7112
Web site http://www.smmt.co.uk