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Aviation refuellers and regional airports

Aviation businesses and operators of regional airports must safely store, handle and use aviation fuel.

Flammable liquids fuel our transport sector and includes commercial forms of petrol and diesel for land transport and fuels such as Jet A-1 and Avgas for the aviation sector.

Operators of aviation fuel businesses range from top tier operators (with the support of their global aviation fuel policies and procedures), to recreational aviation clubs (with substantially less resources to support their operations).

The following is an overview of safety duties that apply to the safe storage, handling and use of aviation fuel with the focus on work health and safety (WHS) laws. It provides a range of standards available to assist duty-holders manage their fuel storage and handling risks at regional airports.

Aviation fuels are made to tightly controlled specifications and consist primarily of hydrocarbon compounds (paraffins, cycloparaffins or naphthenes, aromatics, and olefins) and contain additives determined by the specific uses of the fuel. By their nature, aviation fuels are flammable and give rise to fire and explosion risks.

Below are examples of flammability hazards described in a manufacturer’s safety data sheet (SDS):

Properties*

Jet A-1 (Kerosene)

Unleaded Avgas

Flash point

>38oC

< (-) 40oC

Boiling point

140-280oC

40-170oC

Flammable range

0.6 – 6 %

1.4 – 7.6 %

Auto-ignition temperature

207-250oC

280-470oC

Vapour pressure

15 mmHg @ 38oC

285- 367 mmHg @ 38oC

* Values are illustrative only- always refer to the product’s SDS for the specific chemical and physical property information of the product being used, stored or handled.

Hydrocarbons can affect the nervous system, causing headache, dizziness, and lack of coordination. Chemicals may also cause chronic health problems, such as liver and kidney damage. Aviation fuels have an Australian Exposure standard that must not be exceeded. This may include a time weighted average and short-term exposure limit. For further information refer to the product SDS and the workplace exposure standards for airborne contaminants published by Safe Work Australia.

WHS laws apply to the aviation refuelling installations (above ground and underground fuel storage and dispensing systems) unless subject to any exclusions such as being on land under the jurisdiction of Commonwealth health and safety laws. Therefore, subject to any exclusions or exemptions, regional airports, whether owned and operated by local authorities or private entities, are subject to the requirements listed below.

While the WHS Act covers health and safety duties for substances, plant and structures, the Work Health and Safety Regulation 2011 (WHS Regulation) has specific safety obligations for hazardous chemicals such as aviation fuel.

WHS Act

Specific duties apply to those who design, manufacture, import, supply, install, construct or commission plant or structures associated with aviation fuel.

Duties include:

  • carrying out calculations, analysis, testing or examination that may be necessary for the performance of the duty imposed
  • giving adequate information to each person who is provided with the design
  • results of any calculations, analysis, testing or examination, including, any hazardous properties of the substance identified by testing
  • applying conditions necessary to ensure the plant or structure is without risks to health and safety when used.

Refer to sections 20–26A for specific details for these duties.

Note: Where there are no prescriptive standards to follow in designing an installation, professional engineering services are required to be performed by, or under the supervision/sign off of, a Registered Practicing Engineer Queensland (RPEQ) with appropriate expertise in the relevant discipline.

WHS Regulation

Aviation fuel in its various forms is defined as a hazardous chemical under the WHS Regulation because it meets the criteria for a flammable liquid under the Globally Harmonised System for classification and labelling of chemicals (GHS). Meeting the GHS for a flammable liquid triggers the application of Part 7.1 - Hazardous chemicals requirements to aviation fuels and their storage and handling systems.

Fuel classification under the WHS Regulation

Aviation fuel is classified as a hazardous chemical as are petrol and diesel based on their flash point and boiling point assessed against the flammability criteria in the GHS. Refer to the GHS flammable liquid categories, criteria and examples at flammable and combustible liquids.

Note: Always check the hazardous chemical classification and hazard information in the manufacturer’s SDS.

