The PRA technical team is receiving a number of enquiries about when they must notify their Petroleum Enforcing Authority (PEA) of changes they wish to make to their fuel storage and dispensing arrangements.
Apart from when applying for a Petroleum Storage Certificate for a new installation or a knockdown rebuild, the only circumstances under which a site operator has a duty to notify the PEA is when they intend making changes that are prescribed in the regulations. I should clarify that it is the duty of the site operator, known in the regulations as the keeper, and not their contractor to make the notification. I mention this, because traditionally many operators left it to the contractor to liaise with the authorities.
The prescribed material changes are:
cessation of use of one or more of the petrol storage tanks;
removal or permanent decommissioning of one or more of the petrol storage tanks;
installation of any tank, pipework or vapour pipework associated with the storage and dispensing of petrol;
installation of any petrol pump, any other automotive pump, or dispenser in a new location.
As a result of a change in legislation, there are far fewer circumstances where the PEA needs to be involved. This was intentional, as was the fact that all tanks on site that are suitable for the storage of petrol should be listed on the Petroleum Storage Certificate (PSC), even if they currently contain a different product. As an example, the PEA doesn’t have to be notified of pump or grade changes provided any tank that contains petrol is listed on the PSC.
Another change is that when changes are to be made to an operational site, there only has to be a notification of 28 days prior to the commencement of the works. The works may commence after 28 days have passed. You do not need their consent. It is the duty of the PEA to issue a new PSC if necessary.
It remains the duty of the site operator to operate their site and carry out any works in compliance with the Health and Safety at Work etc Act 1974 and the Dangerous Substances Explosive Atmospheres Regulations 2002.