Work instruction for LPG pipework replacement inspection visits

OM 2011/08 - Version 2

Open Government Status
Fully open
Author Unit
FODNWHQ – Operational Strategy
Target audience
HSE Inspectors, VOs, RCOs and administrative staff for action; LA enforcement officers, for information

Aim

1. Assurance that LPG users (and suppliers) are undertaking effective, sensible and proportionate management of the risks arising from small and medium-sized bulk vessel LPG installations, including the replacement (or ongoing inspection and maintenance) of buried metallic pipework.

Work priority

2.  This second year of inspection visits builds on the successful work undertaken in 2010/11, and represents an important part of the ongoing major initiative to improve safety at bulk LPG installations. The purpose is to resolve any issues at targeted sites where pipework replacement is identified as being higher priority, either through likelihood of poor standards or because of an unwillingness to provide information for the pipework survey, or take the replacement action required. The inspections will also provide a basis of evidence for determining the HSE intervention approach in future years, as the buried metallic pipework replacement campaign moves towards its completion. At present all higher priority buried metallic pipework is to be addressed by the end of 2013, and other metallic pipework by the end of 2015. (Subject to an independent review of the timescale for lower priority sites.) 1, 2

Background

3. There have been a number of incidents where LPG has leaked from buried metallic pipework. Over the last 20 years or so, explosions have occurred, most seriously when nine people died and 33 were injured in an explosion at the ICL Plastics factory in Glasgow in 2004. In that instance, LPG had leaked from a corroded underground metal pipe into the basement of the factory and then ignited, causing an explosion which led to the catastrophic collapse of the four-storey building.

4. LPG service pipework installed up until the late 1980s/early 1990s was metallic, often steel or copper, and was usually provided with some form of corrosion protection. However, even if this corrosion protection was correctly installed (which was not always the case), its efficiency reduces over time. Also, gas users do not always appreciate that they own this pipework, and many users have taken no measures to maintain it. There is, therefore, a large number of premises with ageing buried metallic pipework in unknown condition and with inadequate protection against corrosion.

5. One of the recommendations of Lord Gill's report into the explosion at ICL Plastics was that all buried metallic LPG pipes should be replaced with polyethylene. In order for the pipework replacement work to be prioritised, industrial and commercial LPG users were requested to return a questionnaire concerning their buried pipework. These responses were used to determine relative risk rankings for pipework at individual sites.

6. HSE has previously provided a briefing note for LPG suppliers about the inspection visits, consistent with the information in this minute. Suppliers may have provided the note, which is attached at Annex 3, to their customers, or, alternatively issued bespoke letters about action which customers need to take regarding their buried pipework.

Scope

7.  The planned inspections relate only to non-domestic installations with vapour phase pipework. There is ongoing work to address the risks in domestic premises, and a separate project dealing with caravan sites and metered estates. Whilst sites with liquid phase pipework have not intentionally been included within the visit allocation process, it is likely that Inspectors will continue to encounter a small number of these sites. (It is not possible to accurately exclude all such sites from the customer information provided to HSE by LPG suppliers.) The revised LPG topic pack outlines the specific requirements relating to liquid phase LPG installations.

How it works

8. A standardised risk ranking model is applied to questionnaire responses, generating a risk-ranking for each individual site with buried pipework. These results are provided to LPG suppliers in respect of their customers, and also form the basis of a master database held by HSE. Sites are subsequently allocated for visit based on the calculated risk ranking, predominantly focusing on higher risk pipework. Visits may also be allocated for other reasons, eg where questionnaires are incomplete, or have not been returned.

9.  It should be noted that the risk rankings are calculated using the questionnaire responses concerning buried pipework, and information about soil type derived from the site postcode.  Some user-provided data may be inaccurate or incomplete, and in such cases, the calculated risk ranking will use default data. Consequently, the physical conditions encountered at visits may be significantly different from those indicated by the survey responses. The standards of bulk tank installations are not accounted for within the risk-ranking process. Inspectors should base their judgments on the actual conditions found, eg when considering timescales for remedial action, rather than rely on calculated risk-rankings which may have derived from default values.

Number of sites

10. There are no absolute figures for the number of sites which may have buried metallic pipework. However, experience suggests that the number of such sites which are being ranked as higher risk forms a relatively small proportion of the overall estimated 40,000 commercial LPG installations. Over time, if effective action is not taken, more buried pipework would become higher risk as the pipework deteriorates.

Timing

11. Whilst the majority of users (over 33,000) have now provided questionnaire returns which have been processed, work is ongoing to engage with the remainder of users, and thereby to address those sites with buried metallic pipework for which no risk-ranking currently exists. LPG suppliers will continue to encourage "non-responding" customers to submit questionnaires, and will themselves be undertaking limited checks at non-responding sites.

