Safety notice for overfill of vapour recovery units

The Health and Safety Executive (HSE) have issued a safety notice for operators of vapour recovery units (VRUs) including fuel terminals and COMAH (Control of Major Accidents Hazards) site operators.

This notice follows an HSE investigation into a gasoline overfill of a carbon adsorption VRU that revealed concerns with its design. VRUs are used to recover hydrocarbon vapour which is displaced during transfer operations such as the filling of tankers and ships at fuel storage and distribution terminals.

It was found that the overfill prevention system was not independent of the basic process control system (BPCS), so when the BPCS failed, the overfill prevention system also failed. A failure of the overfill prevention results in a loss of containment and poses a significant risk of fire and explosion occurring, alongside extensive environmental damage.

The HSE are urging duty holders to ensure that a safe system of work is used to assess the risk of overfill, equipment is properly checked and where it is appropriate, VRU control systems are modified or independent control measures are implemented to manage the risk.

Duty holders must ensure they:

• undertake a suitable and sufficient risk assessment of overfilling the absorber column and any other risks associated with the VRU;
• inspect, maintain and test all identified safety functions and equipment on the VRU; and
• modify control measures if the risk assessment identifies risk reduction actions are required.

The HSE advise consulting the VRU manufacturer and specialist contractors for assistance.

For more information, see:

• Safety notice - Overfill of vapour recovery units.