Rejoinder: Cylinder Recirculation Model (CRM) policy – Over 1300 Storage Tanks and Brv’s

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I read the article by Festus William Ameyaw of Express Gas Ltd. in your paper (B&FT) of 16/08/2024 and found it not only amusing but utterly intriguing.

It becomes even more amusing when one knows from which angle the writer is pursuing the CRM matter. Oh yes, as a Manager at Express Gas Limited.

It is recalled that, well before the CRM policy even gained public attention, the writer’s company, Express Gas had imported into the country cylinders branded in its name. Additionally, the company had purchased lots of LPG trucks ready for the CRM. And in an attempt to capture the LPG market, the company invaded the Existing LPG stations market and bought, leased or partnered at whatever cost.



Therefore, the present slow or non-implementation of the CRM obviously is a matter of serious financial concern to the company. No wonder the sudden death of the owner sparked all sorts of spurious stories. It is against this background that his writings on the CRM should be viewed and understood.

But what is CRM? According to the writer, CRM simply means, users of LPG will not have to own cylinders as pertains in the market to-day.

Per the policy of the NPA, current users of LPG will be required to swap their existing cylinders for new ones from LPG Bottling Plants which entirely own and brand the cylinders. But in all honesty and fairness, how can merely swapping of cylinders cause or stop explosions?

The truth of the matter is that for close to thirty years that the Existing Plants have been operational, there has been only two explosions, the Trade Fair Site in December 2016, and the Atomic Junction in October 2017. It is the latter which has been cited extensively by the Authorities to justify CRM but, woefully without success.

It may be necessary to refer to the report of the Private Sector Safety Technical Committee (PSSTC) which investigated the explosion at the Atomic junction in August 2018. The report concluded that CRM is not a panacea to safety and that manual refilling of cylinders has not caused a single LPG explosion in the country. The report noted that discharging LPG from BRVs to station Tanks was the primary cause of explosions. It is noteworthy that this conclusion was also confirmed in both the NPA report on the Atomic junction explosion and its Public Notice of January 2017 on La Trade Fair fire.

The PSTC report also confirmed a long-standing Research findings which list safety risks associated with CRM as follows;

  1. The concentration of already filled LPG cylinders at stations increases the risk of liquid leaks from cylinders which will be difficult to detect and manage. It is well-established fact that liquid leaks are greater source of hazard than vapor leaks.
  2. Empty cylinders that are left in the open space will admit air. In this way an ignitable mixture that can be very hazardous is formed.
  • Ferrying already filled LPG cylinders on trucks on highways represents a significant road safety hazard as seen in countries like France, Russia, and India which have witnessed LPG explosions involving cylinder trucks on highways

As a matter of fact, the writer heavily and expensively departed from the truth when he tried to justify the movement from the Existing Filling Plants (EFP) to CRM when he claimed that there have been series of explosions at various filling stations in the past.

The truth is that there has not been a single gas explosion at any Existing Plant since 2017. It is equally noteworthy that this feat has been achieved through the active collaboration between the LPG Marketers, NPA, EPA, GSA, Atomic Energy, Energy, Fire Service and Factories Inspection Directorate whose very hard working and knowledgeable staff regularly conduct physical inspection of Existing Plants to ensure that safety is never compromised before issuing out Licenses which also come at a great cost.

Another factor contributing to this explosion free environment is the fact that the LPG Marketers Association (LPGMCA) has made it compulsory that BRV’s discharge gas at LPG stations using only ELECTRIC DISCHARGE PUMPS and not the old practice of using BRV Engines which, invariably, are over-heated after long journeys thereby causing explosions even in any remote contact with the discharging gas. So, what is the basis or why call for a change to CRM when a solution has long been found to the explosion problem?

On the contrary, accidents at Bottling plants causing more horrendous damages to life and property are very common in the LPG Industry. Even in developed countries. The same may be said of accidents involving cylinders being transported inter and intra countries. At our local scene, one cannot but sadly, and even morbidly recall the ghastly and costly incident at Apiatse in the western region about four years ago where a whole village was burnt to ashes not excluding heavy human casualties. To date, the ravages still haunt the community as promises made by the Authorities are yet to be fully kept

Again. the writer acknowledges that LPG is a composition of Butane and Propane and can travel long distances to a point of ignition and flash back. Additionally, he also admits that butane readily forms a flammable mixture with air.

