Bulk fuel management
If you are a Z customer that stores bulk fuel on your sites, then we both have legal obligations to ensure that fuel is managed safely. It's also really important to us that we do everything we can to ensure the safety of people who deliver and use our fuels and that we are protecting New Zealand's natural environment.
Download the Z Guide to Bulk Fuel Management (PDF 667KB)
Disclaimer: This guide was updated in February 2022. This document is not, and is not intended to form, legal advice on your obligations or to be relied on to that effect. It is simply a guide to help you get started. You need to ensure you stay connected with your obligations under the Health and Safety at Work Act, Hazardous Substances and New Organisms Act, the Health and Safety at Work (Hazardous Substances) Regulations, WorkSafe codes of practice and guidelines and any other legislation or directions that might apply to you.
What are Z's responsibilities?
Z needs to be sure that any tanks we deliver fuel into, regardless of whether those tanks belong to you or Z, have the following in order:
- the right certification
- a fuel reconciliation is done regularly
- we provide correct information about our fuel products.
What are your responsibilities?
- complete bulk stock reconciliations
- be familiar with Z's safety data sheets
- have HSNO certifications and use an approved HSNO Certifier
- have operating requirements for above and below ground fuel storage
- ensure you have a stormwater management plan and an emergency response plan.
Each of your locations that have bulk fuel tanks need to ensure they are compliant with their responsibilities. You may also have a fuel supply agreement in place with Z, which will set out additional requirements that you should consider regarding the safe management of fuel. It is critical to us that we are delivering fuel to sites that are compliant with all relevant legal obligations. As such, if you aren't compliant then we reserve the right not to supply you with fuel.
For further detail and information for each area of your responsibilities, please look at the sections below.
Bulk stock reconciliations
The requirement to complete fuel reconciliations arises under the Hazardous Substances and New Organisms Act 1996 (HSNO). It is also common for councils to stipulate in resource consents that you follow best practice with respect to fuel reconciliations. Please refer to the Management of Pre 2006 Stationary Container Systems up to 60,000 litres document and HSNOCOP 45 for full details.
Both the above document and code require every storage site operator to monitor for product leakage by establishing and operating a sound system of stock reconciliation that identifies stock losses as they occur. Compliance with HSNOCOP 45 is important to ensure early detection of any product leaks. The code explains:
- how to account for stock
- how to carry out a pump meter/tank dip reconciliation, and
- how to compete a reconciliation summary.
Z is committed to ensuring it only delivers to fuel sites that are fully compliant with the legislation. As such, to ensure you are compliant with your obligations, Z requires you to:
- obtain resource consents, approvals and test certificates for the handling, use and storage of hazardous substances on the premises
- comply with the conditions of any resource consents/approvals
- have available the required HSNO Hazardous Location Test Certificates and Stationary Tank Certificate and provide Z with copies of such certificates
- notify the appropriate authorities of any incident involving hazardous substances resulting in serious harm to any person or the environment
- comply with any other legal requirements regarding the management of hazardous substances at your premises
- refrain from discharging contaminants into the environment
- carry out stock reconciliations, in line with requirements, for underground tanks and above ground tanks with underground pipe work
- keep records of all stock reconciliations
- notify Z within 24 hours if your reconciliation indicates a sudden loss of product or the trend shows losses or gains that are consistently more than 0.5%.
Compliance with these requirements is essential for the safe management of fuel. The penalties for not complying with the above requirements can include imprisonment and large fines.
Safety data sheets
Those coming into contact with, or using, fuel products must have access to information about those products. You need to send a copy of your most recent fuel reconciliation to Envirohaz at email@example.com at least 4 months before your tank’s HSNO certificate expires. This will ensure your reconciliations are correct when the tank is recertified.
Business operators must provide users of a hazardous product, including fuel products, access to a safety data sheet within 10 minutes. You can check out Z's safety data sheets here.
HSNO certifications and use of an approved HSNO Certifier
Certifications of certain equipment are required under the Hazardous Substances and New Organisms Act 1996 (HSNO) legislation. Certifications are carried out by independent test certifiers.
There are two main pieces of legislation that cover hazardous substances:
- The Hazardous Substances and New Organisms Act 1996 (HSNO)
- The Health and Safety at Work (Hazardous Substances) Regulations
The regulations apply to post 2006 bulk fuel storage systems. Pre 2006 systems have a Safe Work instrument that changes some requirements. We recommend you note in particular the section covering management of pre 2006 stationary container systems up to 60,000 litres.
