Who Is Responsible for the LPG Pipework Between the LPG Tank and the Factory?

When you work with liquefied petroleum gas (LPG), whether in a manufacturing plant, processing site, food facility, or any commercial premises, understanding responsibility for the pipework is absolutely essential! One of the most common questions raised by duty-holders and facilities managers across the UK is surprisingly simple, yet heavily misunderstood: who actually looks after the LPG pipework running between the tank and the factory building?

It might seem like the sort of thing that “just gets dealt with”, but the law takes a very tight view on responsibility. The pipework outside your building doesn’t sit in a grey area. In fact, the arrangements are far more black-and-white than many businesses realise. Getting it wrong can mean not only safety hazards but also potential enforcement action, insurance issues, and costly downtime. Let’s break it all down clearly and sensibly!

Understanding the Basic Setup: LPG Tank to Factory

Most commercial sites in the UK using LPG will either have:

• An above-ground bulk LPG tank
• An underground bulk LPG tank
• A compact LPG cylinder installation (although these have different rules)

Between this storage point and your factory sits the external pipework, usually known as the service pipework or installation pipework. It carries LPG from the tank’s outlet valve, through the vapouriser if used, along the site’s route, and into the building where it feeds appliances, heaters, burners, ovens, boilers, or machinery.

This run of pipework can stretch just a few metres or cross a large industrial yard. And crucially, someone must legally own it, maintain it, test it, inspect it, and record its condition.

But who?

Supplier vs Customer Responsibilities – The Key Split!

In the UK, responsibility typically falls into two distinct parts:

1. The LPG Supplier (e.g., Calor, Flogas, AvantiGas, etc.)

The supplier normally owns and maintains:

• The bulk tank itself
• The tank valves
• The regulator(s) situated at the tank
• The pigtails connecting cylinders in cylinder-based systems

Their responsibility almost always ends at the outlet of the first-stage regulator, often called the point of delivery. From that point onwards, they legally hand over responsibility to the gas user.

2. The Customer / Site Operator / Duty-Holder

From the regulator outlet to every appliance inside the building, responsibility belongs to the business operating the premises. That includes:

• All service pipework running from the tank to the building
• All underground pipework
• All supports, brackets, protection measures, sleeves, and ducts
• All internal pipework
• All valves, isolation points, meters, and fittings on the customer’s side

So, the simple answer is: the business running the factory is responsible for the LPG pipework between the tank and the building, unless there is a bespoke written agreement stating otherwise.

Why This Division Exists – A Safety and Liability Perspective

LPG is a highly combustible, high-risk fuel. Any leak in the pipework between the tank and the building could present a serious hazard, especially since LPG is heavier than air and tends to pool at low levels. Because suppliers cannot continuously supervise or control what happens on private land, the UK regulatory framework assigns ownership to the site operator.

This ensures:

• Clear lines of legal responsibility
• Consistent safety controls
• Accountability for inspection and maintenance
• Compliance with UK gas safety legislation

It also prevents confusion during incidents or inspections. The enforcing bodies, such as the HSE, expect the duty-holder to understand and manage the pipework as part of their safety regime.

Legal Framework – What the UK Regulations Say

Several pieces of legislation apply directly to LPG pipework responsibility:

Gas Safety (Installation and Use) Regulations (GSIUR)

These regulations cover gas pipework, fittings, and appliances. For commercial premises using LPG:

• The duty-holder must ensure pipework is maintained in a safe condition.
• The business must use competent engineers for installation and maintenance.
• Records must be kept of inspections, pressure tests, tightness tests, and repairs.

The Health and Safety at Work etc. Act 1974

This places a broad duty on employers to ensure the safety of employees and anyone affected by their activities. Poorly maintained LPG pipework would breach this fundamental duty.

The Pressure Systems Safety Regulations (PSSR)

While the bulk tank itself falls under PSSR (normally handled by the supplier), the downstream pipework may form part of the wider pressure system arrangements on-site.