12. The target for replacement of buried metallic pipework at all "higher risk" sites remains the end of 2013, which is considered achievable by LPG industry. For the remainder of sites, the current limited capacity of the industry to replace pipework, and the number of sites involved may require extension of the existing 2015 deadline. This matter is being considered by an independent expert panel.

13. HSE and UKLPG have both produced 'high level plans', these have been combined, see the gas section on the HSE website.

Communications

14. A number of regional briefings for  both HSE and LA inspectors were held during 2009/2010.  For HSE inspectors, the intention was for those attending these briefings  to cascade, within their teams, further details about the LPG inspection work. Whilst no further briefings are planned, comprehensive information is available within the LPG topic pack, the LPG WebCommunity (for HSE Staff) and the HELEX extranet (for local authority staff.)

Action – buried metallic pipework

15. Inspectors will visit allocated sites to ensure that action is being taken to address buried metallic pipework risks. The optimum solution is for pipework to be replaced with polyethylene within the agreed timescale, since this permanently addresses the risk. Alternatively, dutyholders may implement a robust inspection, examination and maintenance strategy to ensure pipework continuing integrity.

16. Where replacement has not been scheduled, in accordance with EMM principles, LA/HSE inspectors should normally take formal enforcement action to ensure that the pipework is replaced (the preferred solution,) or alternatively, that a robust inspection, examination and maintenance strategy is in place to ensure pipework integrity.

Action – remainder of installation

17. Pipework is only part of an LPG installation. The bulk tank installation should also be inspected during these visits and any necessary action taken to ensure that the risks are being controlled. The revised LPG topic pack should provide sufficient information about the relevant standards for the majority of small installations.

Numbers of inspections

18. For 2011/12, it is anticipated that HSE will inspect approximately 1,500 sites, focusing on those sites identified as "higher risk" by the risk ranking model. The sites will be selected centrally, and forwarded to regional LPG coordinators and local authorities as outlined below. A list of Divisional LPG coordinators is provided at at Annex 1.

LPG call centre

19. The LPG admin team will continue to undertake the central identification of sites to be visited, allocating premises as appropriate between FOD, HID and LAs, based on location and type of establishment. For HSE premises, this information will be forwarded to the divisional LPG coordinators in HID/FOD offices to allocate to the appropriate inspection team.)

20. Information on LA-enforced sites will be input directly onto the LLARD extranet site for action by the relevant local authority,

21. The LPG admin team will monitor overall progress with visits on a central database, and  national progress monitoring and feedback for FOD will be included in the FOD HQ monthly report based on COIN data. LAs will feed outcomes of their visits into the  HSE extranet web tool (LLARD,) which will continue to be monitored by LAU and FOD HQ. HID will review the data for evidence of poor performance by any bulk LPG supplier and use it to target those poor performers for follow up.

Local offices

22. The divisional coordinators will oversee the arrangements in local offices. This will include:

  • Dealing with 'new to FOD' premises, amending or creating site records, where necessary.
  • Allocating inspection visits as appropriate, either directly to Inspectors or via their Principal Inspector as agreed locally.
  • Creation of new "IRF LPG" service orders. These may be created in advance of visits or following inspections subject to local management requirements.
  • Maintaining a record of those sites allocated for visit where no inspection ultimately takes place, or where visits are curtailed eg because they are determined to be a domestic premises or local authority enforced.
  • Monitoring progress
  • For HID sites, discussing with field teams any uncertainties in site allocations from the LPG admin team.

23. Local arrangements will be implemented via regional Partnership Teams or Enforcement Liaison Officers (as appropriate) to ensure effective communications with Local Authorities.

Monitoring

24. Divisional coordinators should monitor local progress with visits, ensuring that service orders are closed out when all action has been completed. The usual Data Quality checks should be carried out (see OM 2009/09). A spreadsheet detailing cancelled / abortive inspection visits should also be maintained.

Inspectors' Instructions

Site inspections – buried metallic pipework

25. When the inspector finds the LPG service order in their worklist, they should use local knowledge and professional judgment and undertake 360° checks on COIN, as required, to check whether there is anything that makes the site unsuitable for a visit eg

  • Previous recent action dealing with buried LPG pipework.
  • Multi-site employers where COIN indicates that action is already being taken centrally. (A list of dutyholders subject to ongoing central interventions is accessible via the LPG WebCommunity.)

If the site is not suitable, the divisional coordinator should be informed, and an appropriate entry made on any COIN Service Order record for the site, giving the reasons for the exclusion from the inspection initiative. Any such Service Orders  should be "Cancelled" rather than "Closed".

