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#1 Posted : 27 May 2008 16:09:00(UTC)
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Posted By Timothy Borrow My client has recently taken delivery of an LPG powered Forklift and wishes to store the fuel tanks inside his factory unit. Does anybody know the maximum storage volumes permissible indoors, the maximum container sizes and any other conditions and restrictions which must be met.
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#2 Posted : 27 May 2008 19:25:00(UTC)
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Posted By Kevin McAughrey Hello Tim, I am no expert on LPG, but wouldn't it be safer storing these things outside? I would firstly contact the supplier of the LPG and get expert recommendations. I do know every place I have worked, High Pressure / High Risk COSHH has been stored outside, and locked away. Kev
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#3 Posted : 28 May 2008 09:27:00(UTC)
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Posted By Malcolm Greenhouse I asssume you have cheked out the following link:- http://www.hse.gov.uk/pubns/chis5.pdf It points out that the storage is better outside because of the need for adequate ventilation. It also suggests to minimise the risk by the second choice of reduction in the risk hierarchy i.e. only have the minimum required amount in store at any one time. Don't forget to let the local fire brigade know you are storing them and provide them with a location detail so that they know where they are in the event of a fire. Mal
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#4 Posted : 28 May 2008 10:24:00(UTC)
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Posted By MP Code of Practice 7 - Storage of Full and Empty LPG Cylinders and Cartridges available from th LPGA http://www.lpga.co.uk/LPGA.htm This will give you all the info you need It has the weight of an HSE ACoP Regards
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#5 Posted : 28 May 2008 15:34:00(UTC)
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Posted By Timothy Borrow Many thanks for the responses guys. I had already visited the web site but it shed no light. I agree that storage outside is preferable. His supplier has advised that small quantities can be stored inside but has not specified any conditions. I know the HSE guide SC8 for retail covers storage up to 400Kg and obviously LPG can and is stored indoors in retail outlets. In the absence of any further info, I will suggest a steel container, minimal volumes and an inert environment. Thanks for the advice on the fire brigade, good point!
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#6 Posted : 28 May 2008 16:51:00(UTC)
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Posted By lewes You might also want to consider protecting it from the elements (to protect against rust and intense sun). You also want to make sure the storage area isnt positioned close to other gases (1.5m if there is a fire wall or 3m without) and it isnt located in an area where its likely to come in contact with passing vehicle
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#7 Posted : 28 May 2008 17:40:00(UTC)
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Posted By Pete48 Timothy, I strongly recommend that you read the response from MP once again and take his advice. Get hold of the codes or talk with a major supplier of LPG, not the local retailer. They will be happy to provide you with some standard information sheets I am sure. I can assure you that you are at risk of completely misinterpreting the level of risk and therefore an appropriate level of control or indeed the correct controls. Inert environment????? Are you really suggesting placing a number of pressurised gas cylinders in a closed container, inerting that environment and saying that is a necessary risk control? I see LPG cylinders stored in the open air everyday, all upright and in secure but open cages, on concrete or other surfaces that drain away surface water to avoid the cylinders being stored in standing water and have clear information and warning signs on them, with only authorised personnel allowed access. The last time I went past my local depot, I estimate there were about 2000 stored in the yard, both full and empty. That doesn't quite fit with your assessment controls does it? One of the key storage controls is good ventilation. If that can be provided indoors, then there is no reason why cylinders cannot be stored indoors. You will after all be using the cylinders indoors and I guess that more than one FLT would be in use? It does, of course, require careful assessment before agreeing it as acceptable. On the other hand, the outside storage does give good ventilation almost, but not always, by default which is why it is a better option unless there are other reasons to store indoors.
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#8 Posted : 28 May 2008 17:55:00(UTC)
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Posted By Pete48 Timothy, I was feeling that my first reply was a lttle strong, (it was that word client that suggested you are being paid for this advice) so I visited the website of a well known supplier of ....gas cylinders, so well known that it is used in the same way as Hoover for a vacuum cleaner:) They have stacks of info on their website, why not try looking there as well.
