Introduction: In a recent safety notice (CEMHD02-2023), the Health and Safety Executive (HSE) has raised concerns about overfill risks in carbon adsorption vapour recovery units (VRUs), urging immediate action to mitigate potential hazards. This alert is particularly directed at VRU operators, fuel terminalsand COMAH site operators.
Background: VRUs play a crucial role in recovering hydrocarbon vapours during transfer operations, such as filling road and rail tankers and ships at fuel storage and distribution terminals. However, a recent investigation revealed that the overfill prevention system in some VRUs is not independent of the basic process control system (BPCS), posing serious safety threats.
Immediate Action Required:
- Risk Assessment: Duty holders are urged to conduct a thorough risk assessment of their VRUs, examining the control system architecture and identifying safety functions dependent on the BPCS.
- Physical Verification: Physically verify the presence of all identified safety functions and equipment on the VRU. Ensure they are suitably inspected, maintainedand tested in line with good practice.
- Modification of Control Measures: Based on the risk assessment, duty holders may need to modify the VRU control system architecture and implement independent control measures to achieve the required risk reduction. Follow a suitable Management of Change (MoC) process.
Guidance for Compliance: Refer to the following guidelines for ensuring compliance and enhancing safety measures:
- British Standard: BS EN 61511 provides relevant good practice, emphasising the independence of safety instrumented systems from the BPCS.
- Energy Institute Guidelines: Specifically for VRUs, these guidelines offer valuable insights into design and operation, emphasising the importance of overfill prevention and high-integrity safety functions.
Legal Compliance: Duty holders are reminded of relevant legal documents, including the Health and Safety at Work Etc. Act 1974 and the Control of Major Accident Hazards (COMAH) Regulations 2015.
Conclusion: Safety is paramountand immediate action is crucial to prevent potential accidents, including fire, explosionand environmental damage. By adhering to the recommended actions and guidelines, duty holders can contribute to a safer working environment in VRU operations.
Share the Alert: Spread the word within your network to raise awareness and prioritise safety. Let’s work collaboratively to prevent accidents and ensure the well-being of all those involved in VRU operations.
Stay Safe. Work Safe.
Find out more here: https://www.hse.gov.uk/safetybulletins/vapour-recovery-overfill.htm?utm_source=hse.gov.uk&utm_medium=referral&utm_campaign=vapour-overfill-sa&utm_content=news-page
