As part of the ongoing commitment to safety and compliance ACAPMA has again taken the Chair duties for the Fuel Industry Safety Forum, the cross jurisdictional stakeholder engagement forum that brings together regulators and industry to understand issues, trends and explore opportunities to learn from each other and deliver tangible safety and compliance outcomes for the whole industry.  This latest Forum saw a consistent theme of concerns from regulators that it is time for operators to get into the detail in order to demonstrate compliance.  The Forum heard from Safety Regulators across the country who made calls to the industry participants to encourage focus on a variety of areas across fuel wholesale, transport and retail now and into the future.  The participants agreed to the development and circulation of resources and information to assist the industry in demonstrating best practice.

 The Forum received a presentation from EPA NSW on the changes to the NSW DG Regulation and the development of guidance material for transporting dangerous goods and the emergency response and prohibited routes that come with transport operations.

“We are calling on all operators to ensure that placard loads are kept off those prohibited routes” explained the EPA NSW.

“EPA NSW is developing guidance for transport of DG and the Forum will be taking that guidance and placing it into training and communication materials for all operators”, explains Forum Chair, Elisha Radwanowski.

 The need for fuel wholesale and retail sites to keep up to date with Notification Requirements was a common call.

“We heard a pretty consistent message from the different State safety regulators that all fuel retail and wholesale sites need to get on top of their notification requirements.  Notification to the regulator, and fire and emergency in many jurisdictions, needs to be given a priority review by fuel retail sites particularly.  It is necessary for sites operators to provide updated information when things change and this includes when tanks are added or removed” adds Elisha.

“We are still seeing sites that have, for example, removed LPG from the site, and they have not updated their notification.  This is a problem because they are non compliant with the regulations if they don’t have accurate and current Notification, but it also makes a difference as to the standards that the site has to meet.  LPG on a regular service station can push that site into the higher MHF category which comes with different requirements, so if it is removed and the site does not do the Notification they remain in a category that no longer applies” explained one of the State Safety Regulators.

Another common area identified by the regulators was Site Plan compliance.  While it was noted that the information is usually included in the main the format, size and minor inclusions have been identified as missing.

“Most site plans are ok, but we are still finding that they are not the right size, which is really important in an emergency, or they are missing little things like indication for North.  Its easy to understand that these elements can seem silly to a site, but they really are vital in dealing with practical emergencies.  One big thing we are calling for is for sites to ensure that the neighbouring business use is identified, it matters a great deal what the neighbours do when there is an emergency at a fuel site – is it a general retail neighbour, a factory, a pool chemical store, a house – the answer makes a real difference to how the emergency response” explained another State Safety Regulator.

“Site plans, and manifests and Emergency Response Plans while we are at it, are vital emergency response and compliance tools, and they have very detailed inclusion and submission requirements.  ACAPMA encourages all operators to add the manifest box contents to their regular paperwork reviews, to check more than just if the documents are in the box, and to ensure if there is a change onsite that these documents are updates and submitted.  Current information can have a big impact in an emergency” continues Elisha.

Other common safety areas identified by multiple state regulators included; Incident Notification, need to understand the local Decommissioning of Tanks requirements and importance of Maintenance.

“There is a need to ensure that the evidence of system maintenance is kept and available.  It is clear the maintenance is happening, but the records are often patchy and that is leading to non compliance” explained one regulator.

“For us it is important that sites understand that when they are decommissioning a tank removal has to be the standard response unless there is a structural reason not to remove the tank it should be removed”, added another.

“The Forum heard loud and clear that there appears to be confusion over when, how and what to notify to the safety regulators, a problem that is compounded in border areas.  As a result ACAPMA will be developing a National Safety and Environmental Incident Notification Ready Reckoner for fuel sites to give operators a simple and industry customised view of when to reach out to their local regulator.  This Reckoner will be published in September 2022” explains Elisha.

The Forum also heard some local jurisdiction concerns, that while less universal are worth all operators understanding and being on the lookout for in their businesses.

“We are concerned about the use of QR Codes at the pumps in the hazardous zones.  Mobile phones are an ignition risk and the sites need to be keeping them out of the zones not encouraging them” explained one regulator.

“These are isolated but we have also seen a few sites with caution signage on pumps that is too small or hard to read and thus not compliant with AS1940, as well as seeing a few sites that are storing their empty portable LPG canisters upside down – which is unsafe and can lead to leaks and valve failure”, noted another regulator.

The Forum also received a presentation from WA regulators on the need to ensure that Pump and Hose Conductivity Tests are conducted regularly in order to ensure safe operation and avoid static fires.

“Spot testing following isolated incidents where static was determined to be the likely cause has highlighted the need for sites to review their conductivity testing.  The resistance between the nozzle spout and earth has to be a maximum of 1 megaohm.  This should be tested and documented regularly” explained the regulator.

The Fuel Industry Safety Forum will meet again in August where the focus will be on the emerging safety, compliance and emergency responses associated with EVs and Hydrogen in a fuel site context.

Here to Help

For more on site plan compliance see; https://acapmag.com.au/2022/02/safety-highlight-nsw-notification-requirements/ or reach out to ACAPMA for guidance on Notification, Site Plan and other safety compliance areas in your jurisdiction.

Safety Highlights are things to consider, implement and watch out for in your business.  They are provided as general information for you to consider and do not constitute advice.  You should seek further advice on your situation by contacting your legal advisor.  ACAPMA members can access resources and receive advice, guidance and support from the ACAPMA employment professionals via employment@acapma.com.au  , it is free for members.  ACAPMA Membership delivers this and more benefits, see; https://acapma.com.au/membership/    for more information.

Elisha Radwanowski BCom(HRM&IR)
ACAPMA

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