Notwithstanding all these frightening cautions, he still supports the idea of filled cylinders being put in cages, and, as currently observed, displayed under heat at all Existing Petroleum retail stations including even shops. Ironically, he concludes that “And if a cylinder is defective and leaking (from the valves) it could cause a volatile explosive atmosphere and life and safety hazards WITHOUT US BEING AWARE (emphasis mine)”.

Even putting aside the factual inaccuracies and, without any empirical evidence, the writer shockingly calls on “stakeholders in the industry not to sit aloof looking on without action. The lack of action is likely to come with serious and devastating consequences which the country may never forget”

By the very nature of CRM. It is highly capital intensive. That makes it mostly a preserve of foreigners to the total neglect of local nationals who are employed as hewers of wood and drawers of water. By this unenforced arrangement, huge sums of foreign currencies are repatriated out of the country as profits every year by these foreign and semi-foreign companies. It is therefore interesting to reveal that not even one dollar has gone out of the country for the full thirty years of the operation of the Existing LPG plants.

Meanwhile over $400 million in investments have been made by INDEGEMOUS GHANAIANS while employing over 10,000 Ghanaian workers. It may be needless to add that the present close to 30% use of LPG in the country has been achieved solely by the Existing Plants without any involvement of the CRM. Therefore, to suggest 50% LPG penetration by 2050 is achievable, without the input of Existing plants scattered all over the country, is to expose one’s naivety.

What is not known to the public or hidden from the public is the fact that nationals from Ivory Coast, Nigeria, Kenya etc. etc. which are practicing the CRM are regularly trooping to Ghana to copy our Existing LPG plant.

Indeed, even some of the so-called foreign experts brought into the country by the NPA come to our stations rather to copy our system and extensively take photographs with them. It is therefore a very disturbing situation clearly confirming that we are definitely swimming against the tide.

To pave way for the introduction of the CRM, the writer recommends the decommissioning of Existing Plants. He therefore calls for the setting up of a Decommissioning Fund, but in a sudden U-turn, admits that decommissioning comes at a cost for which at the moment is not factored in any policy by the various Ministries, Departments and Agencies connected to the Sub-Sector.

In furtherance of his Decommissioning approach, he proposed that the Authorities buy a land/site for De-commissioning of petroleum related wastes such as the over 1300 tanks of different sizes and weights scattered over the length and breadth of the country, dispensers, pumps etc. the total cost of which he claims is to be realized by adding small margin to the Petroleum Price Build up formula.

At a time that the consumption of LPG has drastically gone down because of the very steady high prices? Fortunately, the writer acknowledges that “the main problem lies in the introduction of CRM”. So why blame the Existing LPG Plants?

Apparently, trying to figure out a solution to the problem, the writer calls for “a parallel system” (emphasis mine) in place for about 5-7 years depending on which stakeholder you will engage”. But why peg the years when other countries in the world, according to the writer, are safely and cost-effectively doing CCCM? Why not peg CRM too if the two systems are to run parallel?

You want to accuse the LPGMC Association of not cooperating with the NPA in the implementation of the CRM? That’s a palpable and blatant lie. Right from day one, the Association has held several meetings with the NPA, joined NPA staff on its regional and, even international tours and even allowed the NPA to use some of the existing Plants for its pilot projects. Even at this critical moment, the Association is only asking for a PARALLEL SYSTEM where both the CRM and Existing plants will compete. That is even when the NPA had shown itself to be financially insolvent towards the cost of De-commissioning of over 800 Existing Plants in the country

The writer is only trying to deflect attention from a closer look at the underlying commercial relations and objectives of the CRM. He may very well be advised to take a second look at the realities on the ground and COMPETE in the parallel system as agreed with the NPA. COMPETITION is the name of the game. And also, the spirit of the constitution.

E.D.M Stephens

The writer who is a retired Assistant Commissioner of Police (ACP Rtd) is with Kaysens Gas Co. Ltd & Chairman of PSSTC.

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