To: Head of Fire Departments
From: Stephen D. Coan, State Fire Marshal
Date: April 1, 2002
Re: Self-Service Gasoline Stations with Propane Cylinder Exchange

Effective April 1, 2002 NFPA 58-1998, Section 2-3.1.5, as referenced by 527 CMR 6.07: (1), requires LP-Gas cylinders be equipped with an overfill prevention device. This new requirement has resulted in an increased number of permit requests from propane cylinder exchange vendors to set up cylinder exchange facilities at some self-serve gasoline stations.

Fire departments should be aware of the minimum staffing levels at these service stations prior to granting a propane storage permit for a cylinder exchange operation. Particular attention should be given to 527 CMR 5.08: (5)(d) which states that the controlling mechanism console providing power to the pump motor is in constant attendance by the owner or operator at all times while motor fuel is being dispensed. Constant attendance means that the console operator must be at the console during its operation. Section 5.08: (5)(e) goes on to require constant contact between the controlling mechanism console operator and the pump island as well as constant observation of the filling operation of each vehicle during the time that any of the pumps have been activated to dispense motor fuel. Unrelated business shall be operated by others [5.08: (5)(f)].

The proper exchange of propane cylinders at a self-service fuel facility requires the station attendant to exit the building (i.e. self-serve console area), proceed to the secured propane cylinder storage cage, unlock the cage, exchange the empty propane cylinder for a full one, lock the cage, and return to the self-serve console area. It is not possible to operate both the propane cylinder exchange and fuel dispensing and remain in compliance with the regulations of 527 CMR 5.08: (5) with only one person on duty. Someone must conduct this activity other than the self-service console operator. One condition that should be considered in order to allow propane cylinder exchanges at a self-serve fuel facility is the requirement that more then one attendant is on duty at all times. This should be a condition of any permit issued to allow for propane cylinder exchange at a self-service fueling facility.

If you have any questions, please feel free to contact the Code Compliance and Enforcement Unit at 978-567-3300 or at our Western MA office at 413-587-3181.