Maintaining regulatory compliance within bulk plants can be a challenge. That’s why it’s critical to have an inspection and maintenance process to help your facility and employees stay safe.
What are some of the most common inspection issues for bulk plants and how can they be resolved? Here are the top six inspection issues I frequently see during bulk plant inspections:
1. Emergency shut-offs don’t work properly
The emergency shut-off valve (ESV) that closes the vapor and liquid valves to the container and piping in a bulk plant can experience many issues. These include not closing due to a lack of maintenance or getting stuck in the “Open” position because it was never routinely closed. Management at your bulk plants should verify the ESVs at least once per month to make sure they are in working order and no parts need to be replaced.
2. Lack of security
A bulk plant’s security is only as good as its front gate, and far too often the gates at bulk plants are either left unlocked or fixed with “dummy” locks that look secure but aren’t. I personally know of a propane marketer that left their bulk plant open only for a content creator to go in and film a video—not only is that dangerous, but it negatively impacts your brand’s reputation. Locking gates at night and having secure fencing all the way around is one simple way to prevent bobtail theft, personal injury or worse.
3. Missing or faded markings and decals
Decals and markings at bulk plants may be something that you take for granted—after all, many are designed as permanent fixtures. However, over time, weather conditions and regular wear and tear can cause decals and markings to fade, creating a potential safety issue.
Replacing these markings and decals when they show signs of aging is an easy preventative measure to stay in compliance and provide new and seasoned HAZMAT handlers with the necessary information to keep safe.
4. Expired fire extinguishers
If the unthinkable were to happen at your bulk plant, one of the most important tools to have on hand is a fire extinguisher—but did you know that many extinguishers expire and are not requalified? Fire extinguishers should be inspected monthly and requalified or replaced if needed prior to their expiration date, so you know they’ll work their best if you need them on your premises.
5. Methanol stored too close to the storage container
We all know that methanol should be stored in a cool, dry, well-ventilated area away from direct sunlight and moisture; however, it should also be kept a minimum of 20′ from the point of transfer. Methanol stored too close to propane can spell trouble for your bulk plants, which is why it’s important to check where your methanol is being stored and choose a new location if it is too close to a propane storage location.
6. Unsecured vapor and liquid hoses
Unsecured vapor and liquid hoses without the presence of a qualified individual can be a major issue at your bulk plants. Making sure that these hoses are only engaged in the presence of a representative can greatly reduce the risk of a catastrophe and keep you in compliance.
Find & Resolve Common Bulk Plant Issues
Paper safety inspections have been commonplace across the bulk storage industry for decades now, and some companies have moved toward using PDFs—but this time-consuming process is burdened by a host of drawbacks. There are many reasons why utilizing the latest technology plays a key role in better regulatory compliance than paper forms and PDFs.
Propane compliance experts now recommend digital routine bulk plant inspections to reduce the rate of omissions and errors within inspection reports and highlight any potential safety issues. Some platforms even automatically generate management reports, which can help identify important follow-ups.
To reduce your error rate and do your part in keeping your community and company safe, I highly recommend consulting a propane safety expert for assistance with your bulk plant inspections and reporting. ICM
Paul Craver is the Senior Consultant of Safety & Training at P3 Propane Safety. You can reach him at Paul_Craver@p3propanesafety.com or P3Propane.com.
For many propane marketers, cathodic protection inspections and documentation are the “procrastination task” on their checklist. Though cathodic protection is required by the National Fire Protection Association (NFPA), many propane marketers aren’t meeting requirements because they aren’t sure what is required to satisfy the guidelines. You may be surprised to learn the process is more straightforward than you think. We’ll cover the details one should know about implementing cathodic protection and help introduce this important safety requirement within a company’s container portfolio.
Step 1: Understanding the Requirements
The NFPA has strict and specific requirements regarding cathodic protection testing values. I’ve compiled them below as a reference for your propane company, but you can also find them in your copy of the NFPA 58 Liquefied Petroleum Gas Code Handbook. This is also good information to keep in your company’s policies and procedures manual, which should be easily accessible to every employee.
Installation and testing requirements include:
• Cathodic protection installed and tested in underground containers placed after their State adopted the 2011 edition of NFPA 58.
• Cathodic protection must be at least -.85 D.C. or more (meaning negative) using a copper-copper-sulfate half cell.
• Test must be completed upon installation unless prohibited by climatic conditions, in which case testing shall be done within 180 days after installation of the system.
• For continued verification of the effectiveness of the system, test again 12 to 18 months after the initial test.
• Periodic follow-up testing shall be performed at intervals not to exceed 36 months.
• Systems failing a test shall be repaired as soon as practical unless climatic conditions prohibit this action, in which case the repair shall be made not more than 180 days thereafter. Testing schedule shall be restarted as required initially.
