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This document is available from www.hse.gov.uk/gas/lpg// Page 1 of 29 Health and Safety Executive Liquefied Petroleum Gas (LPG) - Industrial and Commercial Users' Awareness of their legal Responsibilities Contents Page Acknowledgements 2 Executive Summary 3 1. Introduction 4 2. Methods 5 3. Results 8 4. Discussion 12 5. References 14 Appendix A: Main Survey Results 15 Appendix B: Main Survey Questionnaire 23 Appendix C: Feasibility Study 29

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This document is available from www.hse.gov.uk/gas/lpg// Page 1 of 29

Health and Safety Executive

Liquefied Petroleum Gas (LPG) - Industrial and Commercial Users' Awareness of their legal Responsibilities

Contents Page

Acknowledgements 2

Executive Summary 3

1. Introduction 4

2. Methods 5

3. Results 8

4. Discussion 12

5. References 14

Appendix A: Main Survey Results 15

Appendix B: Main Survey Questionnaire 23

Appendix C: Feasibility Study 29

This document is available from www.hse.gov.uk/gas/lpg// Page 2 of 29

ACKNOWLEDGEMENTS

Thanks to all industrial and commercial LPG users who gave their time to take part in this research.

Thanks to UKLPG and all LPG suppliers who provided data for the sampling frame and support to the

project.

Thanks also to HSE laboratory staff who managed various stages of this research and analyses notably:

Roxane Gervais, David Fox, Daniel Greaves, Philip Beards, Kerry Poole, Phoebe Smith, and HSE

Operational and policy staff who assisted in production of this report notably: Simon Clarke, Michael Clarke,

Alison Higgins and Alison Richards.

This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents,

including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily

reflect HSE policy.

This document is available from www.hse.gov.uk/gas/lpg// Page 3 of 29

EXECUTIVE SUMMARY

INTRODUCTION

A public inquiry following an LPG explosion at the ICL Plastics Ltd factory in Glasgow in 2004 concluded

that the cause was ignition of LPG vapour leaking from buried, corroded metallic service pipework and

identified, among other things, confusion over who was legally responsible for maintaining the LPG service

pipework. Further, a 2006 HSL study of industrial and commercial LPG users after the incident suggested

generally very low user awareness of their legal responsibilities with respect to ensuring service pipework

was in a satisfactory condition. Since the incident and inquiry the industry and HSE have been working

together more intensively to improve safety. Some of this work has been aimed at raising users’

awareness of their responsibilities.

This study reports principally on the current level of industrial and commercial users’ awareness of their

legal responsibilities with respect to maintenance of the LPG service pipework to allow assessment of

whether current awareness raising initiatives should be increased, maintained, or scaled back.

METHODS

In June 2015, a telephone survey was administered to a stratified random sample of high and low risk

industrial and commercial LPG users from a sampling frame supplied by the industry. In total, 319 valid

interviews were obtained, 157 among high risk users and 162 among low risk users. Interviews were with

the person claiming to be responsible for the safety of the LPG gas supply at that site and questioned

knowledge and beliefs with respect to installation characteristics, maintenance and ownership.

RESULTS AND DISCUSSION

Approximately 43% of all respondents indicated that their company had a legal responsibility to maintain

the LPG pipework with no significant difference between those in high or low risk groups. Indications are

that this particular level of awareness has probably considerably improved since 2006. However, there is

no clear evidence to benchmark whether this level of knowledge of legal responsibility is comparable with

similar situations in other industrial populations.

Approximately 45% reported the service pipework was owned by their company. Among those that report

ownership of the service pipework, the proportion reporting legal responsibility for its maintenance was

significantly higher.

Most respondents (87%) reported that the LPG supplier was responsible for maintenance of the LPG tank

on their site.

An estimated 58% of respondents claimed to have an installation record for their LPG installation. However,

38% of respondents reported they didn’t know whether their buried pipework was made of plastic or metal,

and 17% didn’t know whether it was less or more than 5 years old.

The main thrust of the safety improvement following the inquiry has been a service pipework replacement

programme prioritised on the basis of risk. No respondents in this survey, undertaken in June 2015,

reported a combination of characteristics, including old metallic buried pipe work, that would be broadly

indicative of a high risk LPG installation. However, as there were a number of respondents that reported

that they “didn’t know” to some of the questions asked about such higher risk characteristics, it is possible

that some such installations exist in the population surveyed.

This survey was designed to provide a quick snap shot of the industry and relied on self-reported

responses to a one off telephone survey. The limitations of the results and conclusions must be viewed in

this context.

This document is available from www.hse.gov.uk/gas/lpg// Page 4 of 29

1. INTRODUCTION

1.1 BACKGROUND

In May 2004 a large explosion at the ICL Plastics Ltd factory in Glasgow resulted in the deaths of nine

people and injuries to 33 more. The explosion was caused by a leak, into the basement of the factory, of

liquefied petroleum gas (LPG) from a corroded underground metallic pipe. Following the incident and the

subsequent inquiry by Lord Gill1 that identified the causal circumstances, HSE worked with the LPG

industry to among other things assess the scale of the problem and improve safety in industrial and

commercial use of LPG. Hence forth in this report the term commercial implies industrial and commercial.

Full details of the inquiry and the government and industry’s response are available from the inquiry

website1 and HSE webpages on LPG2.

