Petroleum

surprised than 'Our new Chairman 'Jim' Hewison to find that the Mayor had him in the Club! The 1066 Club to be precise, and gave him an excellent tie to prove it.

We were 'reminded once more to make sQre we came ba<;k to Hastings and Secretary should note that the weather. <;ould be better later in the year than .eaTly April.

On Thursday, last but by no means least we were pleased to hear from Dr. G. J. Jeacocke on Adminis'tmtion and Europe. It was interesting to speculate just what the 'Bains' commi.ttee could do if they re-organised the Civil Service. Perhaps we might in due course get 'a uniform labelling system?

As usual 'Jim'came prepared to answer (even if not in w.riting) all our questions and a veritable barrage of . arrows they were!

Congratulations to the Chairman from his predecessor.

The Conference Organiser, John Frid, in thoughtful mood.

At the end I suppose honours were even, and the different factions grounded thek spears and lis,tened with interest to the Home Office Statement on the future of Petroleum Adminis'tration. This perhaps was the best finale.

Personally I found throughout the conference a ready acknowledgement of 'the expertise the members of the Association both have and 'sha,re, from whatever discipline they origina1te. For us the most important aspect is a job 'well done' and it is to be hoped that this will be the objective no matter what changes re-organisation bring, and to this end the Association exis,ts and we all hope will continue to exist.

It was the r,ight note on which to leave the battlefield; nobody actually fought and it was one of the best ·confe.rences we have had.

Our thanks to the officers of the Association, Hastings Corporation, and Gordon Beresford and staff for making it a memor-able occasion,

PETROLEUM- BRANCH ' RE-ORGANISATION

By W. C. R .. Dale, Esq., Greater Lo.ndon Council

Introduction

I have seen the ma.ny ,fi,ne a,rguments as to wllich department of 'the upper t ier 'authority should be made responsible after 1st April, 1974 for administration of the Petroleum Acts ana comparable legisl'ation. I have 'also heard the vain impassioned plea -for the work to be done on an agency basis by the lower ,bier authority. Let me 'say therefore at the outset ,that I have no intention of entering either of these two pl;lrticu-la'r It is said that one should never interfere in a fight between a man and his wife and I place the questien 'as to who 'is most competent to deal with administration of the Petroleum -Acts 'in much the ,same category.

You may question how I can help you solve your problems on petroleum branch re-organisation when I do not know what they are. The answer is that I cannot. All that I can do is to tell you how we in the Greater London Council faced up to a similar re-organisation in 1965, the difficulties which we encountered and the solutions which we produced. The most that I can hope for is that our experience may in some way help you with the problems which you now have to solve.

The Problem in London Greater London covers approximately 700 square miles and in 1964 housed more than one-seventh of the population of the U.K. So far 'as Petroleum Act work was concerned the new Greater London Council was required to take over the responsibility borne previously by 60 local authorities. These 'authorities varied in size from small urban district Councils to the London County Council. Each had its own principles of construction and licence conditions and appointed varying disciplines to undertake the work with widely varying efficiency. One authority because of shortage of staff had in fact given up the ghost altogether and had not bothered with issuing petroleum licences for some two years; the District Auditor, however, put a stop to this gambit.

The one great advantage in the London re-organisation lay in the fact that the London County Council had an existing specialist branch comprising 'inspectors and administrators who were already dealing with petroleum work in two-fifths of the proposed Greater London area. It was immediately apparent that the Petroleum Branch of the Greater London Council would have to grow out of the Petroleum Branch of the London County Council. It was sensible that the L.C.C. Petroleum Branch should be made responsible for the pre-planning of the G.L.C. Petroleum Branch.

Pre-Planning Serious pre-planning started as soon as the first Greater London Council was elected in April 1964, i.e. some twelve months before D-day on 1st April, 1965. The first thing to be done was to settle some broad lines of policy. It would be tedious if I tried to distinguish in this narrative between Council, Committee and officer decisions; you are all local government officers and will need no guidance on this score.

