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SAFE+CONNECT PROJECT

LPG leisure cylinder safety review: incidents, cylinder valves, regulations, operational impacts and conclusions August 2017

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Executive Summary Gas Energy Australia (GEA) members in particular, and the LPG industry more broadly, regards the safety of its customers and the community as paramount and works continuously to improve the safety of its products. Reflecting this, early in 2016, GEA established technical and commercial working groups to undertake the Safe+Connect Project to review LPG leisure cylinder safety. This report outlines the main findings of this GEA Review. GEA members and the State and Territory Gas Technical Regulators Committee (GTRC) have for some time been concerned about incidents involving portable gas cylinder (often called LPG leisure cylinders) and their connection to portable appliances. In January 2017, the GTRC advised it was especially concerned about recent incidents involving the ignition of leaked LPG during transport and storage, resulting in personal injury and property damage. In particular, GEA was advised that “GTRC members are of the view that there already is sufficient incident data to justify a review of the current Type 21 POL cylinder valve and to explore alternative options that may produce a safer outcome for consumers. Assisted by incident data collected by GEA members & EnergySafe Vic (ESV), the GEA Review concluded that where the cause of an incident had been identified, the majority were related in some way to the cylinder valve. As well as analysing incident data, the Review assessed the capability of seven alternatives to the current Type 21 valve to reduce the likelihood of leakages when a leisure cylinder is in transit, storage or use. Table 3 and chart 1 (on pages 10 and 11 respectively) provide information on the relative potential safety improvements offered by the alternative valves considered in the study. The Review illustrated that alternatives valves exist that would improve safety outcomes (some valves potentially eliminating up to 50 per cent of incidents), but it would come at a material cost to industry, and ultimately the consumer. GEA’s working groups’ view is change is justified and recommended. LPG leisure cylinder valve options The GEA Review has considered the following seven alternative valves:

1. maintain the current Type 21 threaded connection with a gas tight plug for transport

2. revert to brass connections for appliances and retain the current Type 21 specification

3. add a back-check valve to the Type 21 connection specification

4. revert to brass connections for appliances with a back-check valve included in the Type 21

specification

5. adopt the Quick Connect Coupling which has an external ACME/internal Type 21 (QCC)

6. introduce a modified QCC (external ACME thread only, with no internal Type 21 thread) connection

7. adopt a Kosan connection

The Review concluded the following.

• Maintaining the Type 21 with a gas tight plug would only address initial transport issues. Once the first

connection has been made, any subsequent re-application of the plug would be at the discretion of the

consumer. As such, a gas tight plug was not considered an option to address transit, storage, and

connection related issues. Therefore, it is not recommended. It is also important to note that application

of a gas tight plug (required by regulation in Qld) would defeat the check valve if applied with a back

check, QCC or modified QCC valve.

• The brass only connection would force consumers to use a spanner to achieve a gas tight seal after

being used to a hand wheel and soft seat seal. This change would be likely met with a level of consumer

confusion and not address transit and storage issues. Therefore, this option is not recommended.

• The use of a Type 21 valve with back-check would eliminate transit and storage issues. However, the

back-check valve has been shown to damage the rubber components (o-rings and soft bull nose) of

male (appliance) connections thus increasing the rate of connection issues. Therefore, this option

requires other pre-requisites (changes to the male (appliance) connection) to be met before this option

can be considered.

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• The combination of a back-check valve with brass fittings, while addressing transit and storage issues,

would likely meet with consumer confusion and a potential increase in connection as a spanner would

be required for gas tightness and thus is not recommended.

• The QCC and the modified QCC valve connection both score well in eliminating transport and storage

incidents. The QCC appliance hose offers a safer, more user-friendly connection experience being a

right-hand thread with inbuilt design features that prevent excess flow and provide thermal shut off.

However, both have implementation issues:

o Depending on the design of the back-check, some QCC valves and the Type 21 POL valve

fitted with a back-check may damage poor quality or aged rubber seals on the male POL

(appliance) fitting, thus introducing a potential new source of safety incidents.

o A modified QCC valve cannot be connected to old appliances with a male POL fitting.

Therefore, industry would need to match the changeover to the average life of LPG appliances

to avoid some consumers giving up on LPG, or seeking out cylinder valve adaptors, creating

risk of additional safety incidents. Also, fixed use installations such as dwellings and caravans,

would require their pigtails changed over. This could again lead to consumers giving up on

LPG or using undesirable adaptors.

o There is no recognition of the QCC or modified QCC as a valve approved for use within the

current Australian Standard. However, the QCC does have an International specification (UL

1769). Australian Standard AS2473.2 - Valves for compressed gas cylinders, lists gases and

their assigned outlet connections, and assigns a Type 20 (used for small camping cylinders)

and Type 21 to be used for propane gas.

o The modified QCC valve is not in commercial production, however specifications do exist for

the valve. Feedback received from manufacturers is that production would not prove difficult,

as they would simply “leave out a step” in the manufacturing process. (ie don’t machine the

Type 21 thread, leaving the internal bore of the valve smooth). This modified QCC valve is not

compatible with the current Type 21 connectors in use, so customers requiring a POL valved

LPG cylinder (compatible with Type 21 connectors) would select that cylinder at point of

purchase.

• The Kosan valve scored highest in eliminating incidents. It is a low-cost valve that is simple in both its

arrangement and connection method. This valve would also permit industry to change to automated

filling. While these positives make it a strong contender as a replacement valve, it comes with

implementation issues and question marks over additional risks that could be introduced into the market

place, including:

o Kosan valves lack a fixed ullage/liquid level gauge and as such cannot be decant filled which

could have competition law implications;

o leaks could not be isolated since it does not have an isolation valve;

o dust ingress into the valve and an exposed valve face could be an issue in harsh Australian

conditions; and

o the valve has a significantly slower fill rate than the other valves.