The main thrust of the safety improvement was the replacement of buried carbon steel LPG service

pipework and this was staged by assessed degree of risk3. However, HSE worked with industry to improve

other areas identified as contributory causes to the ICL incident such as ICL’s lack of awareness of their

duties and responsibilities for the LPG installation at the time of the incident. A 2006 study, principally

undertaken to provide information on the number and type of industrial LPG installations in Britain,

indicated very low knowledge and understanding amongst users generally of their legal responsibilities4. To

raise awareness HSE and UK LPG suppliers agreed a number of actions:

• LPG suppliers distributed a leaflet to all commercial LPG users.

• LPG suppliers provided relevant information upon customer contact.

• UKLPG (the trade association for LPG suppliers in the United Kingdom) hosted customer

information on their website.

• HSE ensured relevant information was clearly available on their website

• HSE ensured during regulatory contact such issues were raised if relevant.

This study aims to assess the current level of awareness of commercial LPG users regarding their legal

responsibilities, and so inform a judgement as to whether current awareness raising initiatives should be

increased, maintained, or scaled back.

1.2 PROJECT AIM

The overall aim of the study was to:

• Determine the general level of awareness of commercial LPG users regarding their legal

responsibilities for maintaining their entire LPG gas installation to a safe standard; the factors that

have informed this awareness; and how they act on this.

1.3 OBJECTIVES

The objectives of this study were to:

• Assess commercial duty holders’ level of awareness of their legal responsibilities with respect to

their LPG installation.

• Identify the sources of information that currently help inform commercial users of their

responsibilities.

• Assess levels of maintenance activity and the proportion of those duty holders with an installation

record.

This document is available from www.hse.gov.uk/gas/lpg// Page 5 of 29

2. METHODS

A telephone survey of commercial LPG users was identified as the most cost effective and proportionate

approach to gather the required level of information, given the resources, time and information available.

2.1 SAMPLING FRAME AND FEASIBILITY STUDY

Securely stored individual suppliers’ lists of their commercial customers provided to HSE in 2006 and

updated in 2012 were used to generate a sampling frame. Initially, domestic users, uses for vehicle such

as forklift trucks, liquid phase LPG, cases where LPG supply had ceased, and those with no contact

telephone number was available, were removed from each supplier list. Then, supplier identity and other

information except, contact telephone numbers, contact name, status in terms of original pipework

replacement priority (1 or 2), were removed from each suppliers lists before combination into a single

master list. Finally, duplicates were removed from this master list to form the sampling frame. All prior

created combined lists were destroyed and the sampling frame was stored encrypted and password

protected on a secure server. A small random selection of priority 1 and priority 2 sites were securely

passed to HSL researchers for purposes of undertaking a feasibility study. This feasibility study (reported

briefly in Appendix C) was undertaken to test the viability of the sampling frame, response rates,

questionnaire design and to determine most importantly whether a large enough number of respondents

from priority 1 and 2 categories could be achieved given the size of sampling frame.

2.2 QUESTIONNAIRE AND MAIN SURVEY

The questionnaire was developed and refined in light of consultation with the UKLPG (the trade association

for LPG suppliers in the United Kingdom), and feedback from the feasibility study. The final questionnaire

included questions that were relevant to each of the research objectives – see Appendix B.

Sample size calculations were undertaken in Stata5 (based on 80% power). These calculations indicated

around 150 responses in each of the priority groups would provide estimates within ± 8% and enable a

difference of ± 16% or more between priority groups to be identified with statistical significance. Further,

the combined 300 responses would provide estimates within ± 6%. This level of precision was considered

adequate. The feasibility study indicated this number of respondents was likely to be achievable from the

remaining sampling frame available (see Table 1). However, the feasibility study indicated that it was not

viable or cost effective for HSL staff themselves to undertake the telephone interviewing, so it was agreed

with UKLPG that this part of the survey should be sub-contracted to a professional telephone survey

company.

Table 1 – UKLPG’s commercial user database by structure

Risk rating* Status Sampling frame

(n)

Provided to contractors**

( n)

A - C Priority 1 1223 1123

D1, E1, D2, E2 Priority 2 10456 1500

Total 11679 2623

*Risk rating refers to the probability of pipes corroding and leading to a gas concentration in a building that could result in an event (A = 1 - 0.1; B = 0.1 - 0.001; C = 0.001 - 0.0001

3

** Samples were provided to contractors sufficient to realise a response of around 150 in each group. The priority 2 sample was randomly selected from within this category

The survey company was contracted to undertake at least 300 telephone interviews (150 from priority 1

and 150 from priority 2) with the person claiming to be responsible for the safety of the LPG gas supply at

that site. These included company managers, facilities managers, or health and safety managers. The

interviews followed a mainly structured question set, with the answers consisting of predetermined options

This document is available from www.hse.gov.uk/gas/lpg// Page 6 of 29

for the majority of the questions. An ‘other - please specify’, open-ended option was included also, where

appropriate, to ensure the collection of any other relevant information. The interviews were undertaken in

accordance with the British Psychological Societies Code of Conduct6. This requires that interviewees are

assured of the confidentiality of their responses; that they could terminate the interview at any time; and

that they would not be identifiable in the reported study results.

A random subset of 1,123 priority 1 and 1,500 priority 2 cases, restricted only to telephone numbers and

contact names, were extracted from the sampling frame. These were provided to the selected telephone

interview contractor on a secure server. The contractor was also provided with the questionnaire and an

explanatory script for the interviewers to read out on initial contact that, among other things, assured

confidentiality of responses – see Appendix B).

