BY WIDENING YOUR EXPERIENCE-J. H. B. HORNBY

Presented at the Annual General Meeting of the Association for Petroleum Acts Administration, held at Solihull, 1 Bth April, 1967

·by widening your experience .. .'

A Paper on the petroleum scene in the United States and Canada

by

J. H. B. HORNBY, D.M.A., D.S.A.A., M.l.W.M.A.

Deputy Chief Inspector of Weights and Measures, City of Oxford

In introducing his paper, Mr. Hornby referred to the Churchill Trust, which had enabled him to make a lengthy visit to the North American Continent. A fund was set up after the death of Sir Winston Churchill as a tribute to his memory, and donations to this fund enabled some 60 or 70 persons in all walks of life to visit foreign countries to further their education and to bring back something of value to their own country. Mr. Hornby said that his own fellowship was connected with Consumer Protection matters and, of course, Consumer Safety is a part of Consumer Protection. He said that you might well think that six months is a long time to devote to a subject like Consumer Protection, but its width was still not fully realised by many. Also there were constant distractions. With a magic place like San Francisco, say, an hour away, one's thoughts were hardly on "how they install their tanks" or "the intricacies of their consumer protection services". It was necessary to restrict one's sightseeing to the first day and get down to the hard work later on.

It was a question, therefore, of ''fighting the clock" and he thought the best thing to do would be to look at the current problems concerning us as petroleum officers and see what the Americans and Canadians were doing, and so he looked at the points he thought would be of special interest to members of this Association ; these are enumerated in the paper. Mr. Hornby commented on the problems of diversity, inasmuch as it is extremely difficult to go into a large Continent and at the same time trying to see what is done in the various authorities. The size of the country gives rise to the tremendous range of practices and this was illustrated when he flew into Kennedy Airport on the first day of the airline strike in July, and the scene, as many thousands of people were milling around trying to get to different parts of America, can well be imagined. His objective was Denver. Eventually he was found a seat on a plane to Pheonix which, on a large map of America, looked a comparatively short distance of, say, about J 20 miles, which appeared to be reasonably satisfactory. During the flight Mr. Hornby wondered just how far Pheonix was from Denver. On getting his map out he reconsidered it may be as far as 300 miles. When he did get to Pheonix it was rather hot, being 106°, and it was then to his horror that he found the actual distance was 826 miles.

His second experience was in Los Angeles. He was in his hotel in the middle of the town, and having nothing special to do in the evening decided to take a walk down to the waterfront. Having had the experience of the distance between Pheonix and Denver, he decided to first check the distance and found it was 23 miles! Los Angeles is 50 miles across in any direction and Chicago 30 miles by 10. These experiences Mr. particularly illustrate the Hornby described as 'typical American distance shocks', which reason for difficulty in obtaining uniformity of administration. show the size of the country and Petroleum officers, however, have some excellent guidance from in the United States and Mr. Hornby would like to see some this Association. eminent bodies concerned with this type of administration sort of regular cornmunication with these people from

Mr. Hornby, in his final remarks, stated that he had obtained numerous pamphlets and information on all aspects of Consumer Protection and Safety and that, ({there were any points dealt with in his paper or introduction that members were interested in, it was possible that he had something in printed form which he would be willing to pass on to any interested member.

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"By widening your experience you will be able to give more to this country on your return".

Such is the stated outlook of the Winston Churchill Memorial Trust towards its travelling Fellows; and the money so freely given by the British people towards this fund is being used almost exclusively to serve its Fellows and t~e Nation in this way. My own experience was to be widened. in consumer protection which, these days, commonly mcludes consumer safety. The very existence of the Association for Petroleum Acts Administration is because of the concern for petroleum products and, the safety therefore, of the consumer of the work of the petroleum officer.

My duties as such in Oxford involve me daily with work of t~is kind, a~d I possible, find time felt that during my travels I to take a look at the North should, if American petroleum scene. Six months, at that time, seemed to be enough-but I had set myself a lot to do. Some things had to be missed, ~f course, and the most profitable allocation of available time was a big problem and something which had to be al~ays kept in mind. So I took a look at the objects of this Association to see how, in some small way, I could help to further them. These are: (a) The advanceme~t of .scientific, t~chnical and legal knowledge requued m the admmistration of the Petroleum Acts and associated legislation. (b) The supply and interchange of information relative to (a). (c) To a.tt~in, s.o far as is practicable, uniformity in the adm1mstrat10n of the Petroleum Acts and associated legislation. (d) To promote the formation of Branches. (e) 1:0 . co-operate s1mllar to those with other bodies having objects of the Association or concerned with the safe handling, storage, or distribution of substances falling within the purview of the Petroleum Acts and Associated legislation.