For these reasons, the Kosan could not be supported without further engineering studies and

investigation of possible technical modifications.

• Both GEA working groups recognise that with further time and engineering input, the safety issues

identified with the above valves assessed could be resolved. However, engineering modifications of

any of these valve types could introduce new and previously unidentified issues. Therefore, each

modified valve type would require a reassessment of its safety performance. Consequently, this report

is based upon the valve types on hand at the time of publication, and the expected performance in the

current marketplace.

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Key conclusions The GEA Review also examined the regulations applying to LPG cylinders and appliances. It concluded that a project to work with Standards Australia to make a significant change to the Type 21 connection would require substantial resources given the complexity of the project and the number of Standards involved. It is estimated these changes would most likely take at least two years to implement. Nevertheless, such a process would be preferable to individual jurisdictions within Australia making separate changes to their regulations, possibly resulting in different cylinder valves being mandated in different States and Territories. Given the extent to which LPG cylinders move between Australian jurisdictions, such differences would encourage the use of adaptors which would increase the risk of additional safety incidents. While all alternative valves have positive attributes and risks to varying degrees, on balance, the working groups concluded that a valve change with the following attributes offers the greatest prospect for the safer use of leisure LPG cylinders by consumers:

a. a consumer friendly, easy to make gas tight connection to the appliance;

b. limited mechanical force required to achieve a gas tight seal;

c. elimination of misalignment during connection;

d. a positive connection needs to be made to the appliance fitting before gas can flow;

e. meets consumers’ expectations of being able to achieve a gas tight seal without using tools and

includes a valve which provides a ready means of isolating gas flow;

f. a valve that enables safe and efficient refilling of cylinders;

g. incorporates a valve that is internationally approved and used; and

h. if the current cylinder valve was to be changed, the compatible male (appliance) fittings could be

concurrently specified, mandated and introduced into the marketplace to optimise consumer safety.

The GEA Board has concluded the POL (Type 21) valve with back-check, the QCC with Type 21 internal

threaded valve and the modified QCC all possess the above attributes and has directed the working groups

to further investigate the implementation issues associated with these options in consultation with relevant

stakeholders.

Critically, adopting a new type of cylinder valve would require industry to meet demand as appliances with a new connection enter the market, whilst maintaining supply to the remaining portion of the market still using POL based appliance connections. That said, before industry could embark on any significant change to leisure cylinder valves, it would need the necessary changes to Australian Standards and State and Territory regulations to be in place. This includes requiring changes to appliance connection standards to ensure compatibility with a new cylinder valve. Such a change would require agreement from all stakeholders, including State and Territory Gas Technical Regulators, on an implementation plan and working together to implement it. The stakeholder agreed implementation would need to encompass timeframes, specifications, accountabilities and, most importantly, agreement from all key stakeholder groups. Quality of new appliance leads and the use of adaptors would need to be regulated and enforced by government regulatory bodies to ensure we can maximise the safety outcomes from the new valve.

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In further considerations, the working groups recognise that future investigations may consider other

valve types. If this were to occur, GEA suggests that for consistency and efficiency, the methodology

used by the GEA technical working group as presented in this paper is used. The working groups note

that there are outstanding issues to resolve such as:

• consumer impact on caravan and domestic users (including situations such as out of gas and

financial hardship cases);

• removal of some State and Territory regulation for the requirement for a gas tight plug; and

• changes to Australian Standards including appliance standards.

Further, a detailed implementation strategy would include engagement with key stakeholders such as but

not limited to:

• the Gas Technical Regulators Committee;

• the Gas Appliance Manufacturers Association of Australia;

Standards Australia;

• the Caravan Industry Association;

• gas appliance certifiers;

• major appliance groups such as Australian Barbecue Alliance; and

• the Australian Competition and Consumer Commission.

It would also include milestone requirements such as:

• government advocacy;

• standards timetable;

• regulation timetable;

• consumer education;

• industry training and awareness; and

• a legal review of competition and consumer law issues.

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Table of Contents Executive Summary ...................................................................................................................................... 2

Why undertake an LPG leisure cylinder safety review? ............................................................................... 7

Incident review .............................................................................................................................................. 7

Incident reporting ....................................................................................................................................... 7

Quantifying the causes of recent LPG leisure cylinder incidents .............................................................. 8

Incident summary ...................................................................................................................................... 9

The current Type 21 cylinder valve ............................................................................................................. 10

Type 21 strengths and weaknesses ........................................................................................................ 10

Alternatives to the current Type 21 cylinder valve ...................................................................................... 11

What is the potential of the alternatives to eliminate incidents? ............................................................. 11

Are the alternatives technically compatible with current cylinders? ........................................................ 13

Valve safety outcomes ............................................................................................................................ 13

What else needs to change if the cylinder valve changes? .................................................................... 14

Valve suitability summary ........................................................................................................................ 14

Review of regulations applying to LPG cylinders and appliances .............................................................. 15

Changing the male (appliance) connection ............................................................................................. 17

Conclusions ............................................................................................................................................. 17

Operational review ...................................................................................................................................... 18

Operational change conclusions ............................................................................................................. 25

Additional risks from switching to an alternative cylinder valve .................................................................. 25

Issues with specific alternative cylinder valves ....................................................................................... 25

Type 21 Back Check valve .................................................................................................................. 25

QCC ..................................................................................................................................................... 25

Kosan ................................................................................................................................................... 25

Matching a cylinder valve changeover to the average life of appliances ................................................ 25

Conclusions – operational impacts .......................................................................................................... 27

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Why undertake an LPG leisure cylinder safety review? GEA members in particular, and the LPG industry more broadly, regards the safety of its customers and the community as paramount and works continuously to improve the safety of its products. GEA members acknowledge that the State and Territory Gas Technical Regulators Committee (GTRC) has for some time been concerned about incidents involving portable gas cylinder (often called leisure cylinders) and their connection to portable appliances. GEA members are committed to working with the GTRC to make the use of portable gas appliances and cylinders safe. The GEA Board of Directors set up a working group to review the safeness of the leisure cylinder and connection arrangements. This document outlines the following.

