Jay Johnston
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Often in life we are told it is better to own. However, that is not always the case.
Somehow we tend to lose track of things we own, loan to others, assume under forgotten promises or own by virtue of default.
With these thoughts in mind, who owns the lines and second-stage regulators at your customer locations? Who is responsible
for protecting them?
Before you answer, think about ways your customer installations differ. Did you install the line and add the second-stage
regulator, and if so did you charge the customer for the equipment? Did you take the account over and hook up to an existing
line and second-stage regulator? When you lose a customer, do you pick up your tank, line and second-stage regulator as well?
This relates to your safety program and potential liabilities in a number of ways. First, whoever owns the line and second-stage
regulator is responsible for maintenance and protection from the elements. This begs the questions: Is the line deep enough,
located in the appropriate place, mapped and marked, and are all parties aware? Is the regulator properly installed and protected
from the elements?
I recommend you do not own the line or the second-stage regulator and you sell such owned equipment to the customer at a minimal
charge. This may involve communication about the change of ownership of equipment, some form of compensation (i.e. $1) and
acknowledgment that equipment ownership is being transferred as is.
Customer education and communication about protecting lines from digging and regulators from the elements can be a key factor
in accident prevention.
NFPA states that whomever installs or owns the equipment is responsible for making sure it is protected.
Sometimes it can be as simple as making sure the regulator is installed properly with the vent pointed down and high enough
on the wall to be protected by the eves from the elements. Another way would be to consider or recommend the purchase of a
plastic protector to cover the regulator. Such efforts would be perceived as reasonable attempts to protect and properly install
the equipment. I recommend this be done prior to transferring ownership of equipment.
Another consideration in protecting equipment would be securing all equipment when disconnecting a customer system. Unused
gas piping must be capped or plugged as required by NFPA 54.
If you remove a propane container, it is advisable to cap or plug the supply pipe that remains at the consumer location. If
the piping is disconnected from the regulator, it is advisable that it should be plugged or capped as well.
This may also be a good time to make sure concerns about equipment ownership and regulator protection have been documented.
If you fail to document your efforts to secure equipment and promote safety, those efforts could be challenged at a later
date.
With spring at hand and the busy season winding down, it is a good time to put your efforts toward securing as many Gas System
Checks as possible. I recommend you add inspection-of-equipment security to your Gas System Check process.
Bobtail drivers may not be trained to inspect regulators and piping. I would limit their inspections to the container being
filled. The bobtail driver is trained to the code under the liquid transfer section. Some marketers may not want the driver
to inspect any portion of the system that they are not trained to do. This would be assigned to the service technician or
the Gas Check inspector.
At your next safety meeting, recommend service techs inspect and make note of equipment installation issues such as regulator
installation and protection, unprotected old steel lines underground, tank distance from buildings and other pertinent Gas
System Check information.
Don't miss this great opportunity to communicate with your customers about equipment ownership, security and protection from
the elements. It's the safety way to do business.
Jay Johnston ( http://www.thesafetyleader.com/) is an insurance agent, business insurance coach and consultant; safety writer and inspirational speaker. Jay can be reached
at Jay@thesafetyleader.com
or 952-935-5350.