• Documentation of the results of the two most recent tests shall be retained.
Step 2: Acquiring Equipment Needed for the Task
Once you are familiar with the requirements outlined by the NFPA for cathodic protection, there are a few pieces of equipment you’ll need to acquire to install and monitor cathodic values. This equipment includes:
• Volt meter
• Copper-sulfate half cell
Basic cathodic protection inspection test kits can be purchased from all major liquefied petroleum equipment suppliers, such as Ray Murray, Webb and Gas Equipment (contact me via email if you can’t find the equipment you need).
Step 3: Having a System for Documenting Inspections & Reporting Re-Inspections
To effectively implement cathodic testing and reporting, you’ll need initial testing documentation as well as follow-up inspection forms. Historically, the industry has conducted these inspections using paper forms. One drawback to consider is that paper forms stuffed in a filing cabinet have no way of letting you know when they’ve expired (and neither do filled-out PDF files).
Instead, there are now software providers specializing in digital documentation, which can automatically flag inspections needing follow-up on your dashboard for management staff to see. Using software to store, retrieve and track cathodic protection documentation makes this process extremely efficient. Plus, software can notify you immediately when corrective action is necessary, unlike forms, which often sit unattended for months.
No matter which method you go with to document periodic inspections, be sure to choose something that works well for your company, your employees and your customers, along with meeting documentation industry standards.
Tip: When you’ve decided upon a tracking method, outline it in your policies and procedures manual so that both employees and auditors can clearly see how your company performs such inspections.
Step 4: Training Your Team
Are your employees trained in proper cathodic testing methods? Ensure that all staff members have received hands-on field training to conduct cathodic tests appropriately per NFPA 58. Training should include:
1. Review and complete Certified Employee Training Program’s (CETP) Topical Cathodic Training found in the Learning Center
Tip: Propane Education & Research Council (PERC) has recently revamped CETP to make it easier for marketers to provide specific training.
2. Provide field training for your employees
Tip: After the required training, I’ve found that the best way my employees learn is by seeing the equipment in action in the field. I take them to the job site and walk them through an inspection so they can see it in real time and then try it themselves.
Step 5: Having a Plan for Failed Cathodic Tests
It’s critical that your company has a procedure in place for the installation or replacement of a missing or failing cathodic protection anode or tank. This corrective process is referred to within the industry as retrofitting.
Failed cathodic protection inspections are often due to one of these common factors:
• Tank does not have cathodic protection installed
• Anodes are old and have worn out, needing replacement
• The entire tank needs replacement
• Dielectric union is required to protect underground piping
Diagnosing the problem will become second nature. The first step is ensuring the issue is not the lack of a dielectric union. Look under the dome of the tank to see if a dielectric union is installed on the tank connection to the gas line. The second spot the dielectric union may be located is between the underground piping and the house. If there is no dielectric union, you will need to install one.
If you do find a dielectric union but continue to have a bad reading, you should determine if the issue is the anode or the tank itself. Start by attaching an anode bag and wire to the tank. If there is an increase in the protection number (e.g. -.5 to -.85), you now have a good reading. If there is no increase in the number when you complete this procedure, you will need to disconnect the tank from the gas line and retest the system, which will tell you whether the problem is with the tank or the line.
Step 6: Implementing Cathodic Protection Testing
It’s now time to decide the most efficient way for your company to maintain this important inspection requirement. The two most common methods I’ve seen in the field are:
• Training all drivers on cathodic protection: have them test tanks when they make deliveries
You will not have to send employees on return jobsite visits.
• Training a few specialists who drive around, focused on cathodic testing specifically
You will not have to buy as many cathodic test kits.
You know your team and delivery routes best—choosing which method will be most efficient for your propane company is a personal decision and can always be adjusted later for best results. ICM
John Horner is the Senior Director of Safety & Training at P3 Propane Safety. He has more than 13 years of industry experience providing DOT and other safety and compliance training. You can reach John at john_horner@bostonenv.com or P3Propane.com.
Have you ever wondered how safe your employees are when they’re out on a jobsite? Even the best-trained employees may not retain all safety information they’ve been given, and the opportunity for mistakes is magnified when a company is less diligent about initial and ongoing safety training requirements.
Common safety-related oversights are usually driven by one of two things:
No matter what the reason is, however, the onus will be on the business if a catastrophic incident were to occur. That’s right—it’s the responsibility of the propane company to ensure employees are up to standard for all training requirements. It’s imperative that a manager or owner ensure that their employees know the company’s safety program and policies inside and out, increasing operational safety and reducing risk for customers, employees and the company alike.
How Many Days Should Be Reserved for Training?