• Incident review, looking at exactly where the issues lie.

• Examining the current Type 21 cylinder valve, its strengths and weaknesses.

• Outlining alternatives to the current Type 21 cylinder valve and how they could potentially eliminate

some of the incidents currently experienced.

• Exploring how the alternatives could be implemented through a review of regulations applying to

LPG cylinders and appliances.

• Assessing the impact on current operations and commercial implications.

• Understanding what additional risks could be introduced into the leisure gas market by the

alternatives.

Incident review This section of the report looks at quantifying recent LPG leisure cylinder and appliance incidents and their causes.

Incident reporting Reporting of gas incidents often attributes cause to an innocent component. To address this and work to ensure robust reliable and consistent data, incident causes, including appliance faults and the failure modes of the current Type 21 cylinder valve connection, were defined and raw incident data collected and mapped against these incident causes. The regulator, hoses and appliances are viewed as a part of the appliance and are captured for completeness of the review.

Diagram 1: LPG leisure cylinder incident causes

Appliance faults and fat

fire

Hose and hose crimp

issues

Leaks from regulator

diaphragm vent, inlet or

outlet threads

Main connection, damaged thread,

seal failure or operator error

Spindle pin

Bleed hole

Pressure relief

Ullage Boss thread

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Quantifying the causes of recent LPG leisure cylinder incidents Table 1 below quantifies the causes of recent LPG leisure cylinder incidents using data collected by GEA Members from July 2016 to February 2017 inclusive.

Table 1: Quantification of causes of recent LPG leisure cylinder incidents

Incident causes

Number of incidents

Percentage

Appliance - e.g Fat fire, 3 4.1%

Connection failure - damaged seal 2 2.7%

Connection failure - not tight enough 4 5.5%

Connection failure - operator error 7 9.6%

Cylinder leak 6 8.2%

Hose failure 2 2.7%

No cause found - damaged 1 1.4%

No cause found - insufficient information 21 28.8%

No cause found - tested 9 12.3%

Valve failure - bleed screw 3 4.1%

Valve failure - operator error 3 4.1%

Valve failure - spindle 3 4.1%

Valve Failure – Pressure Relief Valve (PRV) 2 2.7%

Valve fault - leaking thread in cylinder "boss" 2 2.7%

Valve fault - valve seat faulty 1 1.4%

Valve fault/operator error - inadequate fill process 4 5.5%

Total 73 100.0%

There are other sources of data and often incidents are passed directly to regulators and emergency responders and therefore not captured by industry. EnergySafe Victoria provided Gas Energy Australia with statistics for Victoria which included a review of all gas incidents from July 2012 to March 2016 and identified those related to barbecues, LPG hoses and LPG storage vessels. The number of incidents totalled 592.

Table 2: EnergySafe Victoria Statistics – Victorian LPG incidents

Row Labels Event Totals

Cause unable to be determined 240

Cylinder connection issue 160

Incorrect usage 70

Cylinder valve open 49

Hose failure 36

Cylinder Valve fault 33

Gas Leak - Other 4

Grand Total 592

The above EnergySafe Victoria data indicates that of those incidents where a cause was able to be determined, 69 per cent related to an issue with the cylinder valve connection.

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Following are brief outlines of several serious incidents including fatalities associated with leisure cylinders which are not highlighted in the statistics which have made the news. 29 Dec 2015 - Footscray explosion: One dead, another injured as a truck blast causes chaos in inner Melbourne. (Extract from Coroners letter to Gas Energy Australia – inviting GEA to attend a Coroners round table on 29 May 2017 to look at measures to enhance public safety.) “Mr Kelleher (Fire an Arson Expert from Victoria Police Forensic Services Centre Explosives Branch) determined that a fuel-air explosion had occurred in the cargo compartment of the truck, involving about one kilogram of gas. The apparent source of the gas was one or more of the LPG cylinders, each of which were found to be in good condition, with the valves partly open and low levels of LPG residue detected inside. None of the LPG cylinders’ pressure relief valves had deployed. ….. “ 12 June 2016 – Fairfield explosion: Teen in induced coma in Sydney after gas bottle explosion (extract from media report) “Police said the bottle was in the boot of a car in the car park of the Fairfield RSL. It exploded after the 50-year-old driver got back into his car and lit a cigarette…..The critically-injured teenager was passing by the car when the explosion occurred, police said.” 17 Sept 2016 – Sunnybank Hills explosion: Five hurt in gas explosion at Sunnybank Hills School in Brisbane (extract from media report) “It is understood the explosion was caused by two leaking gas cylinders at the back of a food truck carrying spring rolls and paper cups……. A 67-year-old man caught fire when he opened the back doors to the truck.” The above three serious incidents were associated with the transport and storage of leisure cylinders.

Incident summary The incident data recently collected by GEA Members shows that where the cause of an incident has been identified, the majority of incidents were related in some way to the cylinder valve. Similarly, EnergySafe Victoria data covering July 2012 to March 2016 indicates that of those incidents where a cause was able to be determined, 69 per cent related to an issue with the cylinder valve connection. The GEA data does not include incidents reported to suppliers that are not members of GEA. There will also be incidents reported to State and Territory regulatory, safety and emergency authorities that are not included in this data, including serious incidents subject to police and/or coronial investigations. The GEA data does not attempt to assess the severity of different types of incidents. The former NSW Chair of the State and Territory GTRC previously advised GEA that the GTRC is particularly concerned about recent incidents involving leaks from leisure cylinders in storage or transport that have resulted in ignition of leaked LPG and serious damage to people and property. Consequently, the GTRC Chair advised GEA that industry should consider switching to a cylinder valve that will provide increased levels of safety for consumers, especially when not being used for the purpose it was designed for.

