Gas presents a low frequency, high consequence risk, which means incidents are thankfully rare, but tend to be significant. From age restrictions, to emergency stop button testing, to impact protection, safe receiving, retailing and maintenance – the retail of gas (autogas and bottle exchange) places unique safety demands on retailers. They key among these is the requirement to actively train all staff in the unique issues and controls associated with gas. In this Safety Spotlight we will explore the nuances around the training and monitoring requirements for retailers selling gas.
General requirement to train staff
There is a requirement in the law for all businesses to train their staff in the risks, hazards and controls associated with their work. This is a live and proactive requirement for all businesses in all situations and is captured by the various Work Health and Safety legislations across the country. These laws are proactive, which means that businesses can be fined for not being able to demonstrate that they have complied – even when there is no incident. An inspector can visit the site, and if the business cannot demonstrate that they have done the training, and that is appropriately addressed all of the required elements, then the business and the directors face fines of up to $500,000 for a first offence or gaol time.
When it comes to gas as a product there are even more requirements placed on the business.
Gas creates additional requirements
In addition to the general requirement to train staff in the risks and hazards of their work the business is also subject to the detailed requirements outlined in AS1596: The storage and handling of LP Gas – which sets specific training requirements for businesses to demonstrate that both the managers, and every staff member have undertaken. This standard is “called up” by the various State safety and dangerous goods laws – which means it is not a suggestion, it is a requirement.
Further there is a requirement that the business engage with its supplier to ensure that documentation onsite is appropriate and captures training, incident response, maintenance and emergency stop button testing.
Training Requirement Review
The business must ensure it can demonstrate that it has effectively trained staff in the following;
- The nature of gas products,
- Hazardous Zones during operations,
- Ignition Sources including pilot lights and static electricity,
- Portable Containers,
- Dispensing restrictions and responsibilities,
- Emergencies and responses – Leaks including onto people, fire and equipment failure,
- Deliveries and additional safety requirements onsite,
- Testing, Maintenance and Record keeping requirements onsite, and
- Roles and responsibilities onsite.
There is no specific format that is stipulated for businesses to train their staff in the risks and hazards associated with the work, though there are very detailed, industry specific training courses available, including the LP Gas Safety Module of the ACAPMA Petroleum Convenience Compliance course for staff.
Some courses go even further and form a valuable part of the Safety Management System, such as the completely online UNIGAS Training, which focuses not only on the staff training but also on managers training that includes an exploration in detail of the documentation, risks assessments and compliance measures that the business needs to take.
Lesson to learn…
The message for businesses is that they need to clearly understand that retailing dangerous goods comes with a requirement to train staff, and retailing LPG (including in exchange bottles) comes with unique and detailed requirements.
Businesses should engage with their supplier to explore options to meet the training and documentary requirements, and ensure that they are proactively meeting them.