Discussion Paper

Density Measurement in the Retail

Sale of Liquefied Petroleum Gas

November 2016
Contents

Introduction ................................................................................................................ 3
The National Measurement Institute........................................................................... 3
Stakeholder Consultation ........................................................................................... 3
Submissions ............................................................................................................... 4
Background ................................................................................................................ 4
LPG Dispensers .................................................................................................................................. 4
Temperature Compensation ................................................................................................................ 4
The National Trade Measurement Regulations 2009 ......................................................................... 5

Current Requirement .................................................................................................. 5

Alternative Methods.................................................................................................... 5
Questions ................................................................................................................... 6
Next Steps.................................................................................................................. 6

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Introduction
The purpose of this discussion paper is to commence a review of the current requirements relating to
the measurement of Liquefied Petroleum Gas (LPG) density when supplied for retail sale. More
specifically, this paper is intended to seek stakeholder submissions regarding current pattern approval
requirements for LPG dispensers relating to the measurement of LPG density.
The discussion paper provides an overview of the current requirements and requests stakeholder
submissions regarding possible amendments and improvements to these requirements. In support of
such amendments, the discussion paper also seeks stakeholder proposals regarding innovative or
alternative methods for measuring LPG density which would reduce the overall regulatory burden on
Australian industry while continuing to ensure fair and equitable measure in the retail sale of LPG.
NMI welcomes all stakeholder submissions regarding the current requirements for LPG dispensers as
they relate to the measurement of LPG density. However, the following requirements are considered
to be outside the scope of this discussion paper:
1. the Accuracy class applicable for LPG dispensers (Class 1); and
2. the requirement to correct the volume of LPG to 15C at equilibrium vapour pressure.

The National Measurement Institute

The National Measurement Institute (NMI) is the Commonwealth Government agency responsible for
the administration of the national trade measurement system. Key elements of this system are the
pattern approval and verification of measuring instruments used for trade, including LPG dispensers.

Stakeholder Consultation
NMI has received submissions from a number of stakeholders regarding the issue of density
measurement in the retail sale of LPG. More specifically, the submissions focused on the requirement
for LPG dispensers to incorporate a means of directly measuring density, thereby allowing for the
volume of LPG to be corrected for temperature variations.
NMI is committed to being a responsive, responsible and best-practice regulator. As such, we
recognise the importance of reviewing our requirements over time to ensure that they are still
achieving the intended objective and are providing an overall benefit to Australian industry and the
wider community.
To commence this review, NMI is seeking stakeholder submissions and comments on the
appropriateness and effectiveness of the current requirements for LPG dispensers and whether these
requirements could be amended to support alternative methods for the measurement or determination
of LPG density.

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Submissions
We encourage those who have a view on the issues and questions outlined in this discussion paper
to make a written submission by Friday 16th December 2016.
Submissions can be lodged using any of the following methods:
Email: NMILegalMetrologyPolicy@measurement.gov.au
Website: https://consult.industry.gov.au/
Mail: Legal Metrology Policy
National Measurement Institute
PO Box 264, Lindfield NSW 2070 Australia
Submissions received may be made public on the Department of Industry, Innovation and Science
website and the NMI website unless otherwise specified. Submissions received may form part of
subsequent response papers and project proposals.
Submissions should indicate whether any part of the content should not be publically disclosed.

Background
LPG Dispensers
The retail sale of LPG, particularly as a transport fuel, most commonly occurs via the use of a
dedicated LPG dispenser, which incorporates a flow meter, calculator/indicator, temperature probe,
density probe, indicating device, hose and other components.
In order to be used for trade in Australia, LPG dispensers are required to be pattern approved, verified
and operate with a measurement error no greater than 1% of the volume of LPG that is dispensed
and sold.
This maximum permissible error (MPE) is specified in the international standard OIML R 117 Dynamic
measuring systems for liquids other than water, which is adopted in Australia as the pattern approval
standard for flow metering systems such as LPG dispensers.
In order to ensure that an LPG dispenser operates within the MPE of 1%, as required by the
international standard, the flow meter is provided an MPE of 0.6% of the volume dispensed. As such,
the remaining operations of the dispenser, which primarily includes the calculation of volumetric
corrections based upon measurements of temperature and density, must be accurate to within 0.4%
of the volume dispensed.