Scope of Enforcement The first matter to be decided was the scope of work to be undertaken. Some of the were at that time concerning themselves o.nly WIth the petroleum store. The Greater London however, recognised that the 'or hazards eXIsted m the use of petroleum spirits and mal . tures in ft' manu ac urmg d"l an SIml ar processes. It was efore decided that the Council's Hcences should cover , er as well as storage, that is, that licences should deal use with all keeping up th to' e t f momen 0 d" . lsslpatlOn or removal from the premises.

Modus Operandi It was laid down as policy that applicants forlicences should be clearly 'informed by letter of the conditions which would be attached to their licences and of the works which they would have to complete satisfactorily before a licence was issued. In some cases works required involve a great deal of money and it is proper that an applicant should not only be in a position to know exactly what he is committed to doing before he proceeds but, if he thinks the authority is being unreasonable, to exercise his right of appeal to the Secretary of 'State at the earliest possible moment. General Administration This decision meant that the amount of paper work involved in petroleum licensing would not be inconsiderable. It followed that sensibly an administrative section should be formed to relieve technical field staff of detailed paper work. To make the maximum use of field staff time and save losses due to excessive travelling, it was decided that field staff should be allocated a particular district, should work from home and should report in writing daily to Head Office. Various report forms were devised to keep the amount of writing to a minimum and to ensure that only essential information was transmitted. Clerical processes can take up an awful lot of time unless they are kept under tight control. Overall policy control and direction was vested centrally with the administrative staff supported by executive and clerical officers. This enabled much of the routine process of determining requirements and granting and amending licences, etc., to be delegated to the Head of the Petrol'eum Branch.

Licence Conditions By devising special types of licences to match various types processes and premises it was possible to ',tailor lIcences to fit those premises and processes with the, mmimum use of 'ad hoc' conditions. The more usual 'ad hoc' conditions were put on to punched tape so that they be to licences by feeding the tape into an typeWrIter. Some special licences were not to justify printing. Once again the. 'standard of these licences were taped to mahc reprodUction on blank licence sheets. SlffiI1arly 'approval' and other standard types of letters were tap.ed to reduce the mechanical side of letter writinp to a mmimum. By the Use of a 'Stop' code on the tape and other techniques Words and phrases could be inserted and paragraphs and conditions selected at will. The actual ing of licences and letters is done on stencilled sheets. It IS worth while adopting this system of drafting whether or translation to the finished article is by automatic typewrIter because of the time and effort it saves.

Validity of Licences All necessary office procedures were scrutinised to reduce' clerical processes to an absolute minimum. If savings were to be made then preferably this had to be at the of office staff rather than field staff. This was ,a factor m determining that licences should be valid for three and that the chore of renewing licences 'should be sp:.: as evenly as possible over each month of each of the t f e years. The result of spreading the load is that only a e: hundred licences fall due for renewal each month out the three year period which is much better than trymg to cope with a few thousand all at the same time.

Specialised Plant and Equipment In an attempt to ensure consistency and to speed general work processes it was decided that one division would deal centrally with all items of equipment such as and spraying equipment which would find general use the whole of Greater London. This section would deal directly with the manuf.acturers of the equipment and once they had cleared points with the makers would inform inspectors of the conditions under which such eqUlpment might be accepted for use at licensed premises as well as the special points to watch.

Districts There were considerable advantages in allocating each inspector toa set district rather than letting him deal with jobs as they arose and, as I have already indicated, this was the course which was adopted. It was recognised, however, that many of the inspectors would be new to the job and that it would be necessary to arrange for them to be a:ided, advised and supervised by an experienced senior inspector. Thus districts were grouped into areas over each of which a senior inspector exercised ,a supervisory function. Each senior inspector was in addition given a small district of his own. Moreover he was made directly responsible for all the more complicated and difficult cases in his area, to the exclusion of the inspector in whose district !the premises lay. This ensured the best use of available expertise. Nevertheless, senior inspectors are encouraged to take district inspectors from time to !time ,to the complicated 'reserved' cases 'on their districts, partly as a training exercise and partly so that the district inspectors can oversee works at the premises if the senior -inspector is not available.

