Managing Risks with Flammable Liquids and Hazardous Atmospheres

Fuel Tank Maintenance (Non-Entry) SWMS

Compliant with AS 1940 and Australian WHS Regulations

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This Safe Work Method Statement (SWMS) provides a framework for conducting fuel tank maintenance activities that do not require personnel to enter the tank (non-entry). This work is considered high-risk due to the presence of flammable and combustible liquids and their associated vapours. This document is essential for any PCBU or worker involved in the maintenance of fuel storage tanks to comply with Australian WHS laws and AS 1940.

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Overview

What this SWMS covers

Non-entry fuel tank maintenance encompasses all activities performed to service, clean, or inspect a fuel storage tank from the outside. This method is strongly preferred over confined space entry due to its significantly lower risk profile. Common tasks include pumping out residual fuel, water, and sludge from the tank bottom; cleaning internal surfaces using high-pressure jets or specialised robotic equipment; conducting remote visual inspections with cameras; and testing or replacing external fittings, vents, and sensors. The process requires careful planning to manage large volumes of flammable liquids and control the hazardous vapours that are always present. This work is critical for maintaining fuel quality, ensuring tank integrity, and complying with environmental and safety standards.

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Why this SWMS matters

A SWMS for non-entry fuel tank maintenance is essential because the work still involves high-consequence risks. A fire or explosion can occur if flammable vapours are not properly managed and find an ignition source. Accidental release of fuel during pumping can lead to major environmental contamination, attracting huge fines from the Environmental Protection Authority (EPA). Inhalation of concentrated fuel vapours can cause immediate and long-term health effects. This SWMS provides the documented, systematic approach required by WHS law to manage these risks. It ensures that workers follow critical safety protocols like using explosion-proof equipment, grounding and bonding to prevent static discharge, monitoring the atmosphere for explosive limits, and having a detailed emergency response plan. It is a key document for demonstrating compliance with AS 1940 and other relevant standards.

Reinforce licensing, insurance, and regulator expectations for Fuel Tank Maintenance Non-entry crews before they mobilise.

Hazard identification

Surface the critical risks tied to this work scope and communicate them to every worker.

Risk register

Fire and Explosion

high

Flammable vapours from fuel can accumulate in and around the tank. A static discharge, spark from non-compliant equipment, or other ignition source can cause a catastrophic explosion.

Consequence: Multiple fatalities, complete destruction of property, and significant off-site impact.

Inhalation of Hazardous Vapours

high

Fuel vapours (e.g., benzene) are toxic and can displace oxygen. Inhaling these vapours can cause dizziness, respiratory issues, and long-term health problems like cancer.

Consequence: Acute poisoning, long-term illness, or asphyxiation.

Environmental Contamination

high

A spill during fuel transfer, or leakage from a poorly maintained tank, can release fuel into soil and groundwater, causing significant environmental harm.

Consequence: Costly environmental clean-up liabilities, large fines from the EPA, and long-term damage to the ecosystem.

Chemical Burns and Skin Exposure

medium

Direct contact with fuels and cleaning solvents can cause skin irritation, chemical burns, dermatitis, and absorption of toxic substances through the skin.

Consequence: Painful skin conditions, long-term health effects.

Control measures

Deploy layered controls aligned to the hierarchy of hazard management.

Implementation guide

Establishment of a Hazardous Zone and Ignition Source Control

Isolation

Isolate the work area to prevent ignition sources from coming into contact with flammable vapours.

Implementation

1. Establish a clearly marked exclusion zone around the tank work area in accordance with AS 1940. 2. Prohibit all potential ignition sources within the zone, including smoking, mobile phones, and non-certified electrical equipment. 3. Use warning signs to clearly communicate the flammable hazard. 4. Ensure all workers in the zone are trained on the risks.

Use of Intrinsically Safe and Grounded Equipment

Engineering

Use equipment specifically designed for flammable atmospheres to eliminate potential ignition sources.