26. The inspector should telephone the site to check what action has already been taken and request a copy of the completed site questionnaire if available. (Copies of the questionnaires are not available for distribution to inspectors, but the information sent to Divisional Coordinators is derived from it.)

27. At the subsequent visit, which will normally be by appointment, inspectors should check:

  • a. as far as possible, that the information concerning the site is accurate;
  • b. whether there are any factors that increase the likelihood of a leak or the consequences of a fire/explosion, and therefore require more urgent action (see LPG topic pack  for further details);
  • c. what action the site is taking, i.e:
    • i. Replacement of buried metallic pipework within the appropriate timescale;
    • ii. Re-routing of pipework above ground;  OR
    • iii. Implementation of an inspection, examination and maintenance strategy devised by a competent person (see topic pack, appendix 3. )

28. Inspectors should ask for written evidence of intended actions, followed by, as a minimum, written confirmation that action has been completed.

Site inspections – remainder of installation

29. At the inspection, the inspector should also consider the whole LPG installation, from the bulk tank to the point of entry into the building, as a MPMC (see OC 18/12). However, specific work recording requirements apply, as outlined in paragraphs 38- 44 below.

Site inspections – other issues

30. The inspections in this initiative should focus on the condition of the buried service pipework up to the point of entry into the building, the standards of the bulk supply tank and the management of the associated risks. Inspectors should not explore site operators' management of other H&S issues or inspect other work activities unless:

  • The condition of the LPG system points to serious generic weaknesses in the operator's overall approach to managing H&S; and/or
  • Inspectors identify Matters of Evident Concern (MEC), which should be treated in the normal way in line with the guidance in OC 18/12 and/or
  • Information is identified before the site visit indicating probable poor standards or controls in other areas which align with HSE's strategic priorities, and which require follow up.

31. At these LPG inspections, inspectors should only pursue other MPMCs in line with OC 18/12 when they have:

  • Serious concerns about the LPG installation; and/or
  • There are serious generic weaknesses in the operator's approach to managing health and safety; and/or
  • Previous history of the site indicates serious concern.

Inspection and enforcement activities relating to non LPG MECs and MPMCs should be recorded via a separate Inspection IRF, and not on the LPG IRF.

32. For sites where there are good standards of management, and the LPG bulk supply tank and service pipework are satisfactory, inspector action should be limited to clarifying the other activities at the site. For example, to confirm the enforcement authority, and to determine any appropriate follow-up action. This should normally be limited to a visit by a VO/RCO unless the geography makes this unrealistic on efficiency grounds.

33. Sites which are found to have domestic LPG supplies only should not be proactively inspected. Advice may be provided in relation to serious evident defects, but is should be emphasised that domestic customers are not subject to the Health and Safety at Work Act, nor are domestic premises within scope of this inspection programme. For HSE staff, the COIN Service Order should be "Cancelled," an appropriate note made, and the regional coordinator should be advised.

LPG Suppliers' duties

34. If significant failures by the site's LPG supplier are identified, inspectors should follow the guidance in the LPG topic pack for dealing with supplier issues. In general, site-specific defects may be addressed directly, but generic management or systemic issues will require the involvement of HID.

The four main suppliers (Calor, Shell, Flogas and BP) will continue to be subject to established HID lead inspector arrangements. A liaison strategy is currently being agreed between FOD and HID to determine appropriate contact arrangements for the remaining smaller suppliers. LA inspectors should, subject to local agreement, contact either their HSE enforcement liaison officer or partnership manager, who will liaise, as appropriate, with the relevant HID contact.

Enforcement Guidance

35. The actual risk from the ignition of a leak of LPG is of multiple serious injuries and the benchmark standards for LPG installations/pipework are long-established and set out in detail. The initial enforcement expectation will therefore be an Improvement Notice where there is a significant failure to meet the relevant standards.

36. Relevant dutyholder and strategic factors, and examples of enforcement scenarios are set out in the LPG topic pack. Subject to consideration of such factors in accordance with EMM principles, Inspectors should normally take formal enforcement action where dutyholders are not taking appropriate action to control site risks.

37. For further information and a list of relevant published guidance, see the revised LPG topic pack.

Work recording

38. Accurate and consistent work recording is essential, not only to show what has been done, but to ensure that issues, once raised, are closed out, or that the next inspector knows what has been done and can easily pick up the threads. The information recorded will be used to provide important updates to the HSE Board and Ministers on progress, as well as providing intelligence for the inspection strategy in future work years.

The following instructions are for HSE staff - LAs will record work using the Local Authority LPG Database (LLARD), see Annexes 4 and 5.