Under the WHS Regulation, the quantity of aviation fuel to be used, stored, or handled will determine the applicable duties applied. For example:

  • a storage and handling system with a water capacity exceeding 250 or 1000 litres (depending on its GHS classification from the SDS) will trigger placarding (e.g. drum store)
  • storage and handling systems with an aggregate water capacity exceeding 2,500 or 10,000 litres (depending on its GHS classification from the SDS) will be a manifest quantity and trigger additional duties as a manifest quantity workplace
  • storing above 50,000 tonnes (equivalent to about 60,000,000 litres of Jet A1 depending on its relative density from the SDS) will trigger a major hazard facility licence requirement (Schedule 15, Table 15.2, Item 3 liquids that meet the criteria for class 3 packing group II or III)
  • storing above 5,000 tonnes (equivalent to about 6,000,000 litres of Jet A1 depending on its relative density from the SDS) will require notification to Workplace Health and Safety Queensland (WHSQ) and assessment as a possible major hazard facility (i.e., greater than 10 per cent of the prescribed MHF quantity in Schedule 15).

Safety duties

Any quantity of aviation fuel will be subject to Part 7.1 - Hazardous chemical requirements under the WHS Regulation. This includes obligations for importers and manufacturers of aviation fuel requiring hazard classification under the GHS, correct packing in containers, labelling and provision of a SDS. There are obligations for suppliers of aviation fuel and those conducting a business or undertaking (PCBU) storing, handling and using aviation fuel.

Safety obligations for a PCBU under Part 7.1 - Hazardous chemicals include:

  • labelling of containers and pipework and safety signage
  • providing access to SDS and inclusion in a hazardous chemicals register
  • manage risks to health and safety including review of control measures
  • identification of physical or chemical reactions
  • fire and explosion prevention including hazardous areas classification and management
  • fire protection and firefighting equipment
  • safety and emergency equipment
  • emergency plans
  • control of risks from storage and handling systems (e.g. cylinders, tanks, pressure vessels and associated pipework and fittings)
  • where applicable, provision of a manifest, and notification to WHSQ as a manifest quantity workplace or possible major hazard facility and submission of the emergency plan to Queensland Fire and Emergency Services (QFES) for review (applies to MQW and MHF as detailed below).

Fuel systems and hazardous areas

A hazardous area is a three-dimensional space in which an explosive atmosphere is or may be expected to be present or be generated. As a flammable product, aviation fuel can generate hazardous areas. Operators of facilities storing or using it must take precautions to manage the risks to ensure the health and safety of workers and the community. It is important a hazardous area classification is undertaken by a competent person to inform fire and explosion prevention measures for fuel installations. A classification will include the applicable hazardous zones as determined under the AS60079 series. Both WHSQ and the Electrical Safety Office (ESO) have regulatory oversight. Refer to Electrical safety laws below for further information on electrical equipment in hazardous areas.

Training

While there are no specific aviation sector training requirements referred to under WHS laws, there are general duties to provide information, training and instruction (WHS Regulation section 39) to a worker that is suitable and adequate having regard to the:

  • nature of the work carried out by the worker (e.g. filling storage tanks, conducting maintenance activities, or emergency response actions)
  • nature of the risks associated with the work, (e.g. leaks, spills and fires)
  • control measures implemented (e.g. spill containment, fire protection, earthing and bonding, and hazardous area management and safe work procedures).

Section 379 WHS Regulation requires necessary supervision to protect the worker from risks in relation to hazardous chemicals. A competent person is defined as a person who has acquired through training, qualifications or experience the knowledge and skills to carry out the task. Specialist aviation advice may be required to conduct suitable training and related activities. Suitably qualified parties with airport fuel operations experience from major airport fuel operations, or Joint Inspection Group (JIG) or International Air Transport Association (IATA) auditors may be available to assist.

Airports as manifest quantity workplaces

A manifest quantity workplace (MQW) stores, handles or uses hazardous chemical quantities that exceed or likely exceed the prescribed quantities in the regulation. The prescribed quantity will be dependant on the product and its GHS classification sourced from the product’s SDS. For example, Jet A-1, having a GHS hazard category of flammable liquid, category 3 has a prescribed manifest quantity of 10,000 L. A placard is required for exceeding 1000 L of Jet A-1 in a package store or bulk tank.

MQW obligations include:

  • preparing a manifest (includes a site plan) for use by emergency services
  • notifying WHSQ of certain information. Form 73- Notification of a manifest quantity workplace (PDF, 2.5 MB) is used to notify WHSQ of an MQW
  • providing a copy of the emergency plan to Queensland Fire and Emergency Services for review.