The credentials of the sub-contractor were checked to ensure interviewers were appropriately trained,

competent and experienced in conducting telephone interviews. The contractor was required to undertake

a calling strategy that required at least three contact attempts at different times of the day and different

days of the week before the lead was dropped. The specified strategy also included ‘organise call backs’ at

an appropriate time for the business if the appropriate person was not available on initial contact. This

strategy was specified in order to maximise use of the sample so as to ensure that not just easy to reach

leads were interviewed. The interview was undertaken only with the person who claimed to be responsible

for the safety of the LPG gas supply at the site.

2.3 SAMPLING STATISTICS

Approximately 78% of the businesses in the sample of 2,623 businesses provided for interview were

contacted to gain the required sample for the research. This represents approximately 86% of priority 1

businesses and 73% of priority 2 businesses from the respective samples provided. An overall response

rate of 23% was achieved based on those businesses contacted; resulting in 16% of those contacted

providing a full interview. Full details provided in Table 2.

Table 2 Overview of recruitment

N %

Sample provided 2623

Priority 1 1123

Priority 2 1500

Businesses contacted 2048 78

Priority 1 950 85

Priority 2 1098 73

% relative to sample provided

Contacts agreeing to the interview 466 23

Contacts with an LPG supply 327 16

Contacts with an LPG supply & tank

319 16

% relative to those contacted

Completed interviews 319 16

Priority 1 157 17

Priority 2 162 15

% relative to those contacted

This document is available from www.hse.gov.uk/gas/lpg// Page 7 of 29

2.4 ANALYSIS

Analysis was undertaken in SPSS7. Simple descriptive statistics with selected cross-tabulations are

presented only, with proportions rounded to the nearest whole percentage. To indicate the precision of

results, 95% confidence intervals (95% CI), are provided for selected results. These represent the range of

values that have a 95% chance of containing the true value from the population sampled in absence of

bias. Chi-square analysis was used to test the statistical significance of differences in proportions such as

between priority groups 1 and 2. For simplicity, no weighting was applied to the data, although in terms of

representativeness of the total commercial LPG user population it must be noted that priority 1 status were

over represented in the survey sample. In the survey, around half of respondents were classified as priority

1 whereas in the sampling frame which is more representative of all commercial LPG users, only around

10% were classified as priority 1 (see Table 1). Hence, where there is a significant difference between

priority 1 and priority 2 for a particular answer, caution must be exercised in interpreting the combined

results.

This document is available from www.hse.gov.uk/gas/lpg// Page 8 of 29

3. RESULTS

Appendix A provides tabulated responses for all survey questions, ordered by question number. Here are

presented analyses most pertinent to the survey objectives.

3.1 LPG PIPEWORK OWNERSHIP

Reponses to who owns the LPG pipework at their business site is shown below in Figure 1 and in Q12 –

see Appendix A. This question was only asked of the 80% of respondents that reported buried pipework

(Appendix A, Q6). There was no significant difference in answers between priority 1 and priority 2

respondents. Overall, 45% (95% CI: 39% to 51%) indicated that the LPG pipework was owned by their

company. If those who didn’t know are excluded, this rises to 58% reporting their company’s ownership of

the LPG pipework, with around 33% reporting that the LPG supplier owned the pipework.

Figure 1 – Ownership of LPG pipework by user

3.2 MAINTENANCE

3.2.1 KNOWLEDGE OF LEGAL RESPONSIBILITIES

All who had an LPG tank and LPG supply (n=319) were asked if they knew if their company had any legal

responsibility to maintain the LPG pipework. There was no significant difference between priority 1 or 2

groups with respect to answers. Figure 2 and Appendix A, Q18 show that overall 43% (95% CI: 37% to

48%) indicated that their company did have a legal responsibility whereas 22% (95% CI: 18% to 27%) said

that they did not, with another 35% (95% CI: 30% to 41%) not knowing either way.

Figure 2 – Knowledge of company’s legal responsibilities - maintenance of pipework

0

10

20

30

40

50

Our company Landlord LPG supplier Don't know Other

Res

po

nse

s (%

)

Ownership of LPG Pipework

Priority 1

Priority 2

0

10

20

30

40

50

Yes No Don't Know

Res

pon

ses

(%)

Knowledge of legal responsibilities

Priority 1

Priority 2

This document is available from www.hse.gov.uk/gas/lpg// Page 9 of 29

For those that were aware of their company’s legal responsibility most report knowing this from supplier or

industry provided information (67%), with a quarter also reporting getting information from the regulators,

and a quarter from others sources (see Q19, Appendix A). When considered in the context of pipework

ownership, 65% of those who reported owning the pipework reported also that they had legal

responsibilities, compared to 21% among those who reported the LPG supplier owned the pipework – see

Table 3.

Table 3. Whether respondents report their company has legal responsibilities for LPG pipework maintenance by who they report owns that pipework

Yes No

Reported ownership Estimate 95% CI Estimate 95% CI

Our company 65% 60% to 71% 29% 23% to 34%

Landlord 4% 1% to 6% 5% 3% to 8%

LPG supplier 21% 17% to 26% 46% 41% to 52%

Don’t know 8% 5% to 11% 16% 12% to 20%

Other 2% 0% to 3% 4% 1% to 6%

3.2.2 RESPONSIBILITY FOR MAINTENANCE

The questionnaire distinguished responsibility for actual maintenance from any knowledge of legal

responsibility for maintenance covered in section 3.2.1. When those with buried pipework (n=269) were

asked who was responsible for maintaining the pipework just under a third indicated it was their company

that maintained the pipework whilst just over a third indicated it was the LPG supplier (Appendix A, Q13).

