Health and Safety for Petrol Retailers
My business operates in a high risk environment and I have to comply with everything from ‘DSEAR’ to food hygiene legislation. Where do I start?
The simple answer is you need to have a clear picture in your mind of how your safety management system is to be organised. This will be captured within the text of your Health, Safety and Environmental Policy, a key legislative requirement if you have more than five employees. This needs to be matched by a fully transparent approach to safety that is unequivocal and accessible not only to you, but also to your staff as well as public inspectors.
There is no escaping the fact that documentation figures prominently in the administrative side of safety management in any industry and this provides our focus in this instance. The principle of demonstrating ‘due diligence’ was never more relevant than in petrol retailing. We would therefore recommend that all health and safety related documents, including safety notices, petroleum license, mandatory certification, risk assessments, training records, safety checks and emergency procedures are physically managed using three key vehicles:
1. Safety Notice Board
It is a legal requirement that the ‘Health & Safety Law’ poster and the Employers Liability Insurance certificate are displayed to staff. Other notices such as the Safety / Environmental Policy and Emergency Procedures are commonly displayed in this way. Selected safety guidance documents and bulletins should also be included, but take care that such information is current, relevant and in good condition. Overcrowded, irrelevant information used as a poor substitute for wallpaper will have a detrimental effect on staff attitudes to safety.
2. Safe Operations Register
In many respects this is the nerve centre of your site’s safety management system. If a public health inspector or Petroleum Officer calls, or in the course of an investigation following an incident you need to be confident that current, up to date, ‘live’ documentation is available for inspection. If this is not either in the register or on the safety notice board, there should be reliable information as to where it is kept – for example daily wet stock reconciliation records. The last thing you want is a Petroleum Officer becoming increasingly impatient because your staff training records have fallen down behind the cigarette gantry?
3. Archive filing system
One of the most common and irritating faults in terms of the management of health and safety documentation is the maintenance of out dated, irrelevant and in some cases entirely pointless paperwork that serves only to conceal the vital aspects of due diligence. This is not helped by well meaning public inspectors who freely distribute guidance on everything from ‘RIDDOR’ to ‘COSHH’, in the hope that it will contribute to safety ‘compliance’. To make matters worse, petrol retailers who believe that there is a short cut to good health and safety management then collect such information in the apparently mistaken belief that if they keep enough of it, they will gain some magical legal protection or immunity! A cynical view perhaps, but this is a reality!
No-one is denying retailers’ understandable concern that vital documentation may be discarded. The answer is a reliable system of archiving documents that leads to their eventual disposal, whilst also providing a vital safety net. A single drawer in a filing cabinet should be sufficient for this purpose.
Ok so we’re organised. Now what are the key aspects of safety that need to be (seen to be) managed? The following list may help:
- A system for controlling the actions of contractors whilst on site.
- A system for ensuring that all staff are trained and competent.
- A system for regularly checking the safety of the site and operating procedures.
- A system for monitoring wet stock losses.
- A system for the safe acceptance of road tanker deliveries.
- A system of risk assessment covering all key actions and processes.
- A system for responding to major incidents and emergencies, including fire drills.
- A system of reporting and investigating accidents.
This may not be an exhaustive list, but if you’ve got this in position you’re doing ok. It is of vital importance that written evidence is maintained.