Those which really were appropriate were (a) and (b), and probably (e). The advancement of scientific and technical knowledge was the object with which I felt I could do the most. The U.S.A. :particular!y i~ accepted as being well ahead in the application of scientific and technical knowledge and it was ;riot unreasonable to assume that they would be in our particular field. My plan then was to take some of our c~rrent Problems and see how the North Americans deal wI ~th them, 1ound. and this paper will set out some of the things

I will take first that topical subject-· Latched Nozzles The introduction of the latched nozzle most important development of concern is to probably the us for many ~e~rs,

an~ they fir~t_came into use in the U.S.A. ten years g · Durmg my VlSlt I never saw one conventional nozzle a~ywhere, and the position now is that all States accept t e~ happily alth<?ugh some did not in the early stages of theu ~se. There still may be a few hesitant authorities but even if their laws do prohibit latched nozzles they ar~ not enforced. Both the National Fire Protection Association of America and the Canadian Authorities allow their use only where the pumps are operated by a service station attendant, and they are expressly prohibited on selfservice dispensers. In Ontario too "constant immediate attendance" is required where the latched nozzle is used. I travelled comparatively few miles by car, probably about 4,000 mainly as a passenger, but I did hire cars on two occasions. I made a special point of asking about latched nozzles whenever the cars were filled, and this was in a wide variety of places often many hundreds of miles apart. Attendants seem genuinely amazed when I told them they were not in use in England. I would estimate that I asked a dozen attendants if they had ever had trouble with the device, and only once was there a positive reply-"It jumped out once, but shut off when it hit the ground".

I think these will now come in quickly, and the particular advantages I noticed are: 1. Several vehicles can be safely dealt with at one time -something I watched with considerable anxiety at first. 2. If the filling station is not too busy, the attendant invariably occupies himself cleaning the car's screen, windows, mirrors and lights, something which is bound to contribute to general road safety. The American driver shows no surprise when oil, water and battery are checked without asking. 3. Having seen them in action, I think they are no less safe than the conventional nozzle. If the driver is smoking, for example, the attendant is free to go to him and ask for his co-operation. There is less danger on a busy day because the attendant has more time to look for hazards. "Fill her up" service will probably be with us soon, and this should mean less visits to the filling station.

I feel that the Association must do everything in its power to ensure that it recommends only the nozzles which have been proved to be satisfactory over the years in other countries. The pioneering has been done for use, and we should be prepared to copy. Underground car parks Underground car parks are not so numerous as I expected. For one thing, people are happier to build up rather than down. A recent Chicago apartment develop-. ment does not start the living accommodation until the 18th floor-the first 17 being for car parking. Outside the city centres, there is so much space that cars are parked at ground level in the open. Dwelling house developments and supermarket areas invariably have ample surrounding space.

Where there are underground car parks the approach to safety is not unlike our own. If there is any uniformity in the North American Petroleum scene it is certainly not to be found in the construction of basement car parks. Requirements vary not only from State to State, but from City to City, and most building codes in the U.S.A. do not distinguish between garages used exclusively for the parking of cars and those used for other related activities. To further complicate the position there are various recommended Codes of Building

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practices and the general feeling is that the fire hazard of parking garages is very low. In a booklet "Fire Safety in the Atomic Age" the National Fire Protection Association states, in relation to this type of garage: "The principal combustible material is the gasoline in the tanks of automobiles, plus a smaller, almost negligible, amount of combustible upholstery. The total fuel in the contents of the building can be easily calculated by assuming an average number of gallons of gasoline in each tank and multiplying this by the number of autos for which there is floor space. Even if you neglect upholstery and take each tank as twenty gallons full, you have about 130 pounds of gasoline per tank at 20,000 British Thermal Units per pound, or 2,600,000 units per car, which at 200 square feet per car is only 13,000 units per square foot, a very low fire loading.

Actually the fire loading is much less if you consider the entire storage area".

This is not, of course, quite the same as the explosion risk, but nonetheless, this authoritative opinion seems to encourage a not too severe approach.