There was no significant difference between priority 1 or 2 groups with respect to these results.

Interestingly, when considered by reported LPG pipework ownership, 65% of those who report their

company owned the pipework say their company is responsible for maintenance, with only 27% saying it is

the LPG supplier. Conversely, for those that report the LPG supplier owns the buried pipework over 80%

report that the supplier is responsible for the maintenance of that pipework –Table 4. Although numbers are

small, this provides a similar pattern of response to that seen when looking at knowledge of companies

legal responsibility for maintenance. If the respondent believes they own the pipework they are much more

likely to indicate responsibility for the maintenance both in practice and as a legal requirement on them.

Table 4 – Reported responsibility for LPG pipework maintenance between own company and LPG supplier by who is believed to owns that pipework

Who reported responsible

Company LPG supplier

Reported ownership Estimate 95% CI Estimate 95% CI

Our company 65% 59% to 71% 27% 21% to 32%

Landlord 18% 14% to 23% 27% 22% to 33%

LPG supplier 7% 4% to 10% 83% 78% to 87%

Don’t know 17% 13% to 22% 32% 26% to 37%

Other - 2% 0% to 3%

This document is available from www.hse.gov.uk/gas/lpg// Page 10 of 29

Of those with buried pipework, 75% reported that those who under take maintenance are gas safe

registered (Q15, Appendix A. Further, 45% report maintenance had been carried out in the last 5 years

(Q15, Appendix A) and this maintenance was reported to most frequently involve pipework replacement

and visual inspection (Q16, Appendix A). Nearly 10% of those with buried pipework (Q11, Appendix A)

reported that they planned to replace that pipework.

For all those with an LPG tank and LPG supply (n=319), nearly all indicated the LPG supplier was

responsible for maintaining the LPG storage tank with only 3% not knowing (Q5, Appendix A). This level of

certainty was not characteristic of responses to the other questions on maintenance and ownership

reported on above, i.e. Questions 11, 12, 13, 15, and 18. Here, those who reported they “didn’t know” to

these questions, typically ranged 9% to 35% with, as noted previously, the highest ‘don’t knows’ recorded

against legal responsibility.

3.3 INSTALLATION KNOWLEDGE AND RECORDS

For those with buried pipework, around 38% didn’t know whether the pipework was made of plastic or

metal (Q10, Appendix A) and 17% didn’t know whether it was older than 5 years old or younger. Although

based on a small number of responses, 5% didn’t know if any of the pipework was buried, and 21% of

those with an underground void or cellar didn’t know whether the pipework entered this space. However,

58% reported they had an installation record for the LPG installation (Q17, Appendix A).

3.4 HIGHER RISK RESPONDENTS

LPG explosion risks can arise from an LPG leakage, possibly from damaged or corroded pipework, that

tracks down (because it is heavier than air) and accumulates in a poorly ventilated area where it can build

up to sufficient levels to cause an explosion if it finds an ignition source.

In this respect, higher risk LPG installations can be characterised as those where:

• There is pipework that is more susceptible to corrosion and its condition is difficult to check, i.e. older

carbon steel pipework that is buried.

• If any leaks occurred, leakage rates would be higher, i.e. higher pressure LPG installations.

• LPG could accumulate, i.e. buildings with basements, cellars or below ground voids, especially where

LPG pipework directly enters these areas.

Several survey questions touched on these characteristics and the proportions providing what could be

considered higher risk responses to such questions are shown over the page in Table 5.

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Figure 5 – Responses to selected questions indicative of higher risk

Question Response n % Q4 LPG Pressure either High or Medium 18 6%

LPG Pressure either High, Medium or Not known 302 95%

Q6 Buried pipework 254 80%

Buried pipework or not known if buried 269 84%

Q7* Buildings contains basement/cellar/under floor void 61 23%

Buildings contains basement/cellar/under floor void or not known

71 26%

Q8** Pipework enters basement/cellar/void 13 5%

Pipework enters basement/cellar/void or not known 28 10%

Q9* Pipe work older than 5 years 125 46%

Pipe work older than 5 years or age not known 179 67%

Q10* Pipework metal 45 17%

Pipework metal or not known whether metal or plastic 165 61%

* Not asked of those with above ground pipework ** Percentage calculated in relation to question 7 responses, i.e. those who report not having a basement, cellar or underground void are considered to be ‘no responses’ to question 8.

Taken together, no respondents reported a combination of high or medium LPG pressure, and buried metal

pipework older than 5 years that entered a void/cellar or basement. However, as many respondents did not

know the answer to some of these questions, it is possible that up to 12% (95% CI: 9% to 16%) could be

high risk in the unlikely event that all ‘don’t knows’ were in the higher risk categories.

This document is available from www.hse.gov.uk/gas/lpg// Page 12 of 29

4. DISCUSSION

This survey was mainly conducted to inform whether initiatives to make commercial LPG users more aware

of their responsibilities should be increased, maintained, or scaled back. Although no accurate baseline

exists on commercial user levels of awareness of their responsibilities before these initiatives, it was

reported to be very low in at 2006 study4. Given this, and that other factors would also inform such a

judgement, only a relatively crude assessment was considered necessary. This survey takes such a

proportionate approach and hence the results and study weaknesses must be viewed in this context.