Implementation

1. Use only certified explosion-proof or intrinsically safe pumps, lights, and atmospheric monitors. 2. Ensure all equipment, including the tank, transfer vehicle, and hoses, are properly bonded and grounded to prevent static electricity build-up. 3. Use non-sparking tools for any work on tank fittings.

Atmospheric Monitoring and Ventilation

Engineering/Administrative

Continuously monitor the atmosphere to ensure it remains below the Lower Explosive Limit (LEL) and provide ventilation to disperse vapours.

Implementation

1. Use a calibrated gas detector to continuously monitor LEL levels around the work area. 2. Cease work immediately if LEL levels exceed 10% of the limit. 3. Use mechanical ventilation (e.g., air eductors) if natural ventilation is insufficient to keep vapour concentrations low. 4. When purging the tank, monitor oxygen and vapour levels to confirm the atmosphere is inert.

Spill Prevention and Response protocols

Administrative

Implement robust procedures to prevent and manage spills during fuel transfer and maintenance.

Implementation

1. Place portable bunding around connection points during fuel transfer. 2. Have a fully stocked spill kit and fire extinguisher immediately available at the work site. 3. Ensure a trained spotter is present to monitor for leaks during all pumping operations. 4. Never leave fuel transfer operations unattended. 5. Have an emergency spill response plan and ensure all workers are trained on it.

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Personal protective equipment

Fuel-Resistant Gloves

Requirement: AS/NZS 2161 series

When: Required when handling any equipment that may be in contact with fuel, such as hoses and fittings.

Organic Vapour Respirator

Requirement: AS/NZS 1716

When: Required if atmospheric monitoring indicates the presence of vapours above the workplace exposure standard, or as a precaution when working near open tank hatches.

Flame-Retardant and Anti-Static Coveralls

Requirement: N/A

When: Recommended for all personnel working within the hazardous zone to protect against flash fires and static build-up.

Chemical Splash Goggles

Requirement: AS/NZS 1337.1

When: Required during all fuel transfer and cleaning operations to protect eyes from splashes.

Inspections & checks

Before work starts

✓Verify all ignition sources have been removed from the designated hazardous zone.
✓Inspect all hoses, pumps, and grounding straps for damage before use.
✓Calibrate and bump test the atmospheric monitor before starting work.
✓Confirm the spill kit and correct type of fire extinguisher are present and accessible.

During work

✓Continuously monitor the atmospheric LEL levels.
✓Check all hose connections for any signs of leakage during pumping.
✓Ensure grounding and bonding connections remain secure throughout the task.
✓Monitor the surrounding area to ensure no unauthorised personnel enter the exclusion zone.

After work

✓Conduct a final check of the work area for any spills or leaks.
✓Ensure all tank hatches and fittings are securely sealed.
✓Account for all tools and equipment.
✓Properly containerise and label all hazardous waste for disposal.

Step-by-step work procedure

Give supervisors and crews a clear, auditable sequence for the task.

Field ready

Site Isolation and Hazard Zone Setup

Before any work begins, establish and clearly mark a hazardous zone around the tank. Use barriers and signage to prevent unauthorised entry. Remove or control all potential ignition sources within this zone. Verify that emergency response equipment (fire extinguisher, spill kit) is in place.

Safety considerations

The size of the hazardous zone must comply with AS 1940. Failure to control ignition sources is the leading cause of fuel tank explosions.

Lock-Out, Tag-Out and Grounding

Isolate the tank from all associated pipework and electrical systems using lock-out/tag-out (LOTO) procedures. Connect bonding and grounding cables between the tank, the transfer pump, the receiving vehicle/tank, and a designated earth point to prevent static electricity accumulation.

Safety considerations

Static discharge is a primary ignition risk. All components must be part of the grounding and bonding circuit. Only the person who applied a lock may remove it.