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#9 Posted : 28 May 2008 19:33:00(UTC)
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Posted By Timothy Borrow Many thanks Pete48 for your response and advice. I am grateful for all input and not at all perturbed by the strength of feeling in any particular feedback, I believe it's all well meaning. You are absolutely right and I couldn't agree more, that storing outside with all appropriate controls is the most practical and common method, however the advice already received by my client (from c****, the well known "hoover" supplier), was that the cylinders may be stored inside his business unit. They did not however give any guidelines, which is what he requires from me. As you know it is also common practice to store LPG indoors, I am just trying to establish the limits and conditions permissible. Perhaps I should get hold of Code of Practice 7, but £46.00!! I thought that's why forums were invented!
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#10 Posted : 28 May 2008 22:07:00(UTC)
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Posted By Pete48 Timothy, I think, without looking it up, you will find that up to 100kg is the baseline for internal storage without a fairly detailed risk assessment to support the internal storage against external storage. That's around 4 or 5 FLT cylinders dependant on the actual size and type in use. If you store indoors, you do need to look at good ventilation, location of store, design of store, potential impact damage, away from escape routes, away from other materials such as combustibles, flammables etc, not below ground level and so on. It is most definitely not about just putting them in a corner somewhere. (why do I think that is what your client would otherwise doubtless end up doing, perhaps I have seen it too many times?) One other thing to consider is that this change to LPG may also be a material fact for insurance purposes. Usual disclaimer about not relying upon this information, provided only as a pointer to possibilities.
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#11 Posted : 29 May 2008 07:52:00(UTC)
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Posted By Halesowen Baggie MP Are you sure the Cop from the LPGA has the full weight of an approved code of prctice?
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#12 Posted : 29 May 2008 08:00:00(UTC)
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Posted By Halesowen Baggie The codes of practice seem to have replaced HSG 34. http://www.hse.gov.uk/lau/lacs/52-14.htm
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#13 Posted : 29 May 2008 08:05:00(UTC)
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Posted By Timothy Borrow Halesowen Baggie, The COP replaces the Guidance Note CS 8, which was the HSE's guidance on retail storage of small volumes of LPG. Does anyone have a copy of the COP 7?
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#14 Posted : 29 May 2008 09:38:00(UTC)
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Posted By Roger White I am rather surprised that nobody has mentioned that you suggest your client talk to their company insurers. I have witnessed a fire which involved a wooden shed where 18kg LPG cylinders were stored. When exposed to the heat of a fire the cylinders travel about 200 metres when they go bang including going through brick walls, and they are even considering storing them inside!
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#15 Posted : 29 May 2008 09:59:00(UTC)
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Posted By MP Halesowen Baggie - Yes it does. I have been with plenty of HSE Inspectors at gas storage facilities (big and small) and they regularly quote this CoP. There are a few words to this effect in the preface of the document as they (LPGA) acknowledge the HSE as contributors / advisors. It is only LPG that is regulated to this extent however. Other compressed gases (even oxygen, acetylene and hydrogen) are not regulated at all. The British Compressed Gases Assoc (BCGA) publish lots of similar guidance for compressed gas users, but although very similar in content and brimming with best practice, etc. the content is not "enforceable" in the same way as the LPGA tome. Hope this helps Regards MP
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#16 Posted : 29 May 2008 10:00:00(UTC)
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Posted By Halesowen Baggie Roger, What are the insurers going to do? Probably spend thousands on unnecessary and over the top measures that are not needed. From experience insurers are sometimes the worst people to ask for advice. A good example being when a new set of regs come out insurers want a RA on the subject even if it doesnt apply. The amount of clients I visited after the VAWR came into force, that were asked for vibration assessments that were not necessary was (and still is) frightening.
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#17 Posted : 29 May 2008 10:02:00(UTC)
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Posted By Halesowen Baggie MP No it doesnt, HSE quote various guidance notes, it doesnt mean they are approved codes of practice!