The results must also be viewed in context of the nature of most commercial users of LPG. Although

details of business size were not asked in the survey, it was apparent from supplier lists that the majority of

businesses were small or micro businesses such as pubs, etc. It is recognised that responses to health

and safety surveys from such micro businesses are inherently less reliable than those from larger firms that

may have staff with dedicated safety roles. That aside, the questions were directed toward the person in

the business who claimed safety responsibility for the LPG supply at the site.

Approximately 43% of respondents indicated that their company had a legal responsibility to maintain the

LPG pipework and there was no difference in responses between those originally classified as priority 1 or

priority 2. This level of awareness could not be described as very low and on this basis is probably an

improvement on the levels of awareness since 20064. However, neither could 43% be described as

particularly high. There is no useful bench mark to compare whether this level of awareness on such issues

is good or bad. However, some data is provided in a 2005 report on SME compliance that indicated around

70% of hairdressers (with more than 5 employees) were aware of their legal requirements to undertake

risk assessments and assessments for chemicals used8. However, these data are arguably not particularly

comparable as they are broader health and safety requirements in a very specific industry group.

Interestingly, perceptions of pipework ownership and lack of knowledge of who owns the pipework play a

role in reported legal responsibility. Where the business claims ownership of the LPG service pipework,

around 65% report legal responsibility for its maintenance. Whereas, if others such as the LPG suppliers

are reported to own the service pipework only around 20% believe their business has any legal

responsibility for its maintenance. The survey asks also about responsibility for maintenance. It was felt that

this could be interpreted as who looks after, directs, or undertakes the maintenance, which may not be

exactly the same as the legal responsibility. Similar patterns are seen with these data when who the

respondent believes owns the pipework is also considered. There is much greater clarity with respect to

responsibility for the LPG tank, where the overwhelming majority of respondents are clear that the LPG

supplier has responsibility for the tanks maintenance.

Given that respondents are those claiming to be responsible for the LPG installation at the site, there was

lack of knowledge on a number of issues with respect to service pipework. Many did not know what

material the pipework was made of – even when response categories were simplified following the

feasibility study feedback into just metal or plastic. Similarly, there was little knowledge of what pressure

their LPG system operates at. In contrast, approximately 58% claim to have an installation record.

Adoption of a system that provides installation records to LPG users was a recommendation of the inquiry

into the 2004 ICL explosion1. Although industry agreed what such a record should contain and developed a

template9, there is no mandatory requirement to have such a record. What most respondents meant when

they indicated they had an installation record is difficult say and perhaps requires considerably more

questioning on the issue. As noted previously, the survey design was deliberately focused and limited to

reduce the burden on the respondent. A more considered and costly approach could explore the nature of

their claimed installation record and even call back respondents to get more reliable information on the

installation when they had the record at hand. Taking the view that all those claiming to have an installation

record at least had a record of when their LPG pipework was installed, at least 58% of respondents would

know accurately the age of their service pipework in future if such records were retained.

This document is available from www.hse.gov.uk/gas/lpg// Page 13 of 29

For most of the questions there was little difference in response between priority 1 and priority 2 groups.

This justifies the non-weighting of responses in analysis, as, on this basis and considering the levels of

precision being sought, there would likely be little difference in interpretation of unweighted and weighted

results. The lack of difference between priority 1 and priority 2 groups probably reflects the fact that this

prioritisation was applied at the start to suppliers’ lists in a conservative manner based on limited initial

information with the intention not to miss any higher risk installations. Subsequently all priority 1 sites have

been surveyed, many where found not to be high risk, and appropriate remedial actions including pipework

replacement has been undertaken in others. On this basis priority 1 and priority 2 sites were probably

similar at the time of this survey.

Generally surveys of this nature can also suffer from response biases for example where respondents may

provide what they perceive to be social desirable responses in relation to the subject matter and who the

results are for. Non-response bias is also a possibility especially where the response rate is quite low as

the assumption in interpreting results is that those that respond on average would not differ in their survey

responses to those that refused to take part. Accepting these issues and the limited precision of results the

survey has provided for the first time a useful crude indicator of commercial user’s awareness of their legal

responsibilities and knowledge of the LPG installation on their site. This can be used along with other

information to assess whether messaging to commercial LPG users should be increased, maintained, or

scaled back and what that messaging may usefully focus on.

This document is available from www.hse.gov.uk/gas/lpg// Page 14 of 29

5. REFERENCES

1 ICL Inquiry Report Website, Lord Gill Chairman. 16.07.09. Contains links to the inquiry report, evidence and recommendations Available from: http://www.theiclinquiry.org [Accessed 10 February 2016]

2 Health and Safety Executive LPG website. Contains links to the government response to the inquiry and information, guidanceand links to external sources of information on safe use of LPG Available from: http://www.hse.gov.uk/gas/lpg/ [Accessed 10 February 2016]

3 Lindstedt P, Lowesmith B, Taig T, Wigfull R. Report of the LPG Independent Expert Working Group 2011, 2011. Available from: http://www.hse.gov.uk/gas/lpg/working-group-report.pdf [Accessed 10 February 2016]

4 Powell S. Industry Practice Regarding the Integrity of Buried Metal LPG Pipework. 2006. Health and Safety Laboratory Report PE/05/08R 2006.

