I have just returned from a road trip across Europe in a 52-year old classic car. During the trip we filled the car with petrol 14 times in five different countries France, Belgium, Luxembourg, Switzerland and Italy.
Immediately before heading off, I was notified that the guidance from the Petroleum Enforcement Liaison Group (PELG), (of which I am the current chairman) on the protocol for testing the emergency procedures at unmanned sites was available from the Energy Institute website PELG PETEL 19. With this, the new labelling directive and the lobbying by trade associations for the government to mandate the introduction of E10 in my mind, I took note of the situations I found during my trip.
I noted that 10 of the petrol filling stations I visited were operated unmanned. As far as I could see, none of these sites had the features that the UK guidance suggests should be provided. Some sites did have CCTV cameras, but I could not ascertain whether the sites either had live or intuitive monitoring. They gave the impression of simply having pay@pump and nothing more. I am certain that they would all have been found wanting should they have been inspected in accordance with the PELG PETEL 19 guidance. So why do we have guidance that is onerous for unmanned petrol filling stations? The simple answer is Section 3 (1) of the Health and Safety at Work Act 1974 requires that: "It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety. Following the national guidance that is endorsed by the HSE would be the mitigation should a prosecution resulting from an incident at an unmanned site be taken".
All sites we used during our trip had Automotive Fuel Infrastructure Directive compliant labelling, which becomes mandatory here from September 1. As to the provision of E10 petrol, we never knew what we would find. Some sites had E5 and E10, some had one or the other and one had E5, E10 and E85.