The WHS Act requires duty holders to consult, cooperate and coordinate activities with others who have a duty in relation to the same matter; and to consult with workers who carry out work for the business or undertaking. A landlord or managing agent should consult, cooperate and coordinate activities with commercial tenants (e.g. about emergency plans and procedures, or with a contractor carrying out maintenance or repair work). View the Work health and safety consultation, co-operation and co-ordination Code of Practice 2021 (PDF, 0.54 MB) for more information.

Landlords and managing agents that own or manage fuel storage and handling equipment that are used by workplaces must also understand the extent of their management or control under section 21 of the WHS Act.

At larger regional airports, there may be multiple aviation fuel suppliers with their own fuel installations. In such cases, there will be a need for the airport operator and fuel suppliers to consult with each other specifically on establishment of fit-for-purpose emergency plans (e.g. integrated emergency management systems) to facilitate effective emergency response and resources.

Each entity is required to have their own emergency plan (WHS Regulation section 43). The operator with overall management responsibility for the regional airport will require an overarching plan to address the multiple duty-holders detailing the site arrangements for emergency ingress and egress, security arrangements, firefighting, and spill management resources. The overarching emergency plan must ensure an integrated approach is taken to address any emergencies that may eventuate across the site.

There are specific requirements for electrical equipment in a hazardous area under the electrical safety laws including that such electrical equipment must be IECEx certified. The equipment must be suitably rated and effectively earthed in line with Australian Standards. Ignition risks must be adequately controlled. An accredited auditor must inspect electrical installations in hazardous areas prior to connection or reconnection. The Electrical Safety Office regulates accredited auditors for hazardous areas.

It is important that a hazardous area classification is undertaken by a competent person to inform fire and explosion prevention measures for fuel installations. A classification will include the applicable hazardous zones as determined under the AS60079 series and a dossier detailing electrical equipment and their specifications for such an area.

A workplace self-assessment tool (DOCX, 0.36 MB) is available to assist PCBUs assess and manage the fire and explosion risks for electrical installations in hazardous areas. If you are unsure whether the above requirements have been complied with, it is possible the suitability of electrical equipment installed in these areas was not assessed at the time of initial installation. In such instances, a review of existing electrical equipment is required to ensure it is compliant with any new hazardous area classification and complies with Section 7.7 of AS/NZS 3000 (the Wiring Rules). For further information visit: Developing an electrical installation improvement plan for a new hazardous area.

Civil Aviation Safety Authority

The Civil Aviation Safety Authority (CASA) regulates the safety of civil air operations in Australia. CASA laws establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents. This includes fuel quality for operation of an aircraft as described below. Further information on CASA requirements is available at Civil Aviation Safety Authority (casa.gov.au).

Fuel quality considerations

Aviation fuels are made to tightly controlled specifications which must be maintained throughout the storage and handling processes to support the safe operation of aircraft. The most common contaminants are particulates, water, petroleum products (or their residues), and microbial growth. Division 91.D.6 of the Civil Aviation Safety Regulations 1998 sets out standards for ensuring the safety of fuelling operations. CASA has issued an advisory circular (AC 91-25 – Fuel and oil safety) on how to comply with these standards.

While WHS laws do not specifically address the fuel quality, ensuring that the relevant WHS Regulations and supporting codes and standards are being met will contribute to the maintenance of fuel quality. For example, ensuring the integrity of underground fuel tanks to prevent ingress of water that causes fuel contamination and reduces its quality.

Guidance is available from the Joint Inspection Group (JIG) for aviation fuel supply standards covering the entire supply chain for aviation fuels from refinery to wing-tip. When referring to standards, codes or guides, ensure you have obtained the latest version and any amendments.

Example standards include:

  • JIG 1 Standard: Aviation fuel quality controls and operating standards for into-plane fuelling services
  • JIG 2 Standard: Aviation fuel quality controls and operating standards for airport depots and hydrants
  • JIG 3 Standard: Aviation fuel quality control and operating standards for smaller airports.
  • EI/JIG 1530 Quality Assurance Requirements for the Manufacture, Storage & Distribution of Aviation Fuels to Airports.

Queensland Transport

The transport of aviation fuel on public roads is regulated by the Queensland Transport Operations (Road Use Management) Act 1995 and the Transport Operations (Road Use Management- Dangerous Goods) Regulation 2018, administered by the Queensland Department of Transport and Main Roads. The transport regulations refer to the Australian Dangerous Goods Code and covers dangerous goods vehicle and driver licensing.

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Last updated 14 September 2023