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HMRC internal manual

Oils Technical Manual

HM Revenue & Customs
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Measurement: Health and safety

On-line H&S guidance

This is not an exhaustive list, and Health and Safety guidance which covers the risk assessments that should be in place and available for inspection by all Staff involved in oils duty assurance, should be consulted in order to identify the risks and potential hazards involved in visiting trader’s premises, offices, freight, dock and other areas.

  • HS-7 Safe clothing and equipment
  • HS-10 Hazardous substances

Personal protective equipment

Meters and measuring systems are usually in places where there are special health and safety needs. Accordingly Personal Protective Equipment (PPE) should be worn including safety boots with antistatic (and oil-proof) soles (as other soles may melt), fire-retardant overalls, high-visibility jacket, goggles, over-spectacles, gloves and a protective safety helmet as necessary.

Main hazards

  • Oil has obvious hazardous properties, such as its ‘slippiness’ and other less obvious ones, such as the lead additives which are still added to some fuels and which are carcinogenic.
  • Crude oil gives off flammable vapours which in certain circumstances can be highly explosive. This is especially the case with ‘petrol’ or gasoline vapours which are highly volatile.
  • Ladders up tanks for our inspection should go round the tank and have railings as opposed to going vertically up the side.
  • Floating roofs on tanks should NEVER be stepped on.
  • Officers can be called upon to board ships and most loading/discharge places are busy with freight vehicles. Docks and Freight areas are particularly dangerous. (Please note that Officers cannot board vessels without having first completed Dock and Ship Board Awareness and other Health and Safety training).
  • Mobile phones should be switched off when entering oil storage premises and anywhere else where any form of loading or discharge of oil is in progress.
  • Vapour builds up in any oil tank that has a space in it.

Vapour recovery hazards

Directive 95/63 is designed to control volatile organic compound emissions resulting from the storage of petrol and its distribution from terminals to service stations. The Directive is implemented in the UK by the Environmental Protection (Prescribed Processes and Substances etc) (Amendment) (Petrol Vapour Recovery) Regulations 1996. This legislation requires vapour caused by the loading of mobile containers to be recovered and converted back into liquid form.

For loading/unloading areas, be it road, rail or sea, vapour recovery requires equipment that has to be attached and detached on each occasion.

The Energy Institute have issued the Vapour Recovery Hazards Bulletin in 2002, which made specific recommendations relating to road tanker loading and which should have been fully adopted by now following a series of incidents. At some point in the vapour recovery process, the vapour is under pressure and potentially explosive. Vapour pressure can also build up in pipes that are attached and detached.

(For further information on Vapour Recovery and its measurement please see HCOTEG178000)

Will the traders have risk assessments and H&S training?

Officers should comply with a trader’s own H&S training and requirements. All traders should have in place risk assessments to cover all their staff and any visitors. Officers must be made aware of these before going on site.

For further information on Health and Safety, see HCOTEG11000 in the ‘Introduction and overview of oils activity’ section of this guidance.