Perspective - there are an estimated 9 million 9kg cylinders in the marketplace

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The current Type 21 cylinder valve All 4.5kg and 9kg gas cylinders in Australia use a POL valve, which is an acronym for the company that first made the valves - Prest-O-Lite. The valve can also be described by its US Compressed Gas Association (CGA) number CGA 510 and also its Australian Standard AS2473.2 reference as a Type 21 connection. POL, CGA 510 and Type 21 all refer to the same valve specification. There are an estimated 9 million 9kg cylinders with the Type 21 valve and cylinder connection in circulation across Australia. In this market, the cylinders mostly supply gas to consumer owned barbecues and patio heaters. The valve has a left-hand female thread and the valve incorporates a pressure relief valve for safety. The valve specifications have not changed significantly for several decades. In making the connection, a male connector is screwed into the Type 21 valve. The first male connectors relied on a metal to metal connection (brass on brass) with sufficient pressure applied via a hexagon nut to achieve an effective seal. The hexagon nut required a spanner to achieve sufficient pressure to obtain a gas tight seal. The notched hexagon nut denotes it is a left-hand thread. Following international convention, the standard changed to allow the use of an integrated hand wheel, with leak tightness being provided by an o-ring or rubber bull nose.

Hexagon nut (requires spanner to tighten) metal to metal seal

Hand wheel with o-ring seal Hand wheel with rubber bull nose

Type 21 strengths and weaknesses The Type 21 connection has the following strengths.

✓ Consumer familiarity

✓ Left Hand (LH) thread is not interchangeable with other gas connections

✓ There is no need for adaptors

✓ It has a simple design and operation

✓ The appliance industry is supplying to a known standardised product

✓ Industry knows its operational limitations (testing, operations, usage)

✓ The valve is safe when used correctly

✓ The valve is covered by Australian Standards

✓ The cylinder can be decant filled if fitted with an ullage tube and bleeder valve

The type 21 design has the following inherent weaknesses.

Left-hand thread causes confusion with some people

Achieving leak tightness requires soft seat or use of a tool

Soft seats (rubber bull-noses and o-rings) are prone to damage

Multiple examples of poor designs of soft seats and damage

No standard covers the precise dimensions of soft seats components

Design of hand wheel not always conducive to achieving gas tightness

Open a valve and gas will flow without a seal being made

POL/Type 21/ CGA510 valve

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Alternatives to the current Type 21 cylinder valve The seven options identified for consideration as a possible modification or replacement of the current Type 21 are the following.

1. Type 21 CGA 510 with gas tight plug

2. Type 21 CGA 510 with brass connections

3. Type 21 CGA 510 (POL) with back check

4. Type 21 CGA 510 (POL) with back check and brass connections

5. QCC (with external ACME/internal Type 21)

6. Modified QCC (no internal CGA 510 connection)

7. V91 Quick on (Kosan) style

What is the potential of the alternatives to eliminate incidents? Table 3 below quantitatively assesses the capacity of alternatives to the current Type 21 connection to eliminate the potential for the incident to occur. This is overlaid onto the incident review data and provides a qualitative assessment of the capacity of the alternatives to potentially eliminate the incidents observed in the incident review.

Table 3: Quantitative assessment of the capacity of alternatives to eliminate incidents

Incident causes Shar

e o

f in

cid

ents

Typ

e 2

1 w

ith

gas

tig

ht

plu

g

Typ

e 2

1 w

ith

bra

ss o

nly

con

nec

tio

ns

Typ

e 2

1 w

ith

bac

k ch

eck

valv

e

Typ

e 2

1 w

ith

bac

k ch

eck

and

bra

ss f

itti

ngs

QC

C

Mo

dif

ied

QC

C

Ko

san

Appliance - e.g fat fire, 4.1%

Hose failure 2.7%

Connection failure - not tight enough 5.5% 5.5% 5.5% 5.5% 5.5% 5.5%

Connection failure - operator error 9.6% 9.6% 9.6% 9.6% 9.6% 9.6%

Connection failure - (including damaged seal, missing seal and male thread damaged)

2.7% 2.7% 2.7% 2.7% 2.7% 2.7%

Valve failure - operator error 4.1% 4.1% 4.1% 4.1% 4.1% 4.1% 4.1%

Valve failure - bleed screw 4.1% 4.1%

Valve failure – PRV 2.7%

Valve failure - spindle 4.1% 4.1%

Valve fault - leaking thread in cylinder "boss" 2.7%

Valve failure – outlet thread damaged

✓ ✓

Valve fault - valve seat faulty 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4%

Regulator failure

Non-valve component leak

Valve fault/operator error - inadequate fill process 5.5% 5.5%

Cylinder leak 8.2%

Degree of mitigation

Incidents completely eliminated 0% 2.7% 5.5% 8.2% 15.1% 20.5% 27.4%

Incidents partially eliminated

5% 0% 15.1% 15.1% 8.2% 2.7% 9.6%

Legend and colour coding - Does not address issue - % partially resolves the issue - % solves the issue

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Tables 1 and 3 show that in some cases the incident cause could not be identified – these are classified as No Cause Found (NCF) incidents totalling some 42.5% of reported incidents. Including these NCF incidents in Table 3 has the effect of understating the capacity of the alternative options to eliminate incidents because it is impossible to eliminate incidents when the cause is unknown. In Table 4 below these NCF incidents have been proportionally allocated according to the known incident distribution shown in Table 1 above.