39. The COIN screen for the LPG service order contains only the specific scoring system for the project. The LPG storage tank and the service pipework should be scored separately on a 1 – 4 scale as below:

LPG pipework - Initial site visits

Criteria

  1. No buried metallic pipework (ie replacement action already completed). All above-ground pipework in good condition and subject to an appropriate inspection regime – no action
  2. Visible pipework in good condition, buried metallic pipework known to be in good condition, provided with efficient corrosion protection and subject to an appropriate inspection, examination and maintenance regime – no action
  3. Visible pipework in good condition, buried metallic pipework in unknown condition, replacement required – IN unless:
    1. dutyholder can provide evidence that pipework replacement is scheduled in line with risk ranking timetable and
    2. there is no evidence that pipework is in poor condition, and no additional risk factors.
    Where IN not issued, follow-up is still required to ensure replacement is completed
  4. Visible pipework in poor condition - issue PN (where immediate risk)

LPG storage tank – Initial site visit

Criteria

  1. Good standards, meets UKLPG Code of practice in all respects, evidence of understanding and management of risks at site level – no action
  2. Single or minor failing, eg small amount of combustible material, minor deviation from separation distance, to be dealt with by letter, with follow-up
  3. More significant or multiple deficiencies eg failure to provide protection from vehicles in tank vicinity, significant amount of combustible material in area, issue IN
  4. Poor installation that fails to meet UKLPG Code of Practice in significant areas, lack of management control of risks, issue IN or PN (where immediate risk)

40. Inspectors should score the site in accordance with the above scheme, and enter the number of any Notices issued on the service order. A site visit will only be considered an inspection where IRF scores are provided, regional co-ordinators will maintain a list of abortive visits. (eg where sites are found to be domestic, or local authority enforced.)

Where the site has not completed all the actions required in relation to the LPG installation, inspectors should complete the issues tab with details of the relevant outstanding issue(s), together with the required action(s) and follow-up date. (An issues tab is not required in circumstances where a relevant Notice has been issued.) The service order should be left open until all required remedial action is complete and the issues tab is closed down.

41. In order that pipework replacement action can be accurately monitored, any required remedial action taken by the dutyholder with respect to buried metallic pipework should be recorded against the third line of IRF scores in accordance with the scale below. Where no remedial action was required (all pipework already above ground or PE prior to visit) then no score should be entered and the remedial action  IRF line should be left marked as "Not Discussed."  

LPG Pipework - Remedial action

Criteria

  1. Buried metallic pipework replaced with PE
  2. Buried metallic pipework re-routed above ground
  3. Buried metallic pipework subject to inspection and maintenance regime
  4. LPG Usage Ceased (eg switched to alternative fuel, discontinued supply, changed to cylinder supply etc)

42. The summary field of the IRF service order note will be pre-populated by the administrative staff / LPG coordinators with the following information: "Visit Details"; Name of Contact (and Telephone Number if one exists); Name of the Supplier. The details of the visit should include the following on the same note:

  • Date of Visit
  • Location
  • Reason for visit - Questionnaire returned or not returned
  • Who you were accompanied by
  • Who you met
  • Issues discussed/raised including
    • Type of bulk tank
    • What it is used for
    • Actual Supplier (NB see Annex 2 for list)
    • Type of pipework (metallic, polyethylene) and whether it was buried
    • Conditions found (such as evidence of corrosion)
    • Bulk tank- any issues
  • What action the duty holder is taking (eg replacement of buried metallic pipework within appropriate timescale and/or implementation of an inspection, examination and maintenance strategy)
  • Action taken
  • Follow-up required and when

Example 1:

01/10/09 - Visited site. Met Mr Smith (MD) and TU Rep Mr Jones. Questionnaire returned. Above ground LPG bulk tank (supplier name) only with above-ground metallic pipework. No buried metallic pipework at site. Service pipework showed no evidence of corrosion, was protected from foreseeable damage and was subject to inspection, examination and maintenance strategy devised by competent person Mr Smith. Bulk tank met standards and was recently installed.

Example 2:

01/10/09 - Visited site. Met Mr Smith (MD) and TU Rep Mr Jones. Questionnaire returned. Above-ground LPG bulk tank (supplier name) with buried metallic pipework. Service pipework was in unknown condition with no evidence of an inspection, examination and maintenance strategy. IN served for pipework replacement or competent person to devise such a strategy. Bulk tank approx 9 years old, but no matters of concern noted. Revisit will be required to check compliance with IN in February 2010.

43. Time spent on these issues should be fully recorded by completing the time fields on the IRF/Ratings page against relevant Hazard Topic. The 'Present/Discussed' field should be changed to reflect the situation encountered.