5 StataCorp. 2009. Stata Statistical Software: Release 11. College Station, TX: StataCorp LPS

6 The British Psychological Society. Code of Ethics and Conduct. Guidance published by the Ethics Committee of the British Psychological Society, 2009. http://www.bps.org.uk/sites/default/files/documents/code_of_ethics_and_conduct.pdf [Accessed 10 February 2016]

7 SPSS Inc. Released 2009. PASW Statistics for Windows, Version 18.0. Chicago: SPSS Inc

8 Health and Safety Executive. RR366 - Making an impact on SME compliance behaviour: An evaluation of the effect of intervention upon compliance with Health and Safety legislation in small and medium sized enterprises

9 UKLPG. LPG Installation Record and Documentation. User Information Sheet 025. 2011. Available from: https://www.breckland.gov.uk/sites/default/files/Uploads/environmental_health/LPG%20Installation%20Record%20and%20Documentation.pdf [Accessed 10 February 2016]

This document is available from www.hse.gov.uk/gas/lpg// Page 15 of 29

APPENDIX A: MAIN SURVEY RESULTS

The following tables provide the frequencies for each of the questions from the survey. Where

supplementary information is collected to a question the letter s is suffixed to the question number.

Q2. Do you have an LPG supply?

Have LPG supply n %

Yes 327 70

No 137 29

Don’t know 2 <1

Total 466 100

Q3. Do you have a bulk LPG storage tank on the premises?

Have LPG tank n %

Yes 319 98

No 8 2

Sub-total 327 100

Responses not provided 139

Total 466

Q4. Is the LPG supply operating at:

LPG pressure n %

Low pressure 17 5

Medium pressure 7 2

High pressure 11 4

Don’t know 284 89

Total 319 100

Q4s. Is the LPG supply operating at (verbatim responses).

Pressure types n

1 bar 2

18.6 Bar 1

3.5 bar 1

37 millibar to 1 -2 bar 1

55 psi 1

63mb 1

Cannot recall, would need to look up information 2

From high steps down to medium and then low 1

Not used in the last two years 1

Up to 80% 1

Responses not provided 307

Total 319

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Q5. Who is responsible for maintaining the LPG storage tank?

Tank maintenance n %

My company 26 8

LPG supplier 278 87

Don’t know 10 3

Other 5 2

Total 319 100

Q5s. Who is responsible for maintaining the LPG storage tank? - Other

Other responses n

3rd party company 1

Brewery 1

Independent company, not LPG supplier 1

Landlord 1

Maintenance company 1

Responses not provided 314

Total 319

Q6. Is any of the pipework between the LPG tank and appliances using LPG buried or below ground/floor level?

Location of pipe - underground n %

Yes 254 80

No 50 16

Don’t know 15 5

Total 319 100

Q7. Do any of your buildings have a basement, cellar, or under floor void?

Type of room in building, e.g., basement n %

Yes 61 23

No 198 74

Don’t know 10 4

Sub-total 269 100

Responses not required 50

Total 319

Q8. Does the LPG supply pipe work enter any basement, cellar or under floor void?

Location of pipe work e.g., in basement n %

Yes 13 18

No 43 61

Don’t know 15 21

Sub-Total 71 100

Responses not required 248

Total 319

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Q9. How old is the pipework?

Age of pipework n %

Less than 5 years old 90 33

More than 5 years old 125 46

Don’t know 54 20

Sub-Total 269 100

Responses not required 50

Total 319

Q10. What material is the LPG pipework made from?

Pipe materials n %

Metal 45 17

Plastic 94 35

Don’t know 120 45

Other 10 4

Sub-total 269 100

Responses not required 50

Total 319

Q10s. What material is the LPG pipework made from? - Other

Material - other n

As recommended by local council 1

Metal above ground, plastic below 1

Metal covered in plastic 1

Mixed 3

Mixed some plastic some steel 1

Plastic and copper 1

Plastic and steel 1

Underground is plastic 1

Sub-total 259

Responses not required 50

Total 319

Q11. Is there a plan to replace the pipework?

Plan to replace pipe n %

Yes 28 10

No 213 79

Don’t know 28 10

Sub-total 269 100

Responses not required 50

Total 319

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Q11s. Is there a plan to replace the pipework? - Other

Replacing pipework - Other information n

100%, will be moved temporarily and then moved back. 1

Alkathene to steel. 1

All been done to meet the new regulations, survey done and work done to bring up to

standard. 1

Already been done, to council requirements. 1

Barriers installed, valve installed pipework replaced and put underground. 1

Checked 2 years ago, fine for next decade. 1

Checked a few months ago. 1

Don’t know yet - will know next week. 1

HSE inspection, recommended pipework change and tree removal, had to excavate

pipework. 1

Just had it done. About 14 months ago, as weren’t meeting the regulations. 1

No, under a maintenance contract, contractor will advise. 1

Not currently, but about to undergo an overall assessment. 1

Plan to replace in the future. 1

Replaced 4 years ago. 1

Shell surveyed; no problems 1

Tested recently and pipework replaced. 1

Tested, all ok. 1

Responses not provided 302

Total 319

Q12. Who owns the LPG pipework?

Ownership of pipe owner n %

Our company 120 45

Landlord 11 4

LPG supplier 69 26

Don’t know 63 23

Other 6 2

Sub-total 269 100

Responses not required 50

Total 319

Q12s. Who owns the LPG pipework? - Other

Ownership - Other n

Mixed 1

Shared ownership, us and landlord depending on where pipes routed 1

Shared - respondent and supplier 4

Responses not provided 313

Total 319

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Q13. Who is responsible for maintaining the LPG pipework?