As to whether or not a garage should be treated as subbasement for our own purposes, the usual American definition of an open parking garage might help-these " . . . are structures having not Jess than 50 per cent of two sides of the structure open at each storey . . . "

Enclosed parking garages (our basement or sub-basement garages) are usually regulated when they are built to hold more than 20 cars. In such cases mechanical ventilation is always required, and its capability is specified in a somewhat different way from ourscharge ! cubic foot of air per minute it must for each simply square disfoot of floor area. Automatic sprinklers are required in basement garages with a floor area exceeding 5,000 square feet (parallel to this Association's recommendation) and looked upon as desirable in all enclosed garages exceeding a height of 65 feet. I know of no rules for ramp gradients. Provisions on alarms, exits, fire resistance of the structure are similar to our own.

An underground car park in Columbus, Ohio, is dealt with in some detail (page 38) in the April, 1967, issue of The Bulletin, and the main features here are: 1. the public address system, 2. the powerful ventilators, 3. the outside traffic accumulation, and 4. the fault of smooth concrete.

Self-Service

I did not get very far with my investigations into this problem. The reason is simply that it was prohibited in all the places where enquiries were made. Both Los Angeles and Ontario have specific prohibitive sections in their laws, at any rate for Class I or Class II liquids. In its 1966 Code, the N.F.P.A. does allow self-service, provided that dispensing of gasoline is under the observation and control of a competent attendant at all times. Emergency controls are required too, and clear operating instructions.

The reasons for this lack of self-service are in no way obvious, and my own view is that the greater tank capacity of American vehicles, and the widespread competitive night service, all contribute. There are very few motor scooters in the U.S.A.

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Filling Stations

The only filling stations I examined in detail were in California, and the observations are dealt with in an article on page 97 of the October, 1966 Bulletin. The most significant points here concern the installation of tanks without concrete or special backfill (except in dock areas), the leaving open of vent pipes at the top and the ban on the use of liquids for cleaning or any other purpose where their flash point is less than 100°F. The other points are closely associated with the particular circumstances of climate and the American tradition, and do not really affect us.

My overall impression of the American Filling Station is that a lesser concern for safety is balanced (from the customer's point of view) by a greater interest in good service. Warning notices are not, in general, as prominent as ours, and advertising is always the first eye-catcher.

There is a proliferation of small two-pump service stations.

Installation of underground tanks

I have got into the habit of classifying things found as "big surprises'', "small surprises'', and "that which was expected", and the big surprise in petroleum matters was that our ideas of tank installation are quite different from those of authoritative bodies both in Canada and the U.S.A. Although there are those who like the brick vault and the concrete shell, the majority consider them unnecessarily complicated and expensive-and, and this is !he point-no-one seemed satisfied that they helped much m the fight against corrosion.

In the City of Los Angeles, one of America's foremost petroleum safety authorities, all that is required is well tamped earth, with sufficient strength at the surface to take the stresses it will be subject to. If this is vehicular traffic, a c<;>ncr~te slab is specified. Only in their Pacific waterfront reg10n IS a concrete chamber (note not a shell) required. The conditions of Canada's Dominion Fire Commissioner require well tamped soft earth or sand; with a minimum t<;>P covering of 2ft. of earth, or alternatively lft. with a 4u;i. concrete slab. Where vehicles pass over the top, these thick?,e~ses are roughly doubled. "Solid, well-packed eart~ Is all that the new Ontario Gasoline Handling Act reqmres.

The august American Petroleum Institute goes further than most in recommending "proper backfilling of the tank on all sides with a minimum of 6 inches of washed sand". Unlike Los Angeles, they suggest that the tank be strapped on top of two concrete beams where there are sub-surface water conditions.

Nobody seemed convinced that either the vault or the ~oncrete shell were justified. Neither, it was felt, would hep petrol in or moisture out, and although there was a c ance of less corrosion, it was remote, and, once there was a leak in a concreted tank, the problems were enormous_. I was asked many questions about this British practt~e. "Does concrete stop corrosion ? Will the shell ~ontam a leak ? Is concrete inexpensive ? Is it used mstead of the bituminous coating ? " When my answers were ."No'', I began to re-think very seriously the whole question of the use of concrete.

Consequently I am now uncertain myself and although I was very much a concrete advocate before I crossed the Atlantic, I am not now !

I would like to think that the Association is in line with the Home Office and more sure of concrete than I am ; and that we are not all making one awful mistake which will leave a great headache for the petroleum officers of the 1980's and 90's. I do hope that I leave this meeting once more re-assured.

Cathodic protection for underground tanks (January Bulletin, page 9; April Bulletin, page 40) could profitably be given more consideration. The fibre-glass reinforced plastic tank was dealt with in January, page 8.