Table 4: Adjusting incident data for NCF incidents

Incident causes Shar

e o

f in

cid

ents

Typ

e 2

1 w

ith

gas

tig

ht

plu

g

Typ

e 2

1 w

ith

bra

ss o

nly

con

nec

tio

ns

Typ

e 2

1 w

ith

bac

k ch

eck

valv

e

Typ

e 2

1 w

ith

bac

k ch

eck

and

bra

ss f

itti

ngs

QC

C

Mo

dif

ied

QC

C

Ko

san

No cause found (NCF) - damaged 1.4%

No cause found (NCF) - insufficient information 28.8%

No cause found (NCF) - tested 12.3%

Proportionate Allocation (PA) of No Cause Found (NCF) incidents to incidents with an identified cause

PA of NCF - Incidents completely eliminated 0% 1% 2% 3% 6% 9% 12%

PA of NCF - Incidents partially eliminated 2% 0% 6% 6% 3% 1% 4%

Chart 1 below summarises the capacity of alternatives to the current Type 21 connection to eliminate incidents taking into account NCF incidents in accordance with Table 4 above.

Chart 1: Capacity of alternatives to eliminate incidents, including NCF adjustment

Type 21with gas

tight plug

Type 21withbrassonly

connections

Type 21with back

checkvalve

Type 21with back

checkand brass

fittings

QCCModified

QCCKosan

PA of NCF - Incidents partially eliminated 2% 0% 6% 6% 3% 1% 4%

Incidents partially eliminated 5% 0% 15% 15% 8% 3% 10%

PA of NCF - Incidents completelyeliminated

0% 1% 2% 3% 6% 9% 12%

Incidents completely eliminated 0% 3% 5% 8% 15% 21% 27%

0%

10%

20%

30%

40%

50%

60%

Esti

mat

ed %

red

uct

iuo

n in

inci

den

ts

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Are the alternatives technically compatible with current cylinders? Table 5 below compares key operating and safety features across the alternative options.

Table 5: Technical comparison of the alternative options

Valve characteristics Gas

tig

ht

plu

g in

Typ

e 2

1

con

nec

tio

n

Typ

e 2

1 w

ith

bra

ss

on

ly c

on

nec

tio

ns

Typ

e 2

1 w

ith

bac

k

chec

k va

lve

Typ

e 2

1 w

ith

bac

k

chec

k an

d b

rass

fitt

ings

QC

C

Mo

dif

ied

QC

C

Ko

san

Isolation valve Yes Yes Yes Yes Yes Yes No

Check valve No No Yes Yes Yes Yes Yes

Filling rate (kg/min) 44.29 44.29 37.45 37.45 36.15 36.15 19.24

Cylinder “boss” thread ¾” -14 NGT ¾” -14 NGT ¾” -14 NGT ¾” -14 NGT ¾” -14 NGT ¾” -14 NGT ¾” -14 NGT

Pressure Relief Valve Yes Yes Yes Yes Yes Yes Yes

Setting 375 p.s.i 375 p.s.i 375 p.s.i 375 p.s.i 375 p.s.i 375 p.s.i 375 p.s.i

Valve - Australian Reference Standard

AS2743.2 AS2743.2

Valve - International Reference Standard

UL 1769 UL 1769 UL 1769 UL 1769 UL 1769 UL 1769 ISO15995

Valve designation CGA 510 CGA 510 CGA 510 with check device

CGA 510 with check device

CGA 791 V91

Usage Current requirement in Qld and NT

Mandated by regulation in the US Used in New Zealand

Valve specification exists Not in production or use

Used in Europe

Specification drawing for the following valves are included as attachments to this document Attachment 1 – Type 21 (CGA 510) Attachment 2 – Type 21 with check valve Attachment 3 – QCC Attachment 4 – Kosan (V91)

Valve safety outcomes The comparative safety merits assigned to the valves in the above tables are discussed in the Executive Summary section of this report.

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What else needs to change if the cylinder valve changes? Table 6 below outlines the impact on the appliance connection of the alternative cylinder valve options discussed above.

Table 6: Impact on appliance connection of alternative cylinder valve options

Valve Connection

Gas Tight Plug

No change to POL connection

POL valve with brass male fitting

Change to brass male fitting

POL with back-check No change to POL connection

POL with back-check valve and brass male fitting

Change to brass male fitting

QCC

New appliances would have QCC Connector and existing cnnections would retain the

POL connection

or

Modified QCC

Change to QCC connector

Kosan style valve

Change to Kosan connection

Valve suitability summary The review of valves suitable for use in LPG cylinders for the leisure cylinder market shows that the

capacity of a range of viable alternatives to the current Type 21 valve to eliminate incidents associated with the existing connection varies considerably. The review is a desktop analysis based on manufacturer information available at the time of the review. It does not cover improved safety outcomes from the connector and importantly does not show is that those alternative valves which offer the prospect of the greatest mitigation of current incidents, eg, the QCC or Kosan, could increase the likelihood of other types of incidents as a result of the characteristics of these valves. These increased risks could include but have not been quantified: Back-check valve has internal surfaces which can damage the rubber bull nose seals used on

appliance connectors creating the potential for leaks, or itself be damaged by poorly manufactured appliance connectors or filling guns (decant or otherwise)

QCC has external threads which are exposed to dust and potential damage and

excess flow valve in the male lead connection can activate under normal operating conditions causing flow restrictions (there is a reset procedure however if consumers are not familiar with this functionality they may assume an empty cylinder)

Kosan potentially is prone to dust ingress if not capped when not in use, no decant fill facility and being only a soft seat check valve, it does not have a positive shut-off valve to enable isolation when a leak occurs, and lack of a positive shut off valve is not reflected in the Kosan valve’s safety score.