Critical Data Quality Concerns

44. Significant and persistent data quality issues have been identified within completed LPG Service Orders. This obstructs progress monitoring, and undermines accountability where actions and outcomes cannot be clearly determined from COIN records. Inspectors should therefore ensure that the following aspects of work recording are given particular attention:

  • That the "Actual Start Date" reflects the date of the site inspection visit.
  • That IRF scores are completed appropriately for both tanks and pipework. (Even tanks supplying detachable hose systems will typically have some fixed service pipework which can be assessed.)
  • That the "number of notices" box on the IRF score lines reflects the actual number of notices issued.
  • That action taken by inspectors is unambiguously recorded (ie avoiding phrases such as "Notice proposed," or "Possible I/N.")
  • That it is clear from the inspection visit note what remedial work was required and undertaken. (See paragraph 42.)
  • That Service Orders are appropriately linked with COIN Enforcement Cases as "related objects." (ie directly where each share the same customer number, or otherwise via a linked "Master Case.") COIN guidance at http://intranet/information/coin/training/multisiteinterventions.pdf refers.

Follow-up actions

45. Inspectors should follow-up all sites, whether or not Notices are issued, to ensure that replacement action is completed – check visits should be made to sites, where required, and in all cases where Notices have been issued. For all visits, the issues tab status should be changed when action is complete and appropriate entries made in the COIN Service Order notes. The service order can then be closed as "completed."

46. Sites should not be re-scored via a separate LPG IRF, since the existing service order should not be closed until satisfactory compliance has been achieved. The remedial action taken should be evident from the notes, and the pipework-remedial action score. The IRF scoring system is tailored to the LPG inspection programme, and is distinct from a normal inspection rating.

Specialist resource

47. The specialist resource, mainly mechanical engineering (or process safety), to support the programme is limited. Inspectors should discuss any proposed request for specialist advice in advance with their line managers. Any necessary support request should be clearly prioritised. It is anticipated that specialist resource will always be available to support appeals against Notices, prosecutions, or to give urgent advice where Prohibition Notices are being considered on site.

48. The aim of the topic pack is to equip inspectors, VOs, RCOs and LA enforcement officers to deal with most of the issues they come across. There may  be occasions where the dutyholder argues that their pipework is sound, or that a system of inspection & maintenance is suitable & sufficient, but the inspector disagrees, particularly if formal enforcement action is under consideration. In these circumstances, it will be necessary to bring mechanical engineering expertise to bear. Process safety inspectors have expertise in fire and explosion matters, but not in corrosion. It is important that inspectors appreciate the distinction when making a request for specialist support. LA staff should contact their usual enforcement liaison officer in the first instance.

49. A list of FAQs and supporting advice on developing issues is available via the HSE LPG WebCommunity for HSE staff, and via the HELEX extranet for LA officers.  

Footnotes

  1. This remains a top priority workstream for FOD. (Construction Division are not expected to undertake any LPG campaign inspection visits.) If a Division cannot find the 'headroom' to undertake the inspections eg by prioritising preventive work, then they should consider freeing up the time from reactive work via the DRF system for new investigations. Divisions have complete freedom to identify the proactive work which may need to be reprioritised (or stopped) without reference to FOD HQ. Back
  2. In HID this work will form part of planned interventions at COMAH sites. Back

Annex 1 – List of Divisional LPG Coordinators

  • East South East                        Mark Daniels – Chelmsford
  • North West                                 Elaine Norris – Preston
  • Scotland                                    Sandra Clark – Glasgow
  • London                                      Jeanne Bennett
  • Yorks and North East                Raj Bhogal
  • Wales & South West                  Margaret Hatton – Wrexham
  • Midlands                                    Marg Erskine - Nottingham
  • HID                                               Andrew Oakes - Bootle, Viv McClelland - Bootle

