Buried metallic LPG service pipework initiative - Residential (mobile) home and parks and Holiday parks
Health and Safety Executive / Local Authorities Enforcement Liaison Committee (HELA)
Local Authority Circular
- Subject: Liquefied Petroleum Gas (LPG)
- Open Government Status: Fully Open
- LAC Number: 52/21
- Publication Date: 30/03/2012
- Review Date: 29/03/2014
This circular gives advice to all visiting staff including local authority enforcement officers.
This guidance should be read in conjunction with LAC52/19 rev1 and addresses activity and issues specific to residential (mobile) home parks and holiday parks where caravans are located on a permanent basis. It also applies to communal blocks on sites where touring caravans may be located on a transient basis.
HSE has used a survey to identify those residential (mobile) home and holiday parks that have buried metallic LPG service pipework carrying vapour phase LPG from a bulk storage tank around the site including potentially to accommodation units (eg static caravans). The results of the survey will be used to prioritise on a national basis replacement of metal pipework to communal buildings on these sites using the same approach as that applied to commercial premises. Communal buildings include eg club houses, shower blocks, swimming pools and inspectors should concentrate their attention on these areas in addition to examination of the bulk LPG storage tank(s) and enclosure(s) if there are patent defects.
The details of higher risk sites will be added to the LPG Local Authority Reporting Database (LLARD) for LAs to address as part of their work plans. To allow HSE to collect national information LAs are requested to complete details of their inspection on LLARD as detailed in LAC52/19 rev1.
If you do not have access to LLARD contact [email protected].
Inspectors should apply the same enforcement standards to the communal buildings as those previously applied in this initiative to commercial buildings – ie ensure that either (a) buried pipe work is already PE, or (b) if metallic is planned to be replaced and/or its condition monitored in line with programme timescales (see http://www.hse.gov.uk/gas/lpg/pipework.htm).
Static caravans or 'park homes' should be treated in a manner analogous to domestic situations involving houses; it is for the owner/tenant/landlord to make informed decisions based on information provided. HSE has decided that park owners should receive information to remind/advise the occupiers of caravans (and other homes) that it is important to ensure adequate natural ventilation exists beneath the unit to reduce the possibility of a build-up of LPG in the event of a leak. Lack of ventilation may be a particular problem where skirting is used. HSE does not consider that formal enforcement action to require sub-floor ventilation for caravans would normally be appropriate.
Where the occupier privately owns the caravan/park home, inspectors have no legal vires under HSWA 1974, although they can of course provide information.
For rented accommodation, it is reasonable to expect that the park owner will draw the attention of the landlord (and they may be the landlord) to the need for ventilation as follows:
- For low pressure LPG systems (ie <75mbar) only minimal ventilation is required to significantly reduce the risk of explosion; thus only caravan skirting that provided no ventilation would pose any risk.
- For medium pressure systems (ie >75 mbar to <2 bar) lack of ventilation in skirting would make the risk such as to justify inspectors writing in an advisory manner in the first instance. Only if a duty holder was to persist in failing to take any action should more formal enforcement action be considered.