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Review of regulations applying to LPG cylinders and appliances There is a hierarchy of legal rules in Australia. The highest level is an act of Parliament, which is a sequence of provisions containing statements and rules designed to give effect to a particular policy. Sitting underneath an act of Parliament are Regulations, which are law made by an executive branch of the parliament with the delegated power to do so. In most cases this contains the detailed provisions. Where third party documents are referenced in acts or regulations, they become Law. An example of such documents are Australian Standards. Australian Standards by themselves are published documents setting out specifications and procedures. When they are referenced in an act of Parliament or regulation they become part of the law. Under Australia’s federation, there is a division of responsibility which sees States and Territory Governments having legislative powers for justice, consumer affairs, health, education, forestry, public transport, main roads, power, gas, water and sewerage. This places responsibility for the regulation of cylinder valves and connections within the bailiwick of the States and Territories and Diagram 2 shows the relevant regulation in each jurisdiction.

Diagram 2: Regulations governing LPG leisure cylinders in Australian States and Territories

Qld

Pet

role

um

an

d G

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States and Territories will in the main reference relevant Australian Standards. The hierarchy of regulation for cylinder valves in Australia is outlined below in Diagram 3.

Diagram 3: Summary of cylinder valve regulation in Australia

With the regulatory and standards framework outlined above, changes could be implemented by amending State and Territory regulation directly or by amending the references that government regulations currently make to Australian Standards. Given the framework which the cylinder valve is operating within it may be less time consuming to navigate and more importantly achieve more national consistency and uniformity by making changes within the Standards Australia framework rather than approach State and Territory regulators independently. The current requirements for the valve are specified in Australian Standard - AS 2473.2: Outlet connections (threaded) and stem (inlet) threads. It outlines which valve type is used for which gas (for propane the valve type can be either a Type 20 or Type 21). AS 2473.2 is referenced by AS2030.1 Gas Cylinders, which is in turn referenced by AS1596. AS1596 is referenced in different State and Territory regulations on gas safety. To change the valve connection would requires changes to Australian Standards AS2473.2, AS 2030: Gas Cylinders series of standards and AS1596. It would also require a review of the referenced legislation to ensure there are no conflicts. As a complication, workplace health and safety legislation required design approval and references AS2030. The requirements should also be reviewed to ensure there are no conflicts. Some of the proposals would require the appliance connection to be changed. This would also require a number of Australian Standards to be amended as there are references specifying the connection which are present in these standards.

Reference

•AS 2473.2 Outlet connections (threaded) and stem (inlet) threads

•specifies valve types and gases

•includes Propane where the valve type can be either a Type 20 or Type 21

Reference

•AS2030.1 Gas Cylinders

•Specifies AS2473.2 as being the reference for the cylinder valve

•Qld Petrolem and Gas Safety Regulation references AS2030 directly

Reference

•AS1596 Storage and handling of LP Gas

•Specifies AS2030.1 as being the reference standard for cylinders

Reference

•State and Territory Gas Regulation

•Specify AS1596 as the reference standard for storage and handling of LP Gas

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Changing the male (appliance) connection The male connection requires more changes in the Australian Standards framework. Standards which may require review include: AS 4621 Regulators for use with liquefied petroleum—Vapour phase AS 5263.0 Gas appliances AS 2658 LP Gas—Portable and mobile appliances AS 5262 LP Gas mobile industrial direct fired air heaters AS 4557 Domestic outdoor gas barbecues AS 4565 Radiant gas heaters for outdoor and non-residential indoor use AS 4558 Decorative gas log and other fuel effect appliances AS 3645 Essential requirements for gas equipment AG 404 Approval requirements for LPG mobile industrial direct fired air heaters AS 4563 Commercial catering gas equipment AS 5601 Gas Installations (contains reference to gas tight plug in appendix)

Conclusions A review of the above listed Australian Standards applying to LPG cylinders and appliances demonstrates that a project to work with Standards Australia to make a significant change to the Type 21 connection would require substantial resources given the complexity of the project and the number of Standards involved and would most likely take at least two years. Nevertheless, such a process would be preferable to individual jurisdictions making separate changes to their regulations, possibly resulting in different cylinder valves being mandated in different jurisdictions. Given the extent to which LPG cylinders move between Australian jurisdictions, such differences would encourage the use of adaptors which would increase the risk of additional safety incidents. There would also be significant work required to align the various appliance and component standards and also potential costs for re-certification of appliances because of a material change in the standard.

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Operational review Each option is review on its operational and commercial impacts

Table 7: Scenario – Gas Tight Plug

Scenario Title Gas Tight Plug

Description Use of gas tight plug in all cylinder exchange programs (currently mandated in Queensland

Flow rate comparison POL flow rate 44.29 kg/min

Flow rate for new configuration No change

Impact (+ or -)

Description Industry Issues

Retailer issues

Consumer issues

+ Current requirement in Qld and NT New plug in some states and development of POS material, marketing and legal

Nil expected Nil expected

+ Easy to implement

- Requires amendment to AS1596 – decanting

- Requires new GEA guidance video on decanting

- Consumer behaviour (limited reuse)

- Would require policing of decant operators by regulators

Comment- easy to mandate but with limited effect beyond initial application by cylinder exchange program operator or decanter

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Table 8: Scenario – Type 21 (POL) valve with brass male fitting

Scenario

Title Type 21 (POL) valve with brass male fitting

Description Maintain current POL and make male appliance hose revert to brass fitting requiring spanner for connection

Fill rate comparison POL flow rate 44.29 kg/min

Fill rate for new configuration No change

Impact (+ or -)

Description Industry issues Retailer Issues Consumer Issues

+ Removes rubber components from connection Development of marketing, education material.

