Following a detailed consultation with industry and inspectors WorkSafe QLD has released a significant update to the guidance on compliance around abandoned underground tanks and the required notification scheme. ACAPMA advises all members to familiarise themselves with the new and updated materials.
Abandoned underground fuel tanks and associated pipework are a hidden danger. When unidentified, misjudged, or mismanaged, disused underground tanks holding flammable gases or flammable liquids can expose workers and the public to serious fire and explosion risks and cause significant property damage.
What is an “Abandoned” Tank?
The law defines an “abandoned” tank as;
an underground, partially underground, or fully mounded tank used to store flammable gases and flammable liquids (e.g. fuels, solvents, and resin solutions) at a workplace where the tank has not been used to store product for two years, or there is no intention to use the tank to store product again.
Based on a tank’s internal configuration, an abandoned tank could be either the whole tank, or a single compartment in a multi-compartment tank.
When is it “Abandoned” and when is it “Decommissioned”?
A tank, or compartment in a tank, that is no longer used to store dangerous goods, is considered to be abandoned if it has not been decommissioned appropriately.
In order to be considered ‘decommissioned’ the tank (or compartment) will need to have the risks associated with the dangerous good that was previously stored mitigated and declarations provided from a person of suitable knowledge and skill that this work has been done.
For example by filling the tank with an appropriate inert material such as with dry sand, gravel, slurry mixture or, for gas tanks—gas free, gas purged or compressed gas e.g. carbon dioxide (CO2) or nitrogen (N2).
Notification Requirement
The law places a requirement on the person responsible for the tank to notify as soon as practicable after a tank is abandoned (or a tank is discovered).
There are penalties that apply for failure to notify
WHSQ must be notified using the online eForm: Notification of an abandoned tank (s 367).
This involves a two-step process:
- Complete an online abandoned tank eForm and submit it to WHSQ as soon as practicable after a tank is abandoned or discovered. Do not delay notifying due to incomplete or missing tank technical information or wait to notify until a tank is removed, or decommissioned. Select initial notification in the online eForm, enter site and technical information available at the time, and submit the notification without delay to comply with section 367 of the Work Health and Safety Regulation 2011.
- Submit a follow up notification after an abandoned tank is made safe (removed, decommissioned etc) using the online abandoned tank eForm. Provide the required site and technical information and supporting documentation from a competent person offering assurance of compliance with section 366 of the Work Health and Safety Regulation 2011.
Learnings for all businesses
“The retention of accurate records for underground assets is vital for day to day compliance, but it is imperative that these documents and records are exchanged when a business changes hands. The current owner and occupier will be held responsible for the safe and compliant operations of the fuel location. It is not acceptable to be ignorant of the state and disposition of the underground petroleum storage system, even if the operator is new”, explains ACAPMAs Elisha Radwanowski.
“In the event that an operator has information gaps approaching Council for previous owner/operator information or seeking out land registers, or underground survey services is a first step to closing those document gaps”.
More Information
The new WHSQ Abandoned Underground Tanks guidance and resources can be seen at;
Abandoned underground tanks | WorkSafe.qld.gov.au
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