The Dangerous Substances and Explosive Atmospheres Regulations (DSEAR)

These regulations require the site operator to identify hazardous zones, evaluate LPG risks, and manage ignition sources. External pipework is directly included in this risk assessment.

Together, these frameworks leave no doubt: the factory operator must control and maintain the external pipework.

Does the Supplier Ever Take Responsibility for the Pipework?

Occasionally, yes—but only if you have a written supply contract stating so, and only for specific installations.

In practice, this is rare for industrial sites. Domestic installations may have some exceptions, but in a commercial environment, suppliers almost always limit their obligations to the tank and its immediate fittings.

If your business is unsure, check your supplier’s contract. Many firms discover too late that the pipework has been entirely their responsibility for years without any inspection or testing.

What Does Proper Pipework Management Involve for the Factory?

Taking ownership of the pipework doesn’t just mean acknowledging it exists. It requires an active, routine safety regime. A competent duty-holder should ensure:

1. Regular Inspections

This includes visual surveys and formal assessments, especially for:

• Corrosion
• Mechanical damage
• Undermining
• Settlement issues
• Pipe supports, clips, brackets, and impact protection

Above-ground pipework should be easy to inspect, but underground pipework demands greater attention due to hidden deterioration.

2. Pressure Tightness Testing

UK guidance recommends periodic tightness tests, especially for older installations or pipework exposed to aggressive conditions. The frequency depends on usage, environment, and risk assessments.

3. Corrosion Control

External LPG pipework must be adequately protected, especially if buried. Proper wrapping, tracing tape, marker posts, and corrosion-resistant materials are essential.

5. Marking and Mapping

A complete site plan should exist showing:

• Routing of all external LPG pipework
• Depth of underground sections
• Entry points into buildings
• Valves and emergency controls

This makes emergency response and future maintenance safer.

6. Record Keeping

The HSE expects written evidence of:

• All inspections
• Test results
• Repairs
• Risk assessments
• Certificates from qualified engineers

Lack of documentation is treated the same as lack of maintenance.

Why Many Factories Get This Wrong

LPG installations can be decades old, with staff changes leading to loss of knowledge. Many sites assume the supplier owns “everything up to the wall”, but this belief is incorrect and potentially dangerous.

Common misunderstandings include:

• Thinking the supplier owns all external pipework (false).
• Believing the supplier would automatically inspect the pipework (they do not).
• Assuming underground pipework never needs attention (it does).
• Believing the insurance company would cover faults (not if maintenance was neglected).

When enforcement notices are issued, they often relate to unknown or poorly maintained pipework.

Practical Steps Every Factory Should Take Immediately

If your site uses LPG, review these points today:

1. Identify the pipework route

Walk the site, check drawings, and locate underground runs.

2. Confirm who owns what

Check your supply contract. In most cases, the site is responsible for all pipework after the regulator outlet.

3. Log inspection dates

Establish whether the pipework has been inspected in the last few years.

4. Arrange a professional assessment

If in doubt, commission a competent engineer to assess condition, routing, and safety.

5. Update your DSEAR assessment

External pipework must be included in hazardous area classification and control measures.

The Bottom Line – Responsibility Lies With the Factory Operator

The final answer is clear: the LPG pipework between the LPG tank and the factory is almost always the responsibility of the site operator, not the LPG supplier. This responsibility is both legal and practical, covering inspection, testing, maintenance, mapping, and record-keeping.

Treating the pipework as an integral part of your safety system protects your staff, your site, and your business! Clear ownership and regular maintenance help avoid leaks, incidents, enforcement action, and costly disruptions.

If you run a factory in the UK using LPG, now is the perfect moment to verify the condition of your external pipework and ensure you are fully compliant. Neglecting it isn’t just a regulatory risk—it’s a serious safety issue. Take ownership, stay vigilant, and keep your installation in top condition!

FAQs

Further Reading