Tank Wagon Inspections Distributing depots fall into the class of case reserved to senior inspectors. It is at these depots that tank wagons are for the most part garaged and based. It was therefore arranged that senior inspectors should be responsible for the annual detailed 'strip-down' inspections of tank wagons based and operating in Greater London. District inspectors however are required to carry out 'casual' examinations of any tank wagons which ,they meet in the course of their normal inspections. The prime purpose of these 'casual' examinations is to check on the wagon under operational conditions.

Assessing the Work-load A first priority in pre-planning was to obtain some idea of the probable work load. This was necessary if a reasonable estimate of requirements for staff, office space, file shelving, etc. was to be obtained. All sixty authorities could have been asked to supply figures of their licensed cases but surprisingly at this distance there were political reasons why this could not be done 'immediately. Instead recourse was made to public libraries where the v-arious Council Minutes were assiduously read. Even so, full information could not be obtained and an estimate had to be made. It was predicted that there would be one petroleum licence per 900 head of population and in the result this proved to be surprisingly accurate assessment giving as it did a probable figure of 9,086 licences as against an 'actual figure of 8,972 licences. In London :the Petroleum Branch has other Local Act duties so it was decided that the work-load for each district inspector should be 300 licenced premises and for senior inspectors 200 licensed premises. (This ideal was not exactly achieved because it was also convenient to avoid so far as possible splitting London Boroughs between two inspectors). It was thus apparent that the G.L.C. would require 26 district 'inspectors and 6 senior inspectors. (These numbers have since been slightly varied to 24 district inspeotors and 7 senior inspectors). There was no easy way of determining the ,administrative, executive -and clerical staff required to man the Branch's Head Office. The increase factor as between the L.C.C. area and Greater London was 2.6. However, it was proposed to introduce a number of labour saving procedures in the office. Initially, the number of office staff was determined by multiplying the L.C.C. staffing by a factor of two. Later, after the first impact of reorganisation had been absorbed it was found possible to further reduce this number. Nowadays there a're many techniques for measuring office work and staffing the office side of a Petroleum Branch should present few problems once the overall method of working has been decided.

Once one has determined the number of licence cases and office staff requirements it is a relatively simple arithmetical exercise to express this in terms of office accommodation and furniture needs.

Training Before I finally leave the question of staffing the ne,w Petroleum Branch, I should mention that the G.L.C. was faced with a short-fall of 21 petroleum inspectors. It was decided to arrange a course of training starting from 1st January, 1965, i.e. three months before 'D' or Re-organisation Day. The course lasted 12 weeks and on the -academic side consisted of a series of lectures on specialised aspects of the work by senior staff of the L.C.C. and two full days and one evening attendance per week at a Technical College where the elements of Building Construction, Chemistry, Electrical Engineering, Hydraulics and Hydrostatics were disseminated. Each L.C.C. inspector took two trainees under his wing for up to three days per week to provide the essential practical experience of inspection. The trainees were selected from applicants employed in local government in Greater London as weights and measures inspectors, building inspectors, shops acts and explosive inspectors, public health inspectors and firemen. Delegation The Council decided to delegate the functions of granting, renewing and amending petroleum licences to officers. To set bounds on this delegation Standard Conditions and broad Principles of Construction for the different types of keeping and use were laid down. It was decreed that only major departures from the conditions and principles need be referred to the appropriate committee of the Council for decision.

Preparing the Paper Work Once the standard conditions and principles of construction were approved, the way was open for licence blanks, abstracts, leaflets, hand-outs, etc. to be prepared and print-

cd. Tape for the automatic typewriter was also prepared to cope with letters and the addition to licences of 'ad hoc' conditions. More important than this, however, it was now possible to write detailed instructions and notes for the guidance of inspectors; these inspectors would be working on their own largely unsupervised 'and 'it was therefore essential that they should be able to outline the Council's probable requirements with confidence. In preparing the instructions and notes this prime purpose was kept in mind. There was no attempt to write an inspectors' bible to cover every conceivable s'ituation. The more usual aspects, say 95% of the problems likely to arise were covered, but even so it was made clear that alternatives were not necessarily excluded, When alterna-tJives were proposed ,the facts had to be reported to Head Office for decision. This in effect also helped to ensure consistency of approach and ,application throughout Greater London. Automatic Renewal of Licences It became apparent 'at a very early stage that many petroleum licences in Greater London expired on 31st March, 1965 and therefore fell due for renewal on '0' day itself. To have attempted normal renewal on '0' day would have been a virtually impossible task. The Minister was therefore persuaded to make an Order extending the period of currency of any licence expiring 'between 31st March, 1965 and 30th June, 1965 to 30th June, 1965, thereby ensuring that no petroleum licence required renewal until 1st July, 1965. I cannot over-stress the advantage of this three months moratorium. Without it there must have been real chaos. I would urge you most strongly to ensure that similar provision is made in your re-organisation.

