The Liquid Fuels Handling Code (LFHC) Technical Working Group (TWG) made three amendments to Appendix I of LFHC on retail mobile fueling. Please click to read the updated Appendix I – Retail Mobile Fueling Requirements.
The amendments are as follows:
Item 1
Existing Clause: I.3.1 Twenty heavyweight spill pads (hydrophobic 45cm x 60cm)
Amended Clause: I.3.1 Twenty heavyweight spill pads (hydrophobic, 38cm x 45cm)
Rationale for Change: The size listed is not a common size and therefore it is difficult to source in the marketplace.
Item 2
Existing Clause: I.4 Nozzles used for dispensing shall be no greater than 25.4mm (1in) in diameter and shall be of the automatic shut-off design. The fuel delivery driver shall be in attendance (within arms-reach) of the nozzle during fuel transfer.
Additional Clause:
I.5 Notwithstanding Clause I.4, the dispensing of Class II fuel may be permitted using a non-auto shut-off nozzles with a spout greater than 25.4mm (1in) in diameter where:
(a) The fuel level in the tank is visible during the fueling operation at the filling point when the fuel nozzle is inserted into the fill opening; and
(b) The fuel delivery driver, or in the case of a watercraft, the person located at the fueling position, shall maintain a constant line of sight of the level of the fuel in the fuel tank during the fueling operation to prevent a spill.
Rationale:
It has become evident that the requirements listed in Appendix I – Retail Mobile Fueling, will place a burden on fuel distributors that currently perform mobile fueling to large commercial vehicles and watercraft using highway tanks that do not have a dedicated low pressure delivery hose used to conduct mobile fueling to small vehicles, watercraft and equipment. In most cases these existing delivery vehicles cannot be retrofitted to accommodate a third reel, piping configuration or controls to accomplish this. In addition, for trucks that can accept a third reel, the cost is excessive. This will effectively prevent any fuel distributor from continuing to use their existing delivery vehicles for the purpose of retail mobile fueling to these types of vehicles and watercraft, an activity that they have been doing safely for years with their highway tanks. Requiring an auto shut-off nozzle with a 25.4 mm (1in) spout to be used in this application will not increase dispensing safety or reduce the risk to the environment. In fact, it could have the opposite effect by creating unsafe conditions by using a device that may not function properly under this level of pressure.
Item 3
Under I.13 include an extra provision to allow fueling within 30 m of a stream, river, lake, canal or natural watercourse when fueling watercraft:
I.13 (a) Fuel may be dispensed within 30 m of a stream, river, lake, canal, or natural watercourse
Rationale: Need this provision to fuel watercraft
If you have questions or comments, please email Chris Thompson at cthompson@tssa.org.
This communication was sent to Liquid Fuels Handling Code Working Group, liquid fuels tanker trucks, liquid fuel facilities and Fuel web subscribers.