Responsibility for maintenance of pipe work n %

My company 96 36

LPG supplier 114 42

Don’t know 43 16

Other 16 6

Sub-total 269 100

Responses not required 50

Total 319

Q13s. Who is responsible for maintaining the LPG pipework? - Other

Responsibility for maintenance of pipe work - Other n

3rd party company 1

Landlord 3

Maintenance company 1

Management committee and landlord 1

Mixed 1

Shared - respondent and supplier 8

Shared depended on whether on site or not 1

Responses not provided 303

Total 319

Q14. Are those who undertake maintenance on the LPG pipework ‘Gas Safe’ Registered?

Gas safe registered n %

Yes 239 89

No 9 3

Don’t know 21 8

Sub-total 269 100

Responses not required 50

Total 319

Q15. Has any maintenance been carried out on the pipework in the last 5 years?

Maintenance in the past 5 years n %

Yes 144 45

No 92 29

Don’t know 33 10

Sub-total 269 84

Responses not required 50 16

Total 319 100

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Q16. What has the maintenance work involved?

Type of maintenance work n %

Regular visual checks 64 20

Excavation of all buried material 8 3

Excavation of a part of the burial pipework 12 4

Replaced the pipework 86 27

Other 18 6

Don’t know 10 3

Q16s. What has the maintenance work involved? - Other

Type of maintenance work - Other n

Certification every 3 years, regulators replaced and some pipes replaced tested to 5482. 1

Change of tank. 1

Changed location of heater. 1

Changed main pressure valve. 1

Checking for leaks, regulators. 1

Had to relocate tank. 1

Heaters moved so joints pipes checked at that stage. 1

Installation. 1

Leaks fixed. 1

Meters renewed, tank replaced. 1

Moving tree, proper barriers. 1

Pressure test. 1

Pressure test and changed a valve. 1

Regular maintenance on filters 1

Replacing valve. 1

About a year ago, done by company’s supplier. 1

Done by supplier - . 1

New switches etc. 1

New tank. 1

Pipework sent underground and other work done. HSE via supplier. 1

Pressure gauge installed. 1

Pressure tests. 1

Replacement of part of pipework. 1

Some pipework had to buried. 1

Tightening up notes on the pipe. 1

Q17. Do you have an installation record?

Have record n %

Yes 184 58

No 75 23

Don’t know 60 19

Total 319 100

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Q18. Do you know if your company has any legal responsibilities for maintaining any of the pipework?

Legal responsibilities n %

Yes 136 43

No 70 22

Don’t know 113 35

Total 319 100

Q19. How do you know that your company has these legal responsibilities?

Information source n %*

Information from the supplier 89 65

LPG trade associations (UKLPG) 2 1

Other LPG user (e.g. colleague/other business) 8 6

HSE 25 18

Local authority 9 7

Other 27 20

%basis Q18 yes - more than one response allowed

Q19s. How do you know that your company has these legal responsibilities? - Other

Knowledge around legal responsibilities n

As they own it they expect to have that responsibility. 1

Assume this is the case. 7

Both a separate company and HS advisors. 1

Common sense. 2

Consultant. 1

Fitted the pipework from the tank ourselves. 1

Head office. 1

Health and safety at work act 1974. 1

Holiday parks association. 1

HSE inspected installation. 1

Mixed responsibility. 1

My own knowledge. 1

Not sure. 8

Responses not provided 292

Total 319

Q20. Have you received any information regarding maintenance of your LPG installation including the pipework?

Receipt of information n %

Yes 148 46

No 134 42

Don’t know 37 12

Total 319 100

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Q21. Who supplied the information?

Source of information n %

HSE 27 9

LPG Supplier 117 37

LPG trade association 0 0

Don’t know 10 3

Other 4 1

Q21. Who supplied the information? - Other

Source of information - Other n %

Local authority 2 <1

Local government 1 <1

Surveyors 1 <1

Responses not provided 315 99

Total 319 100

Q22. Comments

General comments n

No longer have or use LPG or system removed. 30

System maintained by supplier. 5

Information provided by supplier. 5

Pipework inspected by HSE. 3

Respondent protects the tank by placing barriers. 1

System rigorously checked if pressure valve changed. 1

LPG used for domestic purposes only. 1

System maintained by head office or by manager. 2

Respondent pleased with service provided by supplier. 1

The service test was passed. 1

Respondent would appreciate receiving any information on LPG. 2

No issues. 10

Respondent maintains awareness of what is required for the system. 2

LPG is expensive in terms of maintenance etc. 4

Monitoring of systems should increase. 1

Would like to find ways to safeguard system. 1

The service provided by supplier could improve. 1

Total 71

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APPENDIX B: MAIN SURVEY QUESTIONNAIRE

LPG Commercial Awareness Survey

Introduction

Hello,

My name is ______________ and I am calling on behalf of the Health and Safety Laboratory, an agency of the Health

and Safety Executive. Would it be possible to speak to ______________ (if a person’s name is not listed in the

database, please ask for the person responsible for the LPG gas installation on the site).

I am calling to see if you can help with a telephone survey that the Health and Safety Laboratory, has commissioned

(name of contractor) to undertake on its behalf. The aim of the survey is to speak with commercial users of liquid

petroleum gas (LPG) to understand their levels of awareness of their legal responsibilities in regards to their LPG gas

installation and with their maintenance practices.

Is now a good time to talk?

The survey is not expected to take longer than 15 minutes of your time and mostly needs a ‘yes’ or ‘no’ answer or

provides choices from a list of alternatives that will be read out to you. We appreciate that you might have limited

time, but if you could spare us a small amount of time, we would be really grateful.” You are free to answer only

those questions with which you are most comfortable. You can withdraw from the survey at any time as well.

However, we hope that you will assist us in obtaining information in this area.