Annex 2

List of LPG suppliers as recorded on COIN

Name of Supplier
Trading As,  COIN ID

Andy's Gas                                       

Andy's Gas  1310876

Autogas Limited                                 

Autogas Limited  4185288

Bata Limited                                      

Bata Gas   4185241

BDS Fuels                                          

BDS Fuels    1227340

Beta Gas Limited                                

Beta Gas       4185290

The BOC Group Limited                    

BOC             1009878   

BP LPG (UK) Ltd                               

BP                1012519     

Bulk Gas UK Limited                         

Bulk Gas UK Limited            4184598     

Bywater LP Gas                                 

Bywater Gas           4185243   

Hingley & Callow (Oils) Limited          

Callow Gas       1012427       

Calor Gas limited                                

Calor                1010487                    

Cambrian Gas Limited                        

Cambrian Gas            1331777                           

Cardiff Gas Limited                             

Cardiff Gas           1013637                       

Carver (Wolverhampton) Limited        

Carver Gases              1008971                          

Cheshire Gas Limited                         

Cheshire Gas           1015069                                                               

Chevron Limited 

Chevron Limited                 4057133                                                                                                        

Coleman UK PLC   

Coleman UK      4185282                                                               

ConocoPhillips Limited     

ConocoPhillips  1013161                                   

Countrywide Farmers Plc       

Countrywide      4185305                           

Discount Gas Supplies Limited            

Discount Gas Supplies  4102021                    

Energas Limited

Energas Limited            1009766

Flogas UK Limited

Flogas  1010793

Gauld & Sons

Gauld's Gas   1009613

George Rose

George Rose    1228647

Gleaner Oils Limited

Gleaner Oils      1010233

HBS Fuels Limited

HBS Fuels        1072971

International Energy Group

International Energy Group         4185309

Johnson Oils Limited

J Gas   1013834

JFA Limited

4185330

Lima Autogas Fuels Limited

4185328

Lister Gases Limited

Lister Gases      4143977

LP Gas Wales Direct Limited

LP Gas Wales Direct     4143977

LPG Direct Limited

LPG Direct        1009865

Northern Energy Supplies Limited

Northern Energy            1146092

Nova Gas Limited

Nova Gas         1015052

Petroplus Refining Teeside Limited

Petroplus          1014501

Premier Autogas Limited

Premier LPG     4158428

Rectory Gas Supplies Limited

1010511

Scotia Gas Networks Limited

Scotia Gas        4185325

Shell Gas Limited

Shell     1017617

C & A Sandford

Summerways Gas Distribution Services  1012322

Total UK Limited

Total     1017391

Trentgas 

TBC

Annex 3 – Advisory note for suppliers and LPG users issued in October 2009

LPG pipework replacement programme

Inspection campaign – note for suppliers and LPG users

1 This note provides an overview for LPG supply companies and commercial and industrial users of LPG of the inspection campaign by Health & Safety Executive (HSE) and Local Authority (LA) inspectors as part of the LPG pipework replacement programme.

The Campaign

2 This will be a major inspection campaign, led by Inspectors from HSE's Field Operations and Hazardous Installations Directorates (FOD and HID) and involving Inspectors from Local Authorities. Overall, it aims to improve the safety of bulk LPG installations, including the pipework.

3 The purpose of the Campaign is to resolve problems at sites with bulk LPG metallic installations which have been identified as higher priority or demonstrate poor standards, or because of an unwillingness to provide the information or take the remedial action required.

4 The inspections will also provide a basis of evidence for more precisely determining priorities and resource needs in future years as the Campaign moves towards its completion.

5 In particular, the Campaign will provide assurance that LPG suppliers and users are managing in a sensible and proportionate way the risks from small and medium bulk vessel LPG installations, including the replacement or ongoing inspection of buried metallic pipework.

6 The Campaign has a high priority in HSE, and FOD alone will visit up to 2,000 sites by March 2010.

Sites to be visited

7 Sites selected for visit will include those that have been placed at the higher end of the risk spectrum by the GL ranking tool using the information provided on the questionnaire sent by suppliers to their customers over the summer. Sites that have not responded to the questionnaire may also be visited, and one immediate issue will be to determine why the questionnaire was not returned. Sites will include those supplied by companies that are members of UKLPG as well as customers of suppliers that are not UKLPG members.

8 Whilst on site, HSE and LA Inspectors will consider the LPG installation (ie. not just the pipework) to ensure it meets current standards, as well as examining the site operator's management and risk control systems (eg. maintenance) relevant to LPG use and storage.

9 Inspectors will also need to consider the control and management of any other significant risks that come to their attention during the course of the visit.

10 The Inspection Campaign does not preclude HSE or LA Inspectors inspecting bulk LPG installations as part of visits to sites for other purposes, eg. following an incident or receipt of a complaint, or as part of an intervention plan at a site subject to the Control of Major Accident Hazards Regulations 1999 (COMAH).

11 In the future, and informed by the results of the first phase, the Campaign may focus on those sites ranked in the 'medium' risk category again to seek assurance that appropriate standards are being complied with.

12 HSE Operational Circular 286/105 1 advises HSE inspectors on the action to take where LPG is used in bulk at commercial and industrial sites. Inspectors will continue to follow this guidance during all relevant visits, including those as part of the Campaign. OC 286/105 is available on HSE's website.

13 Throughout the campaign HSE will continue to engage with supply companies on progress. This will be through established mechanisms including the high-level arrangements with the four biggest supply companies, and existing Lead Unit arrangements with these and other large suppliers.