Getting the System to Work The three months was used in different ways by the inspectorate and the head office staff. The inspectors were concerned to identify the licensed premises on the ground, to introduce themselves to licensees and to explain to the licensees the new address to which they should submit applications for alterations, extensions, etc. To assist him in this exercise each inspector was given a printed slip to hand to each licensee with the request that it be kept with the licence.

At his initial visit the inspector was also able quickly to assess the general standard and to identify those premises that were so horrific that at first sight the licences should not 'be renewed. Strangely enough most licensees when the dangers were pointed out to them accepted the position and voluntarily surrendered their licences. In two cases the council had formally to refuse to licence the premises. One of these two licensees decided to appeal against the council's decision; the ,appeal was subsequently denied by the Home Office.

Assimilating Records While inspectors were :he 'feel' of their districts, Head Office staff were asslmIlatmg the records from the 60 constituent former Councils, preparing licensing lists and generally trying to rest?re orde.r out of sheer unadulterated chaos. Before '0' day lists of lI.c7nsed cases were obtained fromaII 60 constituent authOrities. From these lists each premises was allocated a registered number the first two digits of which indicated the London Borough. Three loose leaf ledgers were prepared, one in numerical order, one in alphabetical order of the name of the licensee and the other in alphabetical order of the address of the licensed premises. A copy of each sheet in the alphabetical register was sent to the appropriate district or senior inspector so that he could prepare suitable 'route' slips 'in respect of each of his premises. The only available data on each slip at that time was name, address, quantity and date of renewal. File covers bearing ,the premises registered number and address were prepared for each licensed premises at the same time as the registers. As records were received from the old authorities they were placed appropriately in these folders. On or about '0' day all records and furniture had to be transported by removal men already overloaded by the demands from other offices. The result was that despite the most careful and detailed instructions most of the furniture, records, etc. ended up dumped in a pile in the middle of the largest available room. As soon as this mess was cleared, and it took a couple of days, preparations had to start on the process of renewing all the licences expiring on 30th June, 1965.

The first Renewal

It had 'been -apparent from the first that a licence on G.L.C. conditions could not be granted in respect of particular premises until a full survey of those premises bad been made-it had been suspected and proved to be true some authorities had no drawings or details of the premises which they licensed. All data relating ,to these premises had apparently been locked away in the mind of ,the former petroleum officer, Who now had dis-appeared into the maelstrom of Greater London. In other cases a single set of drawings submitted for approval under the Petroleum (ConSOlidation) Act 1928 and other Acts was ,taken for use under those other Acts. Thus the first renewal of a licence by the G.L.C. had to be made on the conditions attached by the former licensing aU'thol"ity. Once it was clear that 'a premise did not fall into the 'horrific' clasS process of inviting renewal followed automatically. ThiS first renewal was for varying periods and ,the periods were so 'arranged that the renewals expired at the rate of a few h d d un re . ID each month of the next ,three rs yea. I have d already explained this device for spreading the work-loa of renewal.

LicenSing on the Council's Conditions Th e second renewal of a licence by the LG. c . . was on the f 11 d't' con I Ions approved by the Council. . ThiS ant me that a u until new licence had to be issued. This could not be the premises concerned had been fully surveyed. . es the survey threw up the many deficiencies at some premls . These basically fell into three categories ;(a) those deficiencies which could be easily and cheaply remedied; (b) those deficiencies which were of such a minor nature that they could be ignored; and (c) those deficiencies which could not be remedied without major redevelopment of the premises.