Though there’s not a definitive answer for the number of days that should be set aside for training new and existing employees, every company should have an ongoing training program with designated days each year to contribute toward its market’s pool of qualified candidates interested in expanding their knowledge and growing their careers.
This habit will both increase the regulatory, bodily and financial safety protocol at your company, but also help employees realize you are invested in them and their success. A recent study found that 94% of employees would stay at their job if their employer invested in their long-term learning.1
Successful companies are investing in propane-related safety training, and many have committed to training programs year after year. Once you develop a streamlined rhythm with training, initial and recurrent training become a breeze that you can easily mark off your checklist.
Which Trainings to Schedule for 2024
Required Training:
In-Person or Remote Training?
The propane industry has many training options available, with both in-person and online (remote). Both types meet safety training requirements, but there are some pros and cons to consider, as it pertains to the longevity of the knowledge acquired during such trainings.
Remote Training tends to be more affordable, but information is often not retained as well. This could lead to compliance issues for your company down the line if employees who learned remotely did not absorb all of the information presented by your propane safety expert during the course.
Field Training is an auxiliary aspect of in-person training. Field training happens when a trainer joins a technician or driver (or multiple) in the field and provides feedback and corrections in real time. Field teams generally comprise hands-on learners, so this method leads to an incredible return on investment.
Keep in mind that not everyone struggles with the same thing. Providing field training can be an opportunity to connect with employees on an individual level, assisting them with their areas of weakness and demonstrating your investment in their long-term learning and growth.
This will also help your company to tie up loose ends, as many employees don’t understand what issues they may be having and may make errors that have been slipping by undetected by office staff.
Time to Get Training on the Calendar
Every year, the warm (field training-friendly) months seem to slip by in the blink of an eye. Get your training on the calendar now, before it’s too late. This is a critical responsibility of the propane marketer, and one that we should all be handling with the utmost respect to preserve the safety of those around us, as well as the reputation of the propane industry as a whole. ICM
John Horner is the Senior Director of Safety & Training at P3 Propane Safety. He has more than 13 years of industry experience providing DOT and other safety and compliance training. You can reach John at john_horner@bostonenv.com or P3Propane.com.
When colder temperatures roll around, more propane gallons are ordered and delivered—and you know what that means: more interruptions of service. Interruption-of-service calls may be caused by an empty tank, gas leak, equipment failure, inaccurate delivery schedule or increased gas demand caused by weather. Regardless of the reason for the call, every propane company must have a proper protocol to ensure that such situations are handled correctly.
These actionable tips will help your team respond to interruptions of service in a quick, safe and efficient manner. Implementing these routines will help you maintain compliance, keep everyone safe and reduce risk.
Proper Digital Documentation
It is imperative that your propane company documents any response to interruptions of service clearly and that the documentation is stored for your records. In the event of litigation, documentation serves as legal protection. Having easily accessible digital documentation with photos is the best way to protect your company.
Roughly half of all propane accidents are caused by do-it-yourself (DIY) homeowners modifying their equipment. Having photo documentation of container sets and records of every homeowner’s service history will also serve to protect your company in the event of an interruption of service situation caused by homeowner modifications.
You’ve heard it before: If it isn’t documented, it didn’t happen. Properly documenting interruption-of -service calls and how your team responded is crucial to protect your company—and the employee performing the work—in case of litigation.
Written, Updated Policies & Procedures
Having a written manual is an Industry best practice recommended to help your company avoid unnecessary risk. Do you have written policies and procedures for all scenarios, including interruptions of service? That must be part of your manual, established to keep your employees and customers safe and to protect your company in the event of litigation.
Written policies and procedures will guide your team during an interruption-of-service response and make handling these potentially dangerous situations much safer and easier to execute. Whether you need to create a policy and procedure for interruption of service calls or you already have one, ensure it includes the following:
1. A written script for customer service representatives to use when answering interruption-of-service calls from customers.
2. A plan for how to handle interruption-of-service situations outside regular business hours.
3. A procedure for your drivers to follow when responding to the call, including if they complete the leak check before or after fuel is added and if they lock out the tank if the leak check fails.
Initial & Refresher Training for Employees
Training is essential for handling interruption-of-service situations. Do all relevant personnel have proper and updated training to perform their responsibilities appropriately? Start by thinking about your customer service representatives (CSRs). They are the people answering the phones and therefore the first line of communication with the customer. It is crucial that every CSR is trained in how to handle interruption-of-service calls so they can communicate with the customer, as well as dispatch drivers and service technicians, in a timely and compliant manner.
For example, all CSRs should respond to an odor complaint the same way. Instructions should include:
Beyond the CSR, consider the rest of your team. Initial training and annual refreshers are crucial for the drivers and technicians who respond to and remedy these scenarios. Drivers and service technicians alike should understand how to complete the procedures in your Policies & Procedures manual, perform their responsibilities accordingly and document the response to the interruption-of-service situation in the field.