If Z owns equipment on your site then using our HSNO Test Certifiers, Z will certify the equipment under HSNO and ensure it has the appropriate Stationary Tank Certificate.
If you own the equipment, you will need to arrange for it to be certified under the HSNO requirements. The WorkSafe NZ website includes a list of registered HSNO Certifiers.
If you store petrol you are responsible for ensuring your site has the appropriate Hazardous Location Test Certificate. A HSNO Test Certifier will be able to advise you on this requirement.
The circumstances where certification is required are as follows:
- any below ground petroleum or diesel stationary tank with a capacity of more than 250 litres
- any above ground diesel stationary tank with a capacity of more than 5,000 litres
- any above ground petrol stationary tank with a capacity of more than 2,500 litres
- any above or below ground LPG stationary tank with a capacity of more than 100kg
- the storage and use of more than 50 litres of petroleum on the premises and
- the storage and use of more than 100kg of LPG on the premises
Regardless of who is responsible for the certificate, a copy should be available on site. If you wish to obtain a Stationary Tank Certificate for any Z owned equipment on your site, please contact Envirohaz: firstname.lastname@example.org.
You may also be required to obtain an Approved Handler Certificate. Approved handler certification qualifies people to handle very hazardous substances safely and to provide guidance and assistance to other people handling the substances. We recommend you consult with a HSNO Certifier or check the WorkSafe NZ website to see whether this is required.
Even if you're not sure who owns a tank or tanks on your site, it still needs certification. Please contact your Z Customer Manager or our Customer Service Centre if you have questions about tank ownership, and together we can determine the appropriate actions to take to ensure the appropriate certification is obtained as soon as possible.
If you make any modifications to your own fuel storage equipment, or to the product stored in the tank, please notify your HSNO Test Certifier. The change could negate the validity of your HSNO certification and a new certificate may be required.
Operating requirements for above and below ground fuel storage
Worksafe NZ has developed Codes of Practice for the storage of hazardous products. Codes of Practice relevant to the storage of fuel products are as follows:
- Management of Pre 2006 Stationary Container Systems up to 60,000 litres
- HSNOCOP 44 - Below ground existing stationary systems for petroleum - design and installation
- HSNOCOP 45 - Below ground stationary container systems for petroleum - operations
- HSNOCOP 47 - Secondary containment systems.
These Codes of Practice should be consulted to ensure all requirements for the design and installation of new storage systems are covered, and that the operation of these new and existing systems meet all requirements. Requirements for below ground stationary container systems are detailed in the "Management of Pre 2006 Stationary Container Systems up to 60,000 litres" document but the daily management of them may be undertaken in accordance with the provisions of HSNOCOP 45.
We recommend you regularly review the Worksafe NZ website for developments.
Burners linked to Fuel Storage Equipment
If you have a burner connected to our fuel storage equipment or yours, we recommend you check that the burner is on the WorkSafe register. See the WorkSafe Burner Register for a list of approved burners. If your burner is not on WorkSafe’s register, contact your WorkSafe approved Test Certifier or WorkSafe directly for advice about how register your burner. You can apply for a burner approval using this Worksafe form.
For more information about burners, see Worksafe Burner Regulations Subpart 11- Installations for burning class 3.1 substance or substance approved by EPA for details of what is required.
Stormwater management and emergency response plans
Under the Resource Management Act 1991 (RMA) you're responsible for any spills on your site. We strongly recommend that you review and have an up to date Stormwater Management Plan.
In addition, a site specific Emergency Response Plan is required for all locations, detailing the response to all likely emergency scenarios. All facets of the Emergency Response Plan must be tested regularly, with the results of the tests to be recorded, identified improvement actions acted upon, and the Emergency Response Plan updated.
The link to the Hazardous Substance toolbox has useful information regarding safely managing hazardous substances on your site as well as checklists and templates such as an emergency response plan.
Further help and advice
If you're in any doubt as to your obligations when managing fuel products, we recommend that you obtain professional advice from a HSNO Test Certifier as soon as possible. If you have any questions or concerns about bulk fuel storage, contact your Z Customer Manager or our Customer Service Centre and they'll help you out.