Fuel Transfer (Pumping Out)

Using an intrinsically safe pump, transfer the residual fuel from the storage tank to an approved temporary holding tank or vacuum truck. Continuously monitor hose connections and the tank level throughout the process. A second person must act as a spotter, ready to shut down the operation if a leak occurs.

Safety considerations

Never leave the pumping operation unattended. Be prepared for an emergency shutdown at all times. Ensure the receiving tank has adequate capacity.

Remote Cleaning and Inspection

Once empty, conduct cleaning and inspection using non-entry methods. This may involve lowering high-pressure cleaning heads, robotic cleaners, or inspection cameras into the tank through existing access hatches. All equipment used must be rated for use in a flammable atmosphere.

Safety considerations

Do not lean directly over open hatches. Use appropriate respiratory protection if vapours are present. Ensure all equipment lowered into the tank is securely tethered.

Waste Management and Recommissioning

Pump all waste liquids (sludge, cleaning fluids) into sealed and properly labelled drums or a waste tanker. Once maintenance is complete, remove all LOTO tags and recommission the tank according to the client's procedure. Clean and inspect the work area before removing the exclusion zone.

Safety considerations

All waste is considered hazardous and must be disposed of by a licensed contractor in accordance with EPA regulations. Do not mix different types of waste.

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Frequently asked questions

What does LEL stand for and why is it important?

LEL stands for Lower Explosive Limit. It is the minimum concentration of a flammable vapour in the air that can ignite. For safety, work is typically stopped if the concentration reaches 10% of the LEL, as this provides a significant safety margin before the atmosphere becomes explosive.

What is the difference between bonding and grounding?

Bonding is connecting two or more conductive objects together with a conductor to equalise their electrical potential, preventing static sparks between them. Grounding is connecting an object to the earth to dissipate any electrical charge to the ground. For fuel transfer, both are required: all equipment is bonded together, and the entire system is grounded.

Can I use a standard wet-dry vacuum for cleaning out a fuel tank?

No, absolutely not. A standard vacuum cleaner is not intrinsically safe and its electric motor is a guaranteed ignition source for flammable vapours. You must use a pump and vacuum system specifically designed and certified for handling flammable liquids.

What type of fire extinguisher is needed for fuel tank work?

You should have a Dry Chemical (ABE) or Carbon Dioxide (CO2) fire extinguisher. ABE is versatile for Class A, B, and E fires. However, for flammable liquid fires (Class B), a CO2 extinguisher or a dedicated foam (B) extinguisher is also highly effective. Water extinguishers must never be used on fuel fires.

Overview of Non-Entry Fuel Tank Maintenance

Non-entry fuel tank maintenance involves a range of tasks performed from the outside of a storage tank, such as testing fuel quality, pumping out old fuel or sludge, cleaning internal surfaces with specialised equipment, inspecting tank integrity, and testing sensors or fittings. These tasks are common for both underground and above-ground storage tanks at service stations, depots, and industrial facilities. The key principle is to avoid the extreme hazards of confined space entry by using remote tools, pumps, and inspection equipment. Proper planning, isolation of energy sources, and management of flammable vapours are critical to performing this work safely.

Why a SWMS is Critical for This Task

Working with fuel storage tanks, even without entering them, is fraught with danger. The risk of fire or explosion from flammable vapours ignited by a stray spark is ever-present. Exposure to toxic fuel vapours can cause serious respiratory illness, and skin contact can lead to dermatitis. Environmental contamination from a fuel spill can result in massive clean-up costs and regulatory fines. This SWMS is a legal and practical necessity, providing a systematic process to manage these severe risks. It mandates critical safety steps, such as establishing exclusion zones, de-energising equipment, using intrinsically safe tools, monitoring the atmosphere for explosive gases, and having robust spill and fire response plans ready. It ensures that all work complies with AS 1940: The storage and handling of flammable and combustible liquids, thereby demonstrating due diligence and protecting workers, the public, and the environment.

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