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#18 Posted : 29 May 2008 10:07:00(UTC)
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Posted By Halesowen Baggie MP Taken from HSE website The cops you quote replace a HSE guidance note HSG 34 ENFORCEMENT ACTION 14 Enforcement Officers should note the changes described in paras 7-9. It should be recognised that where the revised CoPs include improved standards, these are intended for new/modified installations. Guidance in the new CoPs should not be applied rigidly to existing installations, and any improvements required will need to be reasonably practicable. 15 The new LP Gas Association CoP replace the earlier HSE guidance as indicated: CoP 1 Part 1 replaces HS (G) 34 (except text relating to buried/mounded vessels and testing and inspection); CoP 1 Part 3 will replace the text on testing and inspection in HS (G) 34 when it is published; CoP 1 Part 4 replaces the text on buried/mounded vessels in HS (G) 34; CoP 7 replaces: GN CS 4 (The keeping of LPG in cylinders and similar containers); and GN CS 8 (Small -scale storage and display of LPG at retail premises); CoP 24 Part 5 replaces GN CS 6 (The storage and use of LPG on construction sites); and CoP 25 replaces GN CS 11 (The storage and use of LPG at metered estates). 16 If enforcement officers encounter difficulties in applying the new CoPs, they should consult HSE Regional Support Groups via their ELO's. It is anticipated that the codes will be reviewed by LPGA 2 years after publication. 17 Local authorities can obtain copies from LPGA. Their address is
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#19 Posted : 29 May 2008 10:14:00(UTC)
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Posted By MP I'm with Pete48 on this A few FLT LPG cylinders is not a huge hazard. With good practice, i.e. check valves are shut, training to change the cyinders, impact protection, storage away from the possibility of leaks collecting below ground, etc. I don't see a huge issue. Your insurers may differ but that is a different case. Just as an aside, in my experience, the major problem with external LPG storage is security and protection from the traveling community. Those orange cylinders have a truly magnetic effect. Consider what other damage may be done by insurgents whilst they are on site too. You will need to consider site security and location in regard to fences and site boundary, lighting, etc. I'd be looking at the minimisation of stocks as the gas companies all do next day delivery. There will be extra costs in terms of delivery charges but balance that against inurance premiums and construction of cages, etc. Hope this helps MP
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#20 Posted : 29 May 2008 10:24:00(UTC)
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Posted By Halesowen Baggie MP The missing 'A' from the cops you quote indicates the guidance notes are not Approved codes of practice. Have a look at section 16 of HSAW act. Hope this helps Halesowen Baggie
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#21 Posted : 29 May 2008 10:24:00(UTC)
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Posted By MP Halesowen OK, let me put it this way. If you have a big enough incident involving LPG and it is proven that the advice in the LPGA CoP was not followed, the prosecution would be based on failing to follow the best industry practice as endorsed by the HSE. It's effectively the same as an ACoP inasmuch if you choose not to follow the advice you will have to convince the court your actions had complied with the Law. I have seen INs quoting this document. Regards MP
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#22 Posted : 29 May 2008 10:29:00(UTC)
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Posted By Halesowen Baggie MP Ive seen IN quoting various HSGs,BS etc aswell, it still doesnt mean there acops.
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#23 Posted : 29 May 2008 10:33:00(UTC)
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Posted By MP Let me send you a hair to split
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#24 Posted : 29 May 2008 10:36:00(UTC)
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Posted By Halesowen Baggie MS No hair to split at all, you stated something that is wrong, there are people reading this board who take things posted as gospel. I have just tried to help people get the correct info. Nothing against you mate. Halesowen Baggie
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#25 Posted : 29 May 2008 12:03:00(UTC)
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Posted By Roger White You dismiss the advice of the Company Insurers if you don't care about your business. Generally insurers insist that unless you follow best practice then they will not accept the risk. Bye-bye business! The ACOP referred to in this thread relates to the storage of the little LPG cylinders that you find in DIY stores for use with blowlamps and the likes. It would surprise me if any insurance company would cover you for the storage inside a factory of the quantity of 18kg cylinders (normal FLT size) necessary to keep a FLT going for a week (in an 8 hour working day they use a cylinder per day). As regards new legislation it is ALWAYS necessary to carry out a risk assessment. Only if the RA identifies that there is an insignificant risk do you take no action, but the RA itself is always necessary.
