Has the Time Come for Change?

and Mr. R.W. Smith (Tanker driver), of Ipswich, both pleaded guilty to charges of failing to lock a filling opening in a manhole on a road tank wagon, contrary to Regulation 12(2) of the Petroleum Spirit (Conveyance by Road) Regulations 1957.

The charges resulted from a routine roadside check when a 5 compartment (8,800 litre capacity) rigid road tank wagon was examined. The vehicle was, at the time, carrying 1,800 litres of petroleum spirit in No. 3 compartment, the others being empty, although numbers 2, 4 and 5 had earlier contained a total of 5,000 litres of diesel oil.

Examination of the manlids showed that number 4 was in the open position and could not be closed, and numbers 3 and 5 could be opened, but could be locked closed.

The prosecution, brought by SUffolk County Trading Standards Department,

resulted in the Company being fined £100 \Vi th £15 cos ts, and the driver being given a conditional discharge.

Kent

Conveyance by Road

Sidney Glover (Fuel Oils) Ltd., of Leeds was fined £320.00 with £20.00 costs at Dartford Magistrates Court on 16th August 1978 for a number of of the Petroleum-Spirit (Conveyance by Road) Regulations 1957.

A faulty fire shield brought a fine of £100.00 as did the fact that the tractor unit had not been approved by a government inspector. The failure to keep the manlids closed and the carrying of a key for the manlids each brought £50.00 fines. A £20.00 fine was imposed in respect of the to furnish the driver of the vehicle with a copy of the Regulations.

The writer wishes to express that this is his own personal view upon the subject and in no way reflects the view of any enforcing Authority. The object of the essay is to promote discussion and debate upon the subject of problems that arise and have arisen with licensed petroleum installations.

Question:Is the standard being adopted nationally by nearly all enforcing Authorities too high, and we being over cautious, or do we stay the same and remain unchanged in the light of today's experiences, when we are becoming accustomed to having and controlling some very dangerous materials and processes.

The last model code to be written on the standards to pe adopted for petroleum installation was 1968, perhaps the time has now come to update the standards of such installations in the light of experiences gained since 1974, when County Councils took over the responsibilities for licensing. I - W.A. ATHERTON, STATION OFFICER, BUCKINGHAMSHIRE FIRE BRIGADE propose to deal only with that part of the code which deals with the storage of petroleum spirit in underground tanks, and pumps as found on retail garage forecourts and farms, etc. The seperate code which deals with major installatioffi is another story. I think it is important at this stage to make distinction between existing installations and installations under construction. Let us take first of all the installations under construction and examine them in parts. The prime factor when siting tanks and ancillary equipment is, of course, public safety, but of course one has to look at part No. 2.1.2 of the code together with part 2.2.3 to see how the majority of Licensing Authorities arrive at the safety distance of 14'. I will deal with the distances later on when talking about other safety factors. I think it is well accepted, and good practice, to design the construction of the site as laid down, that is, to prevent leakage and corrosion. However, when talking of

the actual tank, is it really necessary for Licensing Authorities to stipulate that the tank should be made of steel? It has been proved by recent tests that other materials, for example G.R.P stands up better in fire situations than steel and, providing the material used was protected from mechanical and corrosive damage, why not use one made from plastic? I understand that some forward looking manufacturers did at one time construct petrol storage tanks and associated equipment made from plastic, but due to lack of customers, they ceased production. It would be easier to handle when being installed and cheaper cost wise, and of course would not be subject to corrosion by condensation etc., as steel tanks are. Therefore, it would have a longer life expectancy, and alleviate some of the problems that arise when a tank gets older, or is subject to corrosion.

Now, when it comes to the testing of tanks prior to them going underground, there have been all sorts of suggestions and thoughts as to what is the best way to achieve the results of such tests. Of course there is more than one method described of testing tanks other than pressure testing. Now surely if a manufacturer could and would give a certificate of guarantee as to the standard that the tank had been constructed to, surely the tank would not need to be subject to further tests. When companies and persons give the Fire Authorities certificates stating that complicated and dangerous pieces of equipment are satisfactory, surely then it would follow that someone such as a tank manufacturer would come into the same category. To the best of my knowledge nobody yet has approved any other type of material, other than steel, for vent pipes and fittings but for years now water and gas undertakings have been passing liquids and gasses through concrete and plastic pipes with no leaks and, providing they were suitably protected from machanical damage, surely it would be more advantageous to use a material that is not subject to corrosion as steel pipework is, and the problems that arise when a leak is found on pipework and the pipe has to be excavated.

The Siting of Pumps

Recent tests have proved that when one is discharging a product from a nozzle into a vehicle tank, the area away from the actual filling point is the only area liable to explosion. If one takes the situation that arises frequently on retail forecourts, that is the parking of vehicles on top of petrol storage tanks, or two vehicles stationary and filling up with petrol, when the car in the rear starts up its engine the safety factor for the electrical equipment of the vehicle does, of course, not apply. Therefore it would appear to make a farce of the division 2 area. Obviously pumps should be sited in such a position as to protect public safety, however, if one takes the distance of 14' (which has already been reduced from 20') from any boundary or occupied buildings, and asks the question why l4'? Well, it arises from the distance that is considered the danger areas when talking about division 1 and 2 areas and, as we know, this area starts from the centre and top of the pumps and starts to taper off at 10', downwards to the ground, and finishes at 14'. With modern pumps fitted with no rigid dispensing arms and 14' flexible hose, which when removed from the housed position as one does when filling a vehicle, where does one start measuring the 14' from? If the code is followed then the position of the nozzle makes a nonsense of 14'. So, surely it would be better to make the danger area smaller in circumference of the greater distance of the flexible discharge pipe, providing one kept the dividion 1 and 2 areas around the pumps and nozzle.

EXisting Installations

Of course, after four years of dealiLg with the problems associated with existing installations, it is with some hindsight that we can now look back and see the answers to the problems that have arisen over what we call 'sub standard installations', that is, those that do not conform with the model code in some way or another.

Well, of course, as we all know, the preface to the code says that it should be used on new installations, therefore, it is not really fair to expect that installations of, say 20 - 25 years old can be brought up to the present standards. Perhaps it would be better if they were treated with a completely new set of guidelines.