Support to HSE and LA Inspectors

14 A series of half-day briefings from early October have been arranged across the Country for HSE and LA Inspectors involved in this work. The briefings will cover:

  • the purpose of the Campaign,
  • a summary of the technical standards against which installations will be assessed,
  • the sources of other advice and access to technical support.

15 A new Topic Pack on LPG installations will be available to Inspectors before the work starts, along with supporting specific work instructions. The Topic Pack will supplement OC 286/105 and further help ensure consistency of approach by Inspectors. It will contain, for example, enforcement guidelines related to HSE's Enforcement Management Model to help Inspectors decide on any appropriate enforcement action where serious risks and/or breaches of health and safety law are identified.

16 The briefings and supporting material will also include guidance on the factors to take into account when discussing with site operators or suppliers the timescales for the completion for any remedial work.

Health & Safety Executive

Annex 4  - Work recording on the LPG Local Authority Reports Database - LLARD

With so many visits being undertaken, accurate and consistent recording is essential. This will not only show what has been done, but help ensure that issues, once raised, are closed out. The information recorded will be used to provide important updates to the HSE Board and Ministers on progress, as well as providing intelligence for the inspection strategy in future work years.

LLARD can be accessed by designated users using their normal Extranet/HELEX log on.

Due to the commercial confidentially and assurances given to the industry, user access has been limited a restricted number of named individuals. If you are a LLARD user you should ensure that:

  • You do not share your log on with anyone else - Although you can input data for your colleagues.
  • If you have a local agreement to undertake inspections in a neighbouring authority under a flexible warrant arrangement, information is passed to the correct Authority so they can record the information on LLARD against their Local Authority.
  • If a HSE inspector has taken action on one of your Local Authority sites using a flexible warrant, one of the LA named users should record the activity on LLARD.

If you have any other questions regarding data security of information on LLARD or recording inspections, please contact the Local Authority Unit.

You are required to fill in the following data fields:

Lead Inspector

Format

Free text

Data required

The name of the inspector that undertook the inspection or if more than one person was involved who should be contacted if further information is required. (Max 60 characters)

Initial Inspection Date

Format

dd/mm/yy

Data required

The date when the first site visit was made or the date the decision was made that a site visit was not suitable.

Enforcement action  

Format

Pick from drop

Data required

Choices are:

  • No Notice Required [This covers any action short of a formal Legal Notice eg verbal or written advice]
  • Improvement Notice(s). PLEASE COMPLETE COMMENTS
  • Prohibition Notice(s). PLEASE COMPLETE COMMENTS
  • IN(s) & PN(s). PLEASE COMPLETE COMMENTS.

Comments - Key points only

Format

Free text

Data required

Only required if:

  • site does not require visit
  • issue relates to LPG supplier
  • standards will not be met, or

if enforcement action is taken. Please detail number of notices issued and the regulatory breaches

LPG Campaign Outcome 

Format

Pick from drop down menu

Data required

  • Choices are:
  • Installation meets all applicable standards.
  • Enforcement action taken to achieve compliance. PLEASE COMPLETE COMMENTS
  • Standards not met, no enforcement action taken. PLEASE COMPLETE COMMENTS
  • Site not suitable for visit. PLEASE COMPLETE COMMENTS:

Date Installation is compliant

Format

dd/mm/yy

Data required

The date at which the site's LPG installation was viewed as being compliant.
FILLING IN THIS DATE IS CRITICAL AS IT IS USED TO SHOW THAT LPG RELATED INSPECTION ACTIONS ARE CLOSED OUT

LLARD contains only limited data and LAs may wish to store more detailed information locally. The guidance provided for HSE inspectors is shown in the main OC in paragraphs 38 -44 and may be adopted by LAs if they wish. Or LAs may wish to use the template/aid memoire in Annex 5 that was developed by Kent and Medway to support their local visit reporting.

Annex 5 – Optional template/aide memoire for LA local record keeping

Kent and Medway LPG tank and pipework project Inspection Proforma

  • Date –
  • Location –
  • Inspector Name –
  • Questionnaire Returned? -            
  • Site Contact          
    • Name -
    • Phone -     
  • Person met at inspection  
    • Name -
    • Phone-
  • Supplier - 
  • Supplier COIN Ref (Page 13 OM2009/08) -  

Storage Vessel (tank)

  • Number of tanks -                    
  • In same location? -
  • Manufacturer -            
  • Tank Capacity -
  • Test Date -       
  • Type of gas – Propane or Butane? -
  • Condition of tank -
  • Details of any corrosion -
  • Is the tank adequately ventilated? -
  • Suitable separation distances? -
  • (Topic Inspection Pack, page 22) -
  • What is the supply used for? -
  • Is the vessel bonded to an earthing point? -