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#26 Posted : 29 May 2008 16:15:00(UTC)
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Posted By Pete48 Roger, I did draw attention to the impact of this change on the insurance in one of my later posts. However, that was not on the basis that the world is suddenly going to end if a small number of cylinders are stored correctly inside a building. It was on the basis that it is a material change. We are dealing with an energy source that whilst it is allegedly more efficient and "green" than other sources, carries a higher failure consequence in some scenarios. So the risk controls are firmly based in primary engineering controls and supported by strong procedural controls, that's all. In other words a level of respect based on knowledge of the substance and the required controls. Insurers may well want to discuss how we store such substances but I doubt that they would automatically refuse insurance on the simple fact of internal storage of very small number of cylinders. If you follow some of the logic on this thread, what about the 10 LPG powered FLT that wander about the factory next door to me. How come their insurers are happy to cover that? I repeat that I would only accept such storage where a s&s risk assessment was available that explicitly demonstrated an adequate technical knowledge. There are a lot of pointers as to why the external option is always going to be best, not the least that not all users of LPG will maintain compliance with best practice. But as MP has said, there are other risks that have to be considered in large areas of our industrial estates up and down the UK.
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#27 Posted : 29 May 2008 16:43:00(UTC)
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Posted By David Bannister The most common location for internal LPG cylinder storage appears to be in the loading bay. The reasons cited are available space, ventilation and ease of access for fire fighting. Against this is the frightening and forseeable scenario of a cylinder being hit and pierced by a FLT or truck. My advice is always to go for external secure storage in line with the published guidance, unless this is not practicable, when I would accept a couple of spares in the premises, in a safe, agreed location. As a previous poster has said, suppliers generally offer a very rapid service. The same applies to all other bottled gasses, not only fuels. If your insurers are being unreasonable, challenge them to justify their position. If still no joy, get a new one. They are queuing up to do business at present. Most are reasonable, most have experienced and knowledgeable people working for them, most will accept a well-argued case for a particular course of action. Few will cancel cover mid-term although they may exclude property losses from certain causes. I speak from experience. Given the recent media-led witch hunts following tragic deaths of fire fighters, it is doubtful whether Officers would send their fire fighters in to areas where gas cylinders are known to be involved in a fire. If acetylene, you can expect a wide exclusion zone for a minimum of 24 hours.
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#28 Posted : 29 May 2008 18:01:00(UTC)
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Posted By Halesowen Baggie Roger, There is no point in us as safety professionals according to your argument. An organisation could just ring their insurers up to find out what is to be done. David makes some good points with regard to insurers.
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#29 Posted : 29 May 2008 20:04:00(UTC)
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Posted By MP Good grief is this still going? Just out of interest, I actually have a copy of the 2004 LPGA CoP 7 in front of me now (How sad - it's gone 20:00hrs). There is a forward by Nick Starling Chair of HSC Advisory Committee on Dangerous Substances. In it he repeats almost verbatim the wording from the front page of HSE ACoPs and Guidance notes. He also says "HSE inspectors seeking to secure compliance with the law may refer to this guidance as illustrating good practice" He goes on to say "The HSE believes that the contents of this Code demonstrate good practice in the LP Gas industry and commends its use" It may well not be an "approved" Code of Practice, but as I believe I said in my original post "It has the weight of an HSE ACoP"
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#30 Posted : 29 May 2008 22:56:00(UTC)
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Posted By Halesowen Baggie MP Its still not an Acop, Your post above even refers to the geezer from the HSC quoting 'good practice'. Replicated in most forwards to every HSG! Nowhere does it say; 'If you apply whats said you will be satisfying what the law requires'. Thats the last I'm saying on this issue. Goodnight!Sweet dreams! Halesowen Baggie.
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