Documenting the Container Hazard Tagging System
Warning call tags alert customers about a safety hazard and provide instructions to contact you, the propane marketer. Variously colored warning tags (with white and orange being the most common) can be left at the residence of customers who are not at home and whose gas supply valve has been closed, letting them know not to use the tank until they call your company to authorize remediation of the issue.
How is your company keeping track of these warning tags? If you don’t have them saved in a digital dashboard that your management can view at the click of a button, there’s room for improvement in your interruption-of-service procedure. Partnering with a documentation and compliance software company can help get your hazard warning tag process more organized and efficient.
The Busy Interruption-of-Service Season
These scenarios are an unavoidable part of running a propane company during the Winter months, and it’s critical that you remedy and document them appropriately to improve your regulatory compliance and reduce risk. If your propane company’s existing practices don’t quite match up to the recommended protocol above, now’s the time to get organized as the raindrops turn into snowflakes.
The key elements recommended in this column are not just for safety but also for efficiency. We all know how precious every minute of billable time is during the busy season. Having a streamlined interruption of service protocol in place will help your staff address, respond to and resolve these situations safely without losing valuable time. ICM
Shawn Litchfield is the Regional VP of P3 Propane Safety. Contact him at: Shawn_Litchfield@bostonenv.com or P3Propane.com.
Safety inspections are a propane industry best practice that marketers utilize to maintain customer safety and reduce liability. If you are a propane marketer, it’s likely that you’re completing safety inspections of propane systems regularly for new customers, move-in and move-out scenarios, and systems that have been modified.
Something that marketers reviewing this process have often wondered is, “How can I create a more efficient process that will lead to time savings for my team? How can we ultimately produce more accurate and complete documentation that will help protect the company?” Today, I’m here to answer that question.
The Impact of Safety Inspections on Your Propane Business
It’s a fact of our industry that field technicians don’t love paperwork. On any given day they could conduct multiple safety inspections, which may not sound like a lot until you consider that just one safety inspection form has 50 fields to complete. This paper-driven process is detrimental to your company’s overall efficiency. After a safety inspection is completed, a paper copy is usually returned to the office where it gets filed with some information and put into back-office software.
Paper safety inspections are significantly more time-consuming for every department involved. Technicians in the field must complete forms for every inspection by hand, then these forms are manually stored in filing cabinets or back-office software by the office team. Using paper forms also makes it difficult for service managers to quickly review the inspections for errors, omissions or follow-ups.
It should come as no surprise, then, that errors happen. It takes a lot of time and effort to maintain a consistent safety inspection process. Technicians must be trained on how to complete the inspections and the forms, and office staff members need to be able to review the paper forms and input the data. Inevitably, the process yields a significant margin for error. Without a process in place to provide real-time feedback on errors that technicians are making, those errors could potentially be made in perpetuity. How, then, can propane marketers maintain this important Industry best practice without sacrificing efficiency or accuracy? One solution is to transition from a paper-driven safety inspection process to a mobile one.
Mobile Safety Inspections Dramatically Increase Efficiency
Mobile safety inspections come with a number of benefits. These include, but are not limited to:
• They’re completed on tablets, instead of by hand on paper.
• They utilize intuitive prompts and form field options to eliminate factors like illegible handwriting or missed form fields to create 100% accurate and complete safety inspections.
• They save time for technicians in the field by automatically sending a completed copy of the mobile safety inspection form to the customer, and another is sent and stored in an electronic database.
• Some platforms can automatically generate management reports, which can help identify important follow-ups and technician performance.
• They offer a unique opportunity to provide feedback right away, proactively correct any errors and prevent recurring issues.
Consider Your Company’s Current Inspection & Documentation Process
A major shift must take place to transition from a paper-driven safety inspection process to a mobile one, so it is important to make sure you are utilizing the best available technology formulated by propane safety experts. While there may be a lot of electronic systems available, not all of them are equipped to store, retrieve and analyze safety inspection data and other compliance documentation.
When you start looking for electronic safety documentation software, consider these questions:
• Can my current back-office software evaluate operating tests?
• Can field technicians use the mobile application service offline, without cellular data or Wi-Fi?
• Can I use the system to analyze critical operating tests, such as leak checks, pressure tests and flow and lock-up tests?
• Can the system report on regulator replacements and cathodic protection inspections?
Now is the best time to transition from paper to mobile to eliminate documentation errors, save time, increase efficiency and reduce risk for your propane company. ICM
Alex Burns is Vice President of the P3 Compliance System division of P3 Propane Safety. You can reach her at Alex_Burns@p3propanesafety.com or p3propane.com.
