It is important that any works done on facilities are undertaken by competent persons to ensure the safety of the facility and the workers.  This is especially true in the case of works on a fuel site.  However, when it comes to works on a fuel site the historic quirk that led to a lack of formal fuel system qualifications, has traditionally resulted in a ‘competent person’ being one that has experience undertaking the works in the industry.  Recent changes to State safety regulations however, have resulted in a situation where sometimes the only persons ‘authorised’ to remove a tank, are people who have no experience in fuel systems at all, while those with experience struggle to get competitors to ‘sign them off’ as competent.  ACAPMA is seeking members input as this messy area of decommissioning is addressed with the regulators.

Licencing and Qualification Roundup
• WA – Class 1 or 2 (depending on tank height) demolition licence required
• QLD – Demolition licence required to remove tanks
• NSW – To remove tanks competent person must hold a demolition licence with a  Chemical Installation endorsement
• VIC – Licence and demonstrated tank removal experience for all demolition class licenses.
• TAS – Demolition Licence required
• ACT – Demolition Licence required
• SA – Demolition Licence required
• NT – No demolition Licence required but must comply with Demolition Code of Practice – Refer 5.10 – Fuel Storage Tanks for guidance requirements

Catch 22

“In addition to the licencing requriements in VIC and QLD in order to obtain the licence in the first place you must have fuel tank demolition experience.  This catch 22 is causing not a small amount of issues” explains ACAPMAs Elisha Radwanowski.

“So to get licenced to do the work, you must first be able to demonstrate experience doing the work.  This has resulted in new to industry operators seeking work placement with their competitors, or signoff from their competitors just to get qualified.  A situation that predictably, has seen its share of issues”, continued Elisha.

“It is vital that all persons who are undertaking works have the skills and experience to do so, however it is equally important that the regulatory frameworks recognise the reality, which is that for some qualified persons, who have been taking fuel tanks out of the ground for decades, the current approach may see them listed as ‘unqualified’ to do the work, while someone with a demolition licence who has never seen an underground fuel tank may be considered ‘qualified’.  This at the same time as the fuel tank fleet ages out and needs replacement, and more and more ‘works’ are scheduled”, added Elisha.

“ACAPMA is hearing some pretty stunning stories of very experienced petroleum contractors who are having to ‘call in’ greenhorn demolition companies at significant additional cost to the client, simply because the contractor cannot find a competitor willing to sign off on their own experience.  There is clearly room for exploring more practical ways of ensuring safe compliant operations, without distorting competition and driving up the cost of site works”, concludes Elisha.

ACAPMA is seeking comment, suggestions and case studies from fuel contractors, fuel site operators and stakeholders on this vital area of decommissioning of tanks, ahead of engaging with the regulators at a State and Federal level in an effort to ensure that safe compliant tank decommissioning is available and sustainable nationwide.  Comments should be sent to communications@acapma.com.au by 15/4/2024 for consideration.

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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