All of the information that we collect is anonymised and the responses will be collated during the analysis so that

individual responses cannot be identified. The analysis might most likely include other information held in the LPG

gas database, and these will be done only to gain a better understanding of your awareness. The information that

we collect will be used to prepare a report for the Health and Safety Executive (HSE) to improve its knowledge in this

area. This report will be placed on the HSE’s website in due course.

If you wish to speak to the person at the Health and Safety Laboratory, who can verify the legitimacy of the survey,

you can call Roxane Gervais on (detail provided) or e-mail her on (detail provided).

Are you willing to take part in this survey please? Yes / No

If yes, continue with the questions.

If no, thank the person for her/his time and end the call.

Do you have any questions before we start?

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Q1 ID Number

Q2 Do you have an LPG supply?

(choose one)

Yes

No (If No then end interview)

Don’t know (If don’t know end interview)

Q3 Do you have a bulk LPG storage tank on the premises?

(choose one)

Yes

No (If No then end interview)

Don’t know

Q4 Is the LPG supply operating at:

(choose one)

Low pressure?

Medium pressure?

High pressure?

Don’t know

Q5 Who is responsible for maintaining the LPG storage tank?

(choose one)

Our company

LPG supplier

Don’t know

Other

If other, please state

The next set of questions will focus on the LPG pipework that runs from your LPG tank/source.

This document is available from www.hse.gov.uk/gas/lpg// Page 25 of 29

Q6 Is any of the pipework between the LPG tank and appliances using LPG buried or below ground/floor level?

(choose one)

Yes

No (If No then go to Q17)

Don’t know

Q7 Do any of your buildings have a basement, cellar, or under floor void?

(choose one)

Yes

No (If No then go to Q9)

Don’t know

Q8 Does the LPG supply pipe work enter any basement, cellar or under floor void? (choose one)

Yes

No

Don’t know

Q9 How old is the pipework?

(choose one)

Less than 5 years

More than 5 years old

Don’t know

Q10 What material is the LPG pipework made from?

(choose one)

Metal

Plastic

Don’t know

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Q11 Is there a plan to replace the pipework?

(choose one)

Yes

No

Don’t know

Q12 Who owns the LPG pipework?

(choose one)

Our company

Landlord

LPG supplier

Don’t know

Other

If other, please state

The following four questions are around the maintenance of your LPG pipework.

Q13 Who is responsible for maintaining the LPG pipework?

(choose one)

Our company

LPG supplier

Don’t know

Other

If other, please state

Q14 Are those who undertake maintenance on the LPG pipework ‘Gas Safe’ Registered?

(choose one)

Yes

No

Don’t know

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Q15 Has any maintenance been carried out on the pipework in the last 5 years?

(choose one)

Yes (go to Q16)

No (go to Q17)

Don’t know

Q16 What has the maintenance work involved?

(choose all that apply)?

Regular visual checks

Excavation of all buried pipework

Excavation of a part of the buried pipework

Replaced the pipework

Other

Don’t know

If other, please state

The next set of questions will centre on the records that your company holds and your knowledge of your legal

responsibilities around LPG.

Q17 Do you have an installation record?

(choose one)

Yes

No

Don’t know

Q18 Do you know if your company has any legal responsibilities for maintaining any of the pipework?

(choose one)

Yes (go to Q19)

No (go to Q20)

Don’t know (go to Q20)

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Q19 How do you know that your company has these legal responsibilities?

(choose all that apply)

Information from the LPG supplier

LPG trade association (UKLPG)

Other LPG user

HSE

Local authority

Other

If other, please state

Q20 Have you received any information regarding maintenance of your LPG installation including the pipework?

(choose one)

Yes (go to Q21)

No (If No end interview)

Don’t know (If don’t know end interview)

Q21 Who supplied the information?

(choose all that apply)

HSE

LPG supplier

LPG trade association (UKLPG)

Don’t know

Other

If other, please state

Thank you for taking the time to answer my questions. Your assistance is greatly appreciated.

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APPENDIX C: FEASIBILITY STUDY

A feasibility study was undertaken to assess the viability of the sampling frame, identify whether a sufficient

sample could be obtained, and to assist with development of the questionnaire. The principal concern was

that the sampling frame derived from data provided back in 2006 with limited updating since would be too

old to provide sufficient interview leads

In total 20 interviews were conducted by HSE laboratory staff using 172 contacts from the sampling frame.

This provided a response rate of around 12%, and the possibility of increasing that with a better calling

strategy. A summary of phone calls is shown below.

Summary of feasibility study phone calls

Detail n

High level summary n %

1 No answers 57 Rejected (7, 8, 11)

18 10%

2 To call us or them back 30 Dead/NA/No answer (1, 4, 5, 10)

101 59%

3 Not called yet 28 Possibles (2, 9)

33 19%

4 No longer have LPG 21 Interviewed 20 12%

5 Dead/disconnected numbers 21 Total 172 100%

6 Interviewed 20

7 Rejected/declined 13

8 Told to post/email survey 4

9 Telephone engaged 3

10 Wrong number 2

11 Wanted proof of identity of researcher 1

Other key lessons taken from the feasibility study and applied to the main study

• Improved call strategy with repeat calls being undertaken at different times of the day and week.

• Reduction of the questionnaire length to reduce running time to 15 minutes.

• Improvements to questions to improve response accuracy.

• Acknowledgement that a professional telephone interviewing contractor needed to be employed to

make the survey cost effective, consistent in application, and delivered within an acceptable time

frame.