At a meeting in September, the Fuel Experts Association together with the Fuel Industry Working Group met with HSE’s head of manufacturing, transport and utilities unit to give a presentation on the potential unacceptable cost to UK industry due to the reclassification of diesel.
Last month HSE clarified the application of HSG 176.
Understanding and acceptance of the problem by the unit head has seen the HSE, FEA and FIWG work together to clarify the application of HSG 176 with particular regard to the storage and dispensing of diesel.
“The successful outcome is, in large measure, due to the helpful response and swift action of the HSE’s head of unit,” said David Eyres, chairman of the Fuel Experts Association who details the clarification agreed on 16th November 2016 below.
Storage and dispensing of diesel
The classification of diesel has been changed by CLP but the risks associated with storing and dispensing it have not. Therefore all those businesses that are already complying with DSEAR, by controlling the risks posed by diesel, need take no further action as a result of the CLP reclassification..
A number of points in the HSG 176 guidance document are not appropriate for the risks posed by diesel, therefore to avoid businesses inadvertently putting in place control measures over and above those necessary to comply with DSEAR, HSE has set out the following expectations:-
Paragraphs 277 to 289 of HSG 176 provide guidance on issues to consider when working with higher flashpoint liquids such as diesel. Paragraph 277 makes clear that some of the precautions outlined in the wider guidance document can be relaxed.
Where diesel fuel is stored in storage tanks with a capacity not exceeding 150,000 litres, designed to recognised and appropriate industry standards such as BS 799 Part 5, OFS T/200, EN 13341 or OFS T/100 and where the vessels were manufactured in a workshop environment to controlled standards and where there is no risk associated with the formation of a flammable oil mist, the requirements of HSG 176 do not need to be applied.
Information that could be used to inform this decision would include any historical evidence of an incident due to misting as well as any other relevant guidance.
Storage of kerosene at commercial, industrial and domestic premises
For installations up to 10,000 litres the provisions of BS 5410 Part 1 and BS 5410 Part 2 should be applied and for installations of a greater capacity than 10,000 litres the provisions of HSG 176 should be applied.