Article by Andy Watson
This is a personal take on the role of the Petroleum Enforcement Officer and some of the challenges we face. Nothing in it represents the views of either my employer or, quite possibly, my colleagues.
I work for a Petroleum Enforcement Authority, which took on the day to day responsibility of the role in 2007. Before that, the work was done on our behalf by the local fire service. My background in trading standards is that of a weights and measures inspector, which I specialised in back in 1994 after 11 years in trading standards, learning my craft as a general enforcement officer. I started in local government as a trainee trading standards officer in 1983 having studied chemical engineering at University, but decided it wasn’t for me.
This combination of education and experience in the regulatory world means I understand much more about the construction, maintenance, operation etc. of a filling station than many.
Petrol is too dangerous!
Petrol is a product which, if it was being brought to the market today, would probably not get permission to be used by the general public; it is just too dangerous. We all know the hazards it represents but we, in the liquid fuel industry, hopefully appreciate that, and know what we are doing when handling it. This cannot be said of most of the general public.
One thing I recognise in relation to every single filling station, is that they are all different; no two ever seem to be quite the same. This means that there is rarely, if ever, a one size suits all solution for changes to an existing site, or a standard design that works for all new build developments.
As a Petroleum Officer, it is my local knowledge that I bring to bear on plans to make additions to a site; for example; introducing Electric Vehicle (EV) charging, to a site. We recently had a countryside site next to a major ‘A’ road where there was a desire to install EV charging points. A look at the plans suggested there would be plenty of room to do this but, knowing the site as well as we do, we could see that the chosen spot was right alongside the site entrance. This would place charging vehicles in just the wrong place; considering other vehicles entering the site at speed. So not such a good idea after all.
Hopefully the owners will think again. They must place EV charging in a better spot, on what is really quite a big site. The forecourt is quite a small area, but those other locations might cost a little more to utilise.
Different owners & operators
This same site highlights another problem for Petroleum Officers; it is owned by one company but operated by another. When work needs doing, in order to keep it safe to store and operate, there’s a little bit of buck passing goes on to get the work done. We get there in the end, but it is not ideal!
EV charging availability needs to expand if we are to encourage drivers to move from liquid fuel to electric. Filling stations would seem an obvious location to install these, especially those with small shops and/or cafes attached, so drivers can spend a little time browsing or eating/drinking whilst their vehicle charges. But safety must be paramount and high voltage electricity, petrol and motor vehicles are not a good mix. As the previous example illustrates, not all filling stations are actually suitable to have EV charging installed. Just because we need to expand the EV charging network, does not mean filling stations are the best place for them. Most forecourts were not designed with EV in mind.
Too often what I see is site operators taking their eye off the petroleum hazard and looking at how to make more money: the shop, the vacuum cleaner, the jet wash or EV charging, etc. But we all need to be very clear; if you operate a filling station where petrol is stored, the safe operation of this element of the site must override every other consideration.
For me though, the biggest problem is the Petroleum (Consolidation) Regulations 2014. After a very good consultation, the actual regulations were made in a hurry and contain flaws, just don’t try to get the Health and Safety Executive (HSE) to admit that, because they won’t!
As an example; consider the Prescribed Material Changes in Schedule 1 to the Regulations…
In order to obtain a Petroleum Storage Certificate (PSC) the applicant needs to provide copies of the ‘as built’ plans for:
- the layout of the dispensing premises;
- the containment system for petrol at the dispensing premises, including storage tanks and pipework;
- the drainage system for petrol at the dispensing premises.
Nowhere in Schedule 1 are changes to the drainage system mentioned. Why? If accurate plans are needed when the drainage is installed why do changes to it not matter?
The point I am making is that regulations, which were meant to simplify the legislative regime, have actually introduced uncertainties and confusion about what is, and what is not, controlled. We do our best; and, in conjunction with the Petroleum Enforcement Liaison Group (PELG) we do try to be consistent; but it’s not always easy.
Our Editor says;
It’s great to hear an enforcer speak his mind, and we thank Andy for his time in putting this article together. He stressed at the outset, that these are his personal views.
Anybody wish to take up the baton?