Nil expected Resistance to using a spanner

- Requires amendment to AS 2473

- Requires amendment to appliance standards

- Consumer resentment

Comment- would be difficult to mandate from a standards and regulatory perspective and almost impossible to enforce

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Table 9: Scenario – Type 21 (POL) with back check valve

Scenario Title Type 21 (POL) with back check valve

Description Maintain current POL but add a back check valve which would not allow gas to flow unless a positive connection had been achieved

Fill rate comparison POL flow rate 44.29 kg/min

Fill rate for new configuration POL with back check 37.45 kg/min (15% reduction)

Impact (+ or -)

Description Industry issues

Retailer issues Consumer issues

+ Valve changed during 10 year cylinder test Changes in valve and operations

Nil expected Nil expected

+ No change in appliance standards

- Require amendment to AS 2473

- Rubber seals will chew out on back check

- Some leakage could occur if not tightened sufficiently for gas tight seal, but sufficiently engaged to open back check.

Comment - concern that the rubber seals could impact the effectiveness of the back check and that it might not address connection issues

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Table 10: Scenario – Type 21 (POL) valve with back-check and brass male fitting

Scenario Title Type 21 (POL) valve with back-check and brass male fitting

Description Maintain current POL but add a back-check valve which would not allow gas to flow unless a minimum engagement pressure on the connection had been achieved and require appliance hose to revert to brass fittings requiring spanner for connection

Fill rate comparison POL flow rate 44.29 kg/min

Fill rate for new configuration POL with back check 37.45 kg/min (15% reduction)

Impact (+ or -)

Description Industry Issues Retailer Issues Consumer Issues

+ Valve changed during 10 year cylinder test Changes in valve and operations and some educational and marketing material

Resistance to using a spanner

+ No change in appliance standards

- Requires amendment to AS 2473

- Requires amendment to appliance standards

- Some leakage could occur if not tightened sufficiently for gas tight seal, but sufficiently engaged to open back check.

- Consumer resentment

Comments –Implementation of brass only connection would be difficult to mandate from a standards and regulatory perspective and almost impossible to enforce

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Table 11: Scenario – Quick Connect Coupling (external ACME/internal Type 21)

Scenario Title Quick Connect Coupling (external ACME/internal Type 21)

Description QCC connection with internal thread which would allow POL type 21 to be used

Fill rate comparison POL fill rate 44.29 kg/min

Fill rate for new configuration QCC fill rate 36.15 kg/min (18% reduction)

Impact (+ or -)

Description Industry Issues Retailer issues Consumer issues

+ Valve changed during 10 year cylinder test Changes in valve and operations, educational and marketing material

Stock management as old valve is returned and new dual valve is cycled through the consumer held cylinders

New potentially more expensive appliance hose required when old one fails

+ Stage transition in appliance standards

+ Much improved positive connection to appliances

- Require amendment to AS 2473

- Rubber seals will chew out on back check

Comments - concern that the rubber seals could impact the effectiveness of the internal QCC check valve and the amount of time to implement a transition to QCC in standards for appliances would be significant

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Table 12: Scenario – Modified Quick Connect Coupling with no internal Type 21 - CGA 510 (POL) connection

Scenario Title Modified Quick Connect Coupling – no internal Type 21 connection

Description Modified QCC connection – will require separate distribution during changeover

Fill rate comparison POL fill rate 44.29 kg/min

Fill rate for new configuration QCC fill rate 36.15 kg/min (18% reduction)

Impact (+ or -)

Description Industry Issues Retailer Issues Consumer Issues

+ Safe connection Changes in valve and operations, educational and marketing material

Would require two products to be stocked where currently only one is. No detailed costs in this regard

Would require consumers to change appliance hose when they swap to a new cylinder Costs increase where a gas fitter is required to change the pigtail (comes under AS5601) in Caravan and Domestic installations

- Requires significant standards changes

- Requires investment in maintaining two cylinder valve types at retail outlets

- Requires new appliances to be supplied with new connection as soon as Standards are changed -

- requires state regulators to police no ongoing POL hose sales

- Requires new decant gun or use of adaptors at decant sites

Comments – duplicate distribution systems for retailers would impose additional costs and there would be a significant legacy period for maintaining cylinders with a CGA510 connection

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Table 13: Scenario – Kosan style valve

Scenario Title Kosan style valve

Description Click on – V91 style valve

Fill rate comparison POL fill rate 44.29 kg/min

Fill rate for new configuration Kosan fill rate 19.24 kg/min (56% reduction)

Impact (+ or -)

Description Industry Issues Retailer Issues Consumer Issues

+ Safest connection Changes in valve and operations, educational and marketing material

Would require two products to be stocked where currently only one is.

Would require consumers to change appliance lead when they swap to a new cylinder Costs increase where a gas fitter is required to change the pigtail (comes under AS5601) in Caravan and Domestic installations

+ Automated fill possible

- Slow fill rate

- Require significant standards changes

- Require maintaining two cylinder valve types at retail outlets

- Requires new appliances to be supplied with new connection as soon as Standards are changed -

- requires state regulators to police no ongoing POL hose sales

- Only a single valve – no shut off

Comments – has significantly slower fill rate but can be automated in a fill line. Relies on a single valve for isolation (no valve to turn off if it leaks). Would require duplicate distribution systems for retailers with a significant cost impost and there would be a significant legacy period for maintaining cylinders with a CGA510 connection. Would require appliance standard changes. Would remove decant fill as an option.

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Operational change conclusions The most straight forward approach would be to align the valve change with the 10 year inspection cycle for cylinders. It is at this time that the valve is changed. More background on possible impacts on consumers and retailers are outlined in the following additional risks section.

