New Challenges for Filling Station Operators
By Jamie Thompson, APEA Technical Committee Chairman, FEI, F.APEA, MIFire E

In 1997 the HSE approached APEA to produce some industry guidance on petrol station design, construction, modification, maintenance and decommissioning. We worked with the Institute of Petroleum (now the Energy Institute) and produced the ‘Blue Book’ in 1999 and have just published the 5th edition in 2024. This can be purchased on the Publications page of the APEA website at www.apea.org.uk.

The changes over the years have improved public safety and environmental awareness, and the filling stations constructed over that period are recognised as being much improved. There are, however, still causes for concern as fuel and design changes have caused challenges for petrol station operators. The installation of EV chargers on petrol stations has been a development which was foreseen, and guidance was issued in both the previous edition of the Blue Book and the following Codes.

We have found that the first EV chargers installed were mainly on the larger sites, such as motorway service areas run by major operators, and there was an understanding of the risks involved. EV chargers must be kept out of hazardous areas on filling stations as they risk public safety by potentially causing an explosion.

Within the Blue Book, there is clear guidance in Chapter 3 demonstrating hazardous areas on the filling station, such as distances from tanks, pumps, road tanker positions, and vent pipes.

• This states that the charger, the vehicle being charged, and the full extent of the charging cable must be outside the hazardous area.
• The IET/APEA guidance document states that reference to hazardous areas throughout this supplement shall be deemed to include both permanent and temporary hazardous zones as defined in the Blue Book.

The later developments are now proving more of a challenge, as EV chargers are being installed on smaller sites where it is often difficult to find a position outside the hazardous zones. What appears to be a trend now is that marketing companies are approaching operators and leasing land on the filling station to install EV chargers without the operator having to pay for the equipment. They appear to be responsible for the installation, but in some cases, it has been found that they are installing them in unsatisfactory positions, causing public safety concerns.

At present, the existing law does not recognise the installation of EV chargers as a “Material Change” to a petrol station that requires notification to the Petroleum Enforcing Authority. My advice to operators is to check with your PEA if you are hoping to install this equipment. If it proves to be dangerous, a prohibition notice preventing their use could be issued.

Here, EV chargers were placed inside hazardous areas and are a risk to public safety. One installer wrongly ascertained that the tank lids would make them safe – this is not the case. Another common problem is not linking the emergency stop for the petrol pump and the EV chargers together.

Petrol station operators have a responsibility for the safety of the public visiting their sites and also neighbouring property. Operators can see what they should be doing, including staff training, by reading and distributing the Red Guide “Guidance on Managing the Risks of Fire and Explosion”, which is a free download from the following website: https://publishing.energyinst.org.

Since the 1990s, petrol station design and construction has included secondary containment with leak detection on tanks and underground lines, making stations much safer from environmental leaks and reducing fire and explosion risks.

We are, however, finding that in some cases there is a lack of knowledge on site of what to do when alarms sound, and also a lack of maintenance of such equipment. One example involved a tank leak detector warning the operator that the tank was leaking. The staff, wanting to silence the noise, removed the detector to stop it. This was found on a routine safety inspection by the Petroleum Inspector.

A more serious incident occurred when fourteen double-wall tanks were installed at a motorway service station with the necessary leak detection systems. One of the managers heard the alarms and took no action other than to turn off the noise. When the Petroleum Inspector called and turned the alarms back on, 11 of the 14 tanks were found to be leaking. This was a clear case of a lack of training.

Site operators have much to consider in running sites, marketing goods, and managing crime prevention, and are often not experts in safety systems such as leak detection. My plea to the industry is to remind everyone that these systems should not be left to run unattended — they must be maintained.

In this day and age, it is also possible to ensure that when alarms sound, warnings can be sent directly to a responsible person’s mobile phone or computer to make sure appropriate action is taken.