Classification of hazardous liquids

The principle of classifying dangerous liquids, which is common to both the U.S.A. and Canada is an appealing practice. Here again the unfortunate thing is that the classification varies from place to place, and uniformity is lost. Sometimes such liquids are called class A, B, C and D; sometimes I, II, III, IV and so on; sometimes they are further subdivided, sometimes not. To illustrate the point this extract from the Canadian Gasoline Handling Act will serve: "flammable liquid" means any gasoline or associated product having a flash point within one of the ranges described under the following product classes: (i) Class I products, having flash points ~elow 73~F., and include such products as automotive gasohn~, aviation gasoline, naphtha and alcohol-based antifreezes, (ii) Class II products having flash points from 73°F. to 150°F., inclusive, and include such product~ as Type l, 2, 4 and 5 fuel oil, diesel fuel, kerosme, brake fluid and cleaning fluid, (iii) Class III products, having flash po_ints . above l 50°F., and include Type 6 fuel oil, engme o~l, gear oil, automotive greases, shock absorber flmd and glycol-based anti-freezes.

This classification does not, however, extend to nonpetroleum products, but does .Pro_vide a greater cont~ol over oils and paraffins. Regulat10n IS sound, and accordmg to the likely hazard.

The word FLAMMABLE

This word of warning is used universally in North America and our "inflammable" is never seen. Canada remarked that there were enough immigrant problems, without having to explain that "highly inflammable" means "very easy to set on fire" ! In the English language the prefix "in" usually denotes "not", and it would be interesting to find out how the word "inflammable" came to mean "flammable" in the first place.

In the U.S.A. the N.F.P.A. code recommends, for example, the words FLAMMABLE - KEEP FIRE A WAY as a warning on storage cabinets. I like this very much. EXTREMELY FLAMMABLE is recommended for cans by the A.P.I. Ontario requires FLAMMABLE on any vehicle carrying gasoline or associated products in any quantities.

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Fowler of "English Usage", states that "Flammable" is now rare, and goes on to say that when it does appear it is in the form "non-flammable". Before we go on to "non-inflammable" I think we should endeavour to go back to ":flammable" and recommend its use always. Abandoned cars

I soon grew tired of asking about abandoned cars, because there seems to be no safety problem. With these unbelievable scrap car gobblers in the wreckers' yards, proper disposal is encouraged and is easy. No-one knew of any accident in which a child was injured. (The big problem, incidentally, is abandoned refrigerators, into which small children climb, only to suffocate when the door closes on them. All refrigerators are now required to have doors which also open from the inside). Highway transportation

North America's control of vehicles engaged in the transport of gasoline did not seem to be as stringent as ours. For example, nowhere did I find a requirement for the exhaust system to be in front of a protective shield. Los Angeles required, however, a metal shield adequate to prevent contact between the muffler or the piping and the fuel carried. The Ontario Act requires the exhaust run to be clear of combustible materials, and to be terminated in such a position that fumes or heat from it shall not create a hazard to the tank contents or to a filling or discharging facility.

Some authorities require tankers to carry wheel chocks, and to use them at all times when loading or unloading. This has both advantages and disadvantages.

I noticed in many places completely unprotected exhaust systems running up the back of the cab, and I raised the matter with a tanker manufacturer just west of Toronto. His view was that if gasoline did contact the hot exhaust there was a definite hazard, but he felt the chances were so remote that additional protection was going too far. I did not agree wi tb thjs view but did not press the point, because I wanted to improve rather than disturb Anglo/ Canadian relations !

This was the main point on tankers. Another was that I could find no equivalent of our written certification that a tank will accept the quantity to be delivered. Electrical requirements, fire extinguishers and vehicle construction were similar to English requirements. Tank trailers (called pups) were very common.

Looking back now through what I have written, it does seem to be a strange disjointed selection, but I hope there is something in it for everybody.

If these few points will serve as food for members' thoughts, particularly those with special interests in them; and if they lead to a few re-considerations by those who know the subjects well, then I shall be satisfied that my Fellowship obligations are, at least in part, fulfilled.

I confess to great difficulty in coping with the variety of practices found. There are so many in this huge continent, and this, whilst understandable, is a big problem to a travelling observer. It was rather like visiting a dozen countries rather than just two !

It would have helped if I could have found an equivalent of this Association, but this was not possible. Nonetheless, there is excellent guidance for the North American petroleum officer from a large number of eminent bodies, and I discovered four in my limited enquiries. They were the American Petroleum Institute, the National Fire Protection Association, the Automotive Safety Foundation, and the Domjnion Fire Commissioner for Canada.