Environment

  • Is there a 'no smoking/no naked flames' sign in place? -
  • Notice for gas leak instructions? -
  • Combustible material away from facility (eg long grass and vegetation, wooden pallets)? -
  • Tank suitably protected from vehicle impact? -
  • Security – adequate protection from interference (fence/
  • Control valve lock/key control)? -
  • Any drains/culverts/ducts/low lying areas for LPG to accumulate? -
  • Facilities for delivery vehicle/can driver see vehicle and tank during delivery? -

Visible Pipework

  • What material is above ground pipe work made of? -
  • Condition of pipe work/signs of corrosion (metal pipework)? -
  • Polyethylene pipework protected from UV degradation (ie sleeved with protective material such as glass reinforced plastic (GRP)? -
  • Is it in contact with other surfaces (spacers used to keep pipe work away from concrete, brickwork), pipework or conduit? -
  • Metallic pipework provided with cathodic protection? -

Underground pipework

  • Is the buried pipework polyethylene?
  • Is it connected to steel risers?
  • Is pipework subject to inspection, examination and maintenance strategy?
  • Risk factors (circle those relevant)
    • Pipework more than 15 years old (pre 1993) (caution:tank may have been replaced with old pipes!)
    • Ground liable to movement
    • Signs of excavations or building work near pipe
    • Ground been resurfaced since pipe was laid
    • Traffic passes over the pipework route
    • Other….

Risk of Fire/Explosion

  • What pressure is the gas in pipework?(medium pressure above 75mbar increases the risk)
  • Route of pipework?
  • direct (lower risk) /  parallel to building (higher risk)
  • How does the pipework enter the building?(Below ground level / Is pipework sleeved as it passes through the wall)
  • Could vulnerable people eg limited mobility be affected by a leak?
  • Does the building have a basement or below ground service ducts where gas could accumulate?
  • Are there other occupied buildings sited below the level of the installation where gas could migrate?

Management

  • Site plan for dealing with leak or fire?
  • Have employees received information/instruction/training on properties of LPG, management of combustible materials and emergency actions?

Duty Holder Action Plan

  • Does the site plan to replace buried metallic pipework?
  • Is the timescale appropriate given any previously unidentified risk factors?
  • Should the site consider interim measures such as implementing an inspection and maintenance strategy, whilst awaiting replacement?

Pipework subject to an inspection and maintenance strategy

  • Does the strategy meet the standards set out in Appendix 3 of the topic inspection pack (page 33)
  • Does the strategy include:
    • A visual inspection of underground pipework?
    • Details of expected lifespan of pipework?
    • It's planned future replacement?

Action Taken (circle)

  • Informal Advice           
  • Letter/IVR        
  • Improvement Notice    
  • Prohibition Notice       
  • Deferred Prohibition Notice

Details:

Follow-up required (circle)

  • Phone call       
  • Letter  
  • Further Investigation   
  • Other M.E.C.

Details including timescales:

Score LPG Pipework (Please circle)

  1. No buried metallic pipework (ie replacement action completed). All above-ground pipework in good condition and subject to an appropriate inspection regime - no action
  2. Visible pipework in good condition, buried metallic pipework known to be in good condition, provided with efficient corrosion protection and subject to an appropriate inspection, examination and maintenance regime - no action
  3. Visible pipework in good condition, buried metallic pipework in unknown condition, replacement required - IN unless:
    1. dutyholder can provide evidence that pipework replacement is scheduled in line with risk ranking timetable and
    2. there is no evidence that pipework is in poor condition, and no additional risk factors.
  4. Where IN not issued, follow-up is still required to ensure replacement is completed
  5. Visible pipework in poor condition  - issue PN (where immediate risk)

Score LPG Storage tank (Please circle)

  1. Good standards, meets UKLPG Code of Practice in all respects, evidence of understanding and management of risks at site level - no action
  2. Single or minor failing, eg small amount of combustible material, minor deviation from separation distance - to be dealt with by letter, with follow-up
  3. More significant or multiple deficiencies eg failure to provide protection from vehicles in tank vicinity, significant amount of combustible material in area - issue IN
  4. Poor installation that fails to meet UKLPG Code of Practice in significant areas, lack of management control of risks - issue IN or PN (where immediate risk)

Admin

Time spent on site LPG Intervention _________

Time spent on LPG Follow-up activities _______

Time spent on site MEC _____________

Entered into COIN / LA HELEX on: ______________

Name _________________

Reference _________________

Additional information if Flexible Warrant in use

Inspectors' Home Authority _____________________________

Inspectors' Contract phone _____________________________

Inspectors' email _____________________________________

Footnotes

LPG topic pack.

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Updated 2023-02-16