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Edward Wheeler on going unmanned

From fully unmanned trading, 24/7, 365, to selling fuel overnight when your shop is closed, there are a lot of factors to consider when planning to be able to trade unmanned.

Supermarkets have been operating unmanned in the UK for many years and have a specific advantage, normally being linked to a superstore within the same plot of land, which normally has at least 24-hour manned security on site.

The biggest hurdle to operating unmanned is industry guidance, which suggests that the operator of an unmanned filling station should be able to respond to an incident (which requires attendance), within a five-minute window. In mainland Europe, where unmanned filling stations are more prevalent, this rule/guidance, probably doesn’t exist.

The legal emphasis in the UK is on the operator of the filling station to protect the general public from hazards, including themselves. This requires a well thought-out and robust risk assessment and associated control measures to prevent any issues.

This is where there could be a disconnect between the ‘five-minute rule’ (or is it guidance?) and the site’s risk assessment and control measures. In theory, if it is possible to adequately control all the potential hazards on a filling station, without requiring manned attendance, then manned attendance should not be required.

Key questions, like what happens if there is a spill of fuel on the forecourt, via someone overfilling their tank. What happens if they spill fuel on their clothes, how do you help them etc. These questions need to be addressed in the risk assessment.

Another hurdle to operating unmanned is how to ensure legal compliance in terms of licensing factors such as not selling petrol to underage people or people trying to fill illegal containers, like plastic water bottles or even plastic bags!

This is where it gets complicated and frustrating as the ‘rules’ have to be met, despite the risk being incredibly low. In terms of frequency, a risk assessment could probably ignore the ‘hazard’ of selling fuel to underage people, however the law is the law so the requirement needs to be met.

The reality is that there is no 100% way of preventing the sale of petrol to people underage. A determined person could obtain a fake ID, even if you wanted to go to the lengths of checking it.

It would be reasonable to assume that if a person drives on to a forecourt and uses a bank or credit card to authorise a pump via an outdoor payment terminal, that they are not underage. The odds therefore of there being an issue for an operator must be 100,000s or millions to one.

Currently, it appears that the main requirement (the one the regulators care most about) for operating unmanned, is the prevention of the sale of fuel to persons using non-approved containers. With recent world events, causing fuel shortages and panic buying, it would be difficult to argue that the general public don’t try and fill non-approved containers with fuel.

In an ideal world, it should be possible for every single fuel transaction to be remotely ‘authorised’ by someone in a CCTV monitoring station, like it is in the Republic of Ireland, for example. However, this is not always commercially viable as it comes with a significant cost. Therefore, the ‘industry’ in the UK accepts that diesel transactions don’t require remote authorisation and, as long as there is a vehicle present, petrol transactions can go through without authorisation as well.

However, if margins continue to hold at the levels seen recently, pre-authorising every transaction could be commercially viable.

At this point, it is a good time to state that fuel retailers should engage with their local licensing authority on what their requirements actually are. The Petrol Retailers Association can provide retailers with all the help and guidance they need to go unmanned as well and they would be my first port of call if I were a fuel retailer.

This checklist highlights the key things a fuel retailer will need to go unmanned:

- Detailed risk assessment/control measures

- Outdoor payment terminal (ideally linked to POS if a shop is present)

- CCTV, with remote monitoring station

- Ability to kill the power to the site remotely in the event of an emergency

- A person able to respond to visit the site as quickly as your risk assessment requires, but five minutes is the target

There are ways of limiting the need to send a person to site, which should also be considered at the beginning of the journey to unmanned operating. Having adequate drainage channels around the pumps to catch any vehicle tank overfills and the ability to show the site as being ‘CLOSED’ at the pole sign, are good control measures to prevent the need to get someone to site urgently, for example.

There is a lot to consider. Please contact me for any advice you may require and we can help you create a robust unmanned operation that can improve your business.

As labour costs rise and volumes decline, along with shop sales, going unmanned, even just overnight, could help to keep critical infrastructure going and replace lost volume with volume gains from 24 hour trading.

This must be something for all fuel retailers to start exploring…

Published date:
April 22, 2022
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