I would welcome the fostering of friendship with these bodies, and a healthy interchange of ideas, because I am convinced that our countries have a lot to learn from each other and, in a shrinking world, such co-operation can do nothing but good.

Many of the things I learned were, for me, a real widening of experience, and that now I have returned I can ... "give a little more".

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questions

Mr. G. Ashley-Wayne Tank & Pump Co. Ltd.

Mr. Ashley asked whether it would be more correct to use a term "latch-open automatic nozzles" to avoid confusion for traders who had no previous experience with such equipment. . Mr. Hornby agreed and thought it important, particularly m the early stages of the use of a device of this kind. * * *

Mr. G. Balshaw-Shrewsbury

What control if any, is exercised in the U.S.A. concerning L.P.G. and have the Americans progressed as the French have recently done, to underground filling stations?

I am afraid I did not investigate L:P.G.jrom the petroleum angle and did not see or hear of any underground filling stations.

* * * Mr. J. Beer-Worcester

Is it true to say that the type of latch-open automatic nozzle used in the States can be used on every type of car, because I have heard that certain types of nozzles which may be introduced into this country will just not work on some car model~, and secon~Iy what is their approach as far as general hcence conditions are concerned to this sort of thing ? :i:-es, there were nozzles of this type used in the U.S.A. which were so designed as to operate in any type of car. * * *

Some general discussion on this point followed, with Mr . .W· C.R. Dale-G.L.C. pointing out that additional reqmrements over our American counterparts made by the H?me Office required the addition of an inertia device t~ be mcorporated in the nozzle, which, in fact, prevented dis~h_arge of spirit when the nozzle was in a horizontal position. Mr. D. Hall-Newcastle-under-Lyme

Wit_h regard to the phrase "constant and immediate atte?~ion" used in the Ontario Gas Act, what is the posit10n of an attendant who latches a nozzle, must he th~n remain and watch it fill ? If so, then in my opinion, this would defeat the object of using this type of equipment. "C onstant and immediate attention" in my view is a very nebulous phrase, and as far as I could gather provided the attendant busied himself round the vehicle and did not enter any premises, e.g. kiosks, then no objection was taken. * * *

Mr. D. W. Johnson-Slough

Mr. Johnson brought up discussion he had had with the Concrete Manufacturers Research Organisation, who were of the opinion that with regard to swimming pools, concrete less than 6ins. thick did not provide an efficient liquid seal, and secondly that the installation of tanks in excess of 1,000 gallons was an engineering job as opposed to that of a builder. However, they felt that to encase larger tanks with less than 9ins. of concrete would create further problems. They suggested that a better installation method would be to construct shuttered concrete vaults either encased in a plastic membrane, or with the membrane sealed to the inside walls.

Mr. K. C. Hughes-Stafford, told the meeting that in his experience where tanks had been installed directly into the ground in his area, corrosion had occurred within ten to twelve years due to fillings of ashes and clinker, together with the effiuent from salt workings in the area.

In answer to this, Mr. Hornby agreed that much depended on local circumstances and that the criticism which ll'as heard at the American Petroleum Institute was concerned largely with the expansion and contraction of the tank in the concrete which gave rise to space between the ends and sides, perhaps as much as iin., which they said was a good collecting point for moisture, which once there would in all probability remain, and if the bitumastic coating was damaged in any way and coincided with one of these spaces, a leak would soon result. He mentioned that very often a filling station was built alongside a new highway on virgin ground, and in these circumstances cathodic protection is easy and there would be little corrosion material in the earth in any case. He agreed that concrete came into its own where, as is so typical in the English scene, buildings had previously existed and the ground might be long impregnated with all kinds of alien substances-clinker, lime, and soon. But to insist 011 concrete always might be unwise and unnecessarily expensive.

Still on the question of concrete surrounds, Mr. Beer said that theory was alright, but facts and figures were what mattered to him; and the fact remained that he had never known a leak in a concrete encased tank, and they have been put in this way for over thirty years now. Surely this was the finest possible justification ?

Mr. Hornby then asked the meeting, through the chair, if anyone present had known such a leak. When no-one had, Mr. Hornby said that this was just the reassurance he was seeking. * * * Mr. S. Brown-Manchester

Mr. Brown enquired whether or not petroleum mixtures were controlled in the United States ?

This question is covered by the classification of liquids as outlined in my paper, petroleum mixtures coming within type I classification.

On cathodic protection, Mr. Dale said he hoped that members would not go round putting cathodic protection in here and there, because in built-up areas there were many snags. Pipes and foundations could be eaten away which had nothing at all to do with the petroleum installation.

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