From 2020 Chemsafety has been examining in detail the evidence available for the fire ratings of flammable gas and liquids stores. This is to provide assurance to both the client and Chemsafety that the regulations are being met and the hazard appropriately controlled.
We have been finding that a number of sites have had information regarding fire ratings taken from earlier certifications, sometimes dating back to pre-HSNO days. While the terminology around stores was similar under the old Dangerous Goods Regulations, the performance specifications are not the same as the HSNO Regulations and the current Health and Safety at Work (Hazardous Substances) Regulations.
In the case of class 4 and class 5 substances the construction thickness of concrete walls can be used to ‘deem’ a fire rating. In the past this information has been used to make informed assumptions for class 2 and 3 substances, however it is not an approach permitted in the regulations for these substances
This presents a potential liability for both the PCBU and certifier if robust evidence of compliance with the current regulations is not available.
Additionally, particularly in relation to LPG, where a fire rated intervening wall is required, it is not sufficient that a fire rated material is used, it must be installed in such a way as the completed construction is fire rated. Hence we require evidence, such as a producer statement, that the installation has been done in accordance with the manufacturer’s requirements to achieve the stated fire rating.
During the preparation for your renewal, or while on site for a new inspection we will look at the evidence that we have available. If sufficient evidence is not on file we will ask you for this. Evidence may include
We understand that it can be frustrating that there is an apparent change in the compliance requirements, but hope that you appreciate the efforts we are making regarding continuous improvement in hazardous substances management, and that this process will leave you in a stronger position with your compliance and liability risk.