The transfer of dangerous goods in retail settings are a high consequence activity that must come with abundantly clear instructions, training and protocols.  Where that dangerous good is LPG the consequences of breaches during transfer can be catastrophic.  Following a series of identified breaches operators are reminded that nationwide regulators are targeting LPG compliance generally, and LPG Decanting compliance specifically.

LPG Decanting Recap

The decanting of LPG from a fixed cylinder on a fuel retail site to a customers portable LPG Cylinder is one of the highest risk operations at the workplace.  The risk of fire onsite while decanting LPG is always high, due to the nature of the transfer and the fuel itself.  The consequences of such a fire is rarely less than catastrophic  in its outcome, due to the highly flammable and compressed nature of the LPG product.

This is why decanting is often referred to as being a low-frequency-high-consequence activity.

Proper staff training and instruction on safe LPG decanting, and rigorous business focus on ensuring compliance onsite reduce the risk of incident.

Conversely unsafe decanting practices place the staff, customers, site and neighbours at serious risk of death.

“ACAPMA is aware that regulators in multiple jurisdictions are seeing distressing unsafe practices onsite including clamping the deadmans handle on cylinders and leaving cylinders to fill without supervision”, explains ACAPMAs Elisha Radwanowski.

“Such practices are manifestly unsafe, unjustifiable and dramatically increase the chances of a serious incident threatening life and property”, adds Elisha.

“The use of clamps, cable ties, screwdrivers, collars or clips of any type to hold open the deadmans valve is a serious breach and is NEVER ok.  ACAPMA understands that there is a customer service pressure that can exist that makes securing the site for the 5-7 minutes required to go through the decanting process, but this is no excuse for putting staff and the community at risk.  If the site cannot spare a staff member for the time to do the decanting safely then alternatives such as; limiting the decanting offering to specific times where additional staff are on site or moving to a cylinder exchange program that removes the need for decanting at all, should be employed”, explains Elisha.

Safe LPG Decanting requires that the operator;

  • must be properly TRAINED in safe decanting procedures
  • must have appropriate PPE on at all times
  • must NEVER FILL EXPIRED OR DAMAGED CYLINDERS
  • MUST STAY AND SUPERVISE the cylinder for the whole decanting process
  • MUST HOLD THE HANDLE of the cylinder for the whole decanting process
  • MUST CHECK FOR LEAKS on the portable and fixed cylinder after the decanting process

 

See; https://www.fire.nsw.gov.au/incident.php?record=recYCeH66ZgYXiir8 for more information about this incident from 2023

 

More LPG Risks…

  • LPG Cylinder LeaksWhile decanting onsite poses the highest risk, even the use of pre filled LPG Cylinders in a cylinder exchange program come with some risks that need to be addressed.Specifically the risk of leaks due to valves on the cylinders shaking loose in transit.All staff should be trained and instructed in the checking, identification and responses to leaks.
  • Operating LPG Cylinders InsideIt is both dangerous and illegal to use LPG gas appliances that are designed for outdoor use or cylinders in enclosed spaces, this includes in retail kitchens.It is a risk to the staff, to the business as well as illegal and very dangerous to use portable LPG cylinders inside, or to bring gas appliances designed for outdoor use inside.All works on a gas appliance (including the modification or addition to a gas kitchen set up) must be undertaken only by a qualified and licenced gas fitter.Following a series of incidents in recent years SafeWork NSW produced a series of resources, including video and poster media to bring attention to this particular risk.

    See; https://acapmag.com.au/2021/04/safety-alert-lpg-cylinder-fire-in-retail-kitchens/ for more information.

Learnings for all businesses

“There is a legal requirement for all businesses to train their staff in the risks and hazards they will face at work, and the controls needed to mitigate those risks, and the emergency response to take if controls are ineffective.  This need is well understood, but it is vital that businesses ensure understanding and compliance, particularly in areas where the risk is high likelihood and or high consequence” ads Elisha.

“It is not enough for a business to rely on an employees previous licencing, or dense policy documents.  The business must ensure that the vital information is effectively communicated to the employees and that the business takes appropriate steps to ensure that the employee not only understood the information, but is also complying with these vital instructions” adds Elisha.

“It is simply not enough to tell the employees what needs to be done to stay safe.  Businesses need to show, tell, confirm and observe.  This is true for all safety training, processes and policies, but it is a business imperative for high likelihood and high consequence risks” concludes Elisha.

LPG Cylinder Safety Resources

ACAPMA is finalising the updated LPG Cylinder Safety Resources, including posters and checklists now.  The updated pack, will be forwarded to members shortly and supports the staff and manager level training that is provided on this critical area as part of the ACAPMA Fuel Convenience Compliance (FCC) training – see; https://acapma.com.au/our-services/training/fuel-convenience-retail-training-solutions/ for more information.

More Information

Here to Help

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.

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