Growing industry and regulator concern about the management of Underground Petroleum Storage Systems (UPSS) in Australia is driving calls for stricter operational controls. These discussions include the potential introduction of mandatory certification and maintenance obligations for fuel retail businesses to better management consequent environmental and public safety risks. While such protections are warranted, the introduction of such controls presents significant implications for fuel retailers around the country.
Equally important is the industry’s responsibility to uphold its social license by aligning with community expectations on environmental protection and public safety. Ensuring that all operators manage UPSS responsibly prevents reputational damage and eliminates unfair competitive advantages gained by those neglecting essential asset risks.
Background: Time for Industry Leadership
During last year’s APFI Forum Contractors Workshop, stakeholders examined best practices in UPSS management and considered potential measures to enhance environmental safeguards. Attendees included representatives from state and territory regulators, fuel retailers, UPSS equipment providers, and petroleum contractors. The forum also featured insights from New Zealand and Europe on international UPSS management frameworks.
“The overwhelming consensus from the workshop was the urgent need for a Code of Practice for UPSS management in Australia. Participants strongly supported making such a code mandatory through regulatory revisions across all states and territories”, said ACAPMA CEO Mark McKenzie.
Recognizing this need, ACAPMA committed the association to a consultative process for developing a Voluntary UPSS Code of Practice at the end of the 2024 Workshop. ACAPMA advised that the development process would kick-off in March 2025, with the progress document to be presented at the 2025 APFI Forum Contractors Workshop in September. The draft code will likely be modelled along similar lines to the New Zealand Framework and is expected to incorporate elements of the Australian Institute of Petroleums (AIP) Code of Practice #4.
The Code Development Process
Under the leadership of CEO Mark McKenzie, ACAPMA will oversee the development of the UPSS Code and coordinate a national consultation process, with strategic guidance provided by ACAPMA’s National Petroleum Contractor Council throughout. The process will unfold in five distinct stages as briefly outlined below.
Stage 1: Project Establishment (February 2025)
This phase involves drafting the initial framework, defining the scope and structure of the proposed code. The National Petroleum Contractor Council will review the draft framework, ensuring alignment with industry needs and regulatory expectations. A consultative framework for broader stakeholder engagement will also be established.
Stage 2: Development of Draft Framework & Round 1 Consultation (February – March 2025)
ACAPMA will conduct Town Hall Consultations in Sydney, Melbourne, and Brisbane to launch the development process and gather industry feedback. These sessions have been scheduled as follows:
- Sydney
- Tuesday 25/02/2025, 15:00-17:00
- Gallagher Insurance Offices – Level 16/100 Arthur St, North Sydney NSW 2060
- Melbourne
- Tuesday 04/03/2025, 15:00-17:00
- Gallagher Insurance Offices – Level 4/289 Wellington Parade S, East Melbourne VIC 3002
- Brisbane
- Tuesday 18/03/2025, 15:00-17:00
- Gallagher Insurance Offices – Level 23, 145 Ann Street Brisbane, QLD 4000
Given the engagement of east coast regulators in recent discussions, these sessions will focus on Sydney, Melbourne, and Brisbane. However, stakeholders from other jurisdictions can provide input via ACAPMA’s Industry Consultation Page.
Stage 3: Draft Code Development & Round 2 Consultation (April – June 2025)
ACAPMA will refine the draft code, incorporating stakeholder feedback, with oversight from the National Petroleum Contractor Council and input from regulatory bodies.
Once completed, the draft will be shared for further consultation during a second round of Town Hall Meetings which will be convened as follows:
- Melbourne
- Wednesday 14/05/2025, 15:00-17:00
- Gallagher Insurance Offices – Level 4/289 Wellington Parade S, East Melbourne VIC 3002
- Brisbane
- Tuesday 27/05/2025, 15:00-17:00
- Gallagher Insurance Offices – Level 23, 145 Ann Street Brisbane, QLD 4000
- Sydney
- Tuesday 03/06/2025, 15:00-17:00
- Location TBA Sydney City CBD
Stakeholders in other states and territories will again have the opportunity to submit feedback via the ACAPMA Industry Consultation Page.
Stage 4: Code Finalisation & Stakeholder Validation (June – September 2025)
The finalisation phase will involve review and validation discussions with the National Petroleum Contractor Council and key regulatory stakeholders to ensure the Code’s robustness and practical applicability.
Stage 5: Official Release of the Voluntary Industry Code (September 2025)
The final Voluntary UPSS Industry Code will be formally launched during the Asia Pacific Fuel Industry Forum (APFIF 2025) Contractors Workshop, which will be held at The Star Gold Coast on 16 September 2025.
How to Get Involved
ACAPMA encourages industry-wide participation in shaping a practical and effective UPSS management framework.
“This issue—and the associated financial, regulatory, and environmental risks—has been the focus of increasing industry and regulatory discussions over the past decade”, said Mark
“We strongly encourage all industry stakeholders and regulatory representatives to actively participate in the development of a national UPSS management code”, added Mark.
To stay updated on the process or register for one of the Town Hall Sessions, please visit the Industry Consultation Page on the ACAPMA website (UPSS Code Consultation – ACAPMA).
ACAPMA