Additional risks from switching to an alternative cylinder valve This section examines additional possible risks that could be introduced into the leisure gas market by implementing a switch to an alternative valve.

Issues with specific alternative cylinder valves

Type 21 Back Check valve

• Even with the use of a back check valve, leak tightness requires soft seat or use of tool and soft

seats have been shown to be prone to damage.

QCC

• While the QCC improves the connectability of the appliance hose, it still requires the use of a hand

wheel. The QCC has an exposed external thread and while this is a very wide arrangement it can

still be exposed to damage.

• The QCC has an excess flow valve in the hose assembly which operates to limit gas flow. There

are times when this can be activated during normal operation and requires a specific process to be

followed to allow it to be reset.

• Changing the valve would require changing the gas appliance standards and monitoring of quality

and performance of the appliance leads.

• Requirement for gas tight plug would need to be removed from relevant state regulations.

Kosan

• The design currently precludes decant filling and this would possibly require ACCC approval.

• The fill rate is significantly slower than the current POL.

• The design is potentially prone to dust and ingress.

• Leaking seals on the cylinder check valve are unable to be isolated with the current design.

• Changing the valve would require changing the gas appliance standards and monitoring of quality

and performance of the appliance leads.

Matching a cylinder valve changeover to the average life of appliances As pressure vessels, leisure cylinders have a requirement to be internally inspected and tested every 10 years. At this time, it is industry practice to replace the valve rather than undertake a valve recertification. This 10 Year cylinder inspection cycle represents an opportunity to replace existing Type 21 valves with a new type of cylinder valve, ie QCC or Kosan, in an orderly and cost-effective manner. In addition to this process, the introduction of new cylinders each year and replacing retired cylinders is an opportunity to accelerate or slow down the introduction of a new cylinder valve. This managing of cylinder supply can be used to align new and old cylinder valve configurations with customer demand. This would see the number of new cylinder valves introduced into the market gradually increase until after 10 years when it is anticipated that almost all single Type 21 valves would be removed from service. The demand for cylinders with new valves is most likely to match supply when the average operational life of the appliances connected to the cylinders matches the cylinder inspection cycle of 10 years.

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Failure by industry to match a changeover to a new type of cylinder valve unable to be connected to old appliances, ie QCC or Kosan, to the average life of appliances could result in some consumers giving up on LPG (ie demand destruction) or others seeking out cylinder valve adaptors which would create the risk of safety incidents associated with the incorrect use of adaptors. The switch to a QCC valve in New Zealand was initially associated with an increase in safety incidents, in part due to the use of adaptors. Table 14 below shows that the average life of the appliances most connected to leisure cylinders is less than 10 years1. Given that barbeques are by far the appliances most connected to leisure cylinders, the average life of the appliances has been assumed in the cost estimates to be 8 years.

Table 14: Matching the average life of portable appliances

Appliance Operating life

Commentary Impact

Barbecues 8.3 years Demand for new valve cylinders would likely exceed supply based on 10 year changeover cycle

Would require industry to replace valves and retest cylinders 1.7 years earlier

Area Heaters Between 3-5 years

Demand for new valve cylinders would likely greatly exceed supply based on 10 year changeover cycle

Would require industry to replace valves and retest cylinders 5 to 7 years earlier

Estimated combined appliance life cycle

8 years Demand for new valve cylinders would likely exceed supply based on 10 year changeover cycle

Would require industry to replace valves and retest cylinders 2 years earlier

While not costed, there are some other uses of the 4.5 and 9kg leisure cylinders which must be considered in any changeover scenario. Table 15 shows the impact of a valve change on leisure cylinders in fixed use. The appliances associated with these uses tend to have longer lives than the portable appliances often kept outdoors which would increase the average life of appliances therefore better aligning them with the 10 year cylinder life cycle. But the potentially higher costs of switching fixed use appliance connections, increases the risk of some consumers giving up on LPG or others seeking out cylinder valve adaptors.

Table 15: Impact of a valve change on leisure cylinders in fixed use

Use Quantity Commentary Impact

Caravans and Campervans

Caravans – 554,344 Campervans – 60,957 Average age -17.8 yrs.

At some point in the changeover timeline, consumers would be forced to either change to the new connection or use adaptors. Changing the pigtail connection is captured under AS5601

Would require the consumer to replace the pigtail gas connections for caravans and campervans.

Backup for domestic out of gas situation and hardship cases

Unknown Some consumers use a 9kg to supply their home when they run out of gas until a delivery can be made or when suffering financial hardship.

Would require the consumer to replace the pigtail gas connections or use an adaptor if only the modified QCC connection is available.

New domestic installations

Unknown New houses where only a gas cooktop is installed are using dual 9kg cylinders for supply rather than larger 45kg units where space is limited.

Would require the consumer to replace the pigtail gas connections or use an adaptor if only the modified QCC connection is available.

1 BIS Shrapnel 2015 Study

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Conclusions – operational impacts Adoption of a new type of cylinder valve unable to be connected to old appliances, ie modified QCC or Kosan, would require industry to match the changeover to the average life of appliances to avoid some consumers giving up on LPG or others seeking out cylinder valve adaptors which would create the risk of additional safety incidents. The potentially higher costs of switching fixed use appliance connections in caravans and dwellings, increases the risk of some consumers giving up on LPG or others seeking out cylinder valve adaptors. Moreover, any significant change to leisure cylinder valves would require changing gas appliance standards and monitoring of the quality and performance of appliance leads. It would also require regulatory support to prevent the use of adaptors.

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Attachment 1 – Type 21 – (CGA 510)

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Attachment 2 – Type 21 with back-check valve

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Attachment 3 – QCC

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Attachment 4 – Kosan (V91)