Temperature Compensation
When LPG is sold at a price based on volume (e.g. cents per litre), it is important that the volume of
LPG dispensed is corrected to the equivalent volume at a standard temperature in this case 15C.
This accounts for the variation of volume with temperature, and ensures fair and equitable trade of
LPG across Australia regardless of the temperature of the LPG being sold. The compensation
correction depends on the density of the LPG, which varies in turn with the composition of the gas.

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The National Trade Measurement Regulations 2009
The National Trade Measurement Regulations 2009 (Cth) require that where LPG is sold by volume,
it must be sold by the amount of litres that it would occupy at a temperature of 15C at equilibrium
vapour pressure.
In other words, where LPG is sold by volume there must be a correction applied to the measured
volume of LPG (at any temperature) in order to determine the volume the LPG would occupy at 15C.
In order to perform this volume correction, measurements of LPG temperature and density should be
made. These measurements are used by the calculator/indicator of the dispenser to provide an
indication of corrected LPG volume at 15C. It is this corrected volume that is used for trade
purposes.

Current Requirement
In order to satisfy the requirement that LPG be sold at a volume corrected to 15C, NMI requires that
LPG dispensers include a means of directly measuring the temperature and density of the LPG
flowing through the dispenser. In the case of LPG density, this may be achieved by the use of a
density probe, fitted in the dispenser. Alternatively, dispensers may incorporate a mass-flow meter
which measures density as part of the mass-flow measurement process.
Compliance with this requirement is assessed during the pattern approval examination of the design
of LPG dispenser. In order to be pattern approved, LPG dispensers are required to incorporate a
means of measuring the density and temperature of the LPG being dispensed and sold.
The use of density probes and mass flow meters in LPG dispensers provides for a consistent and
effective means of compliance with this requirement.
The current requirement was formally introduced in 1997 as a result of the adoption of OIML R 117,
with exemptions provided for LPG dispensers approved prior to that date. In practice, this means that
all LPG dispensers approved after 1997 include a means of measuring LPG density, either via the
use of a density probe or a mass-flow meter.

Alternative Methods
NMI is seeking stakeholder input and proposals regarding viable alternative methods of measuring,
determining or accounting for LPG density, other than via direct measurement by a density probe
incorporated in the dispenser.
Any viable alternative method would need to ensure that the overall MPE of the dispenser does not
exceed 1%, and that the measurements and calculations required for the temperature correction of
LPG volume do not exceed 0.4%.
NMI is also seeking stakeholder comments regarding whether any viable alternative methods would
necessitate amendments to the current requirements in order to be implemented. Finally NMI would
welcome stakeholder comments regarding potential costs and benefits that would result from any
viable alternative methods.
It is anticipated that any potential innovative or alternative methods would aim to reduce the overall
regulatory burden on Australian industry while maintaining fair and equitable measurement in the
retail sale of LPG.

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Questions
NMI welcomes all stakeholder submissions regarding the current requirement for LPG dispensers to
include a means of measuring density as well as proposed alternative methods of measuring or
determining density in the retail sale of LPG.
In addition to any general submissions on the topic, NMI encourages stakeholders to provide answers
to the following questions:

1. Should the current requirement to include a means of density measurement (e.g. via a
probe) in LPG Dispensers be maintained? If so, why?
2. What are the current costs and/or savings incurred by your business as a result of this
requirement?
3. What are the current benefits realised by your business as a result of this requirement?

4. Should the current requirement to include a means of density measurement (e.g. via a
probe) in LPG Dispensers be amended? If so, why?
5. If so, what alternative methods could be developed and implemented to directly measure,
determine or otherwise account for LPG density in order to ensure ongoing correct measure
in the retail sale of LPG?
6. What are the costs and/or savings that would be incurred by your business as a result of
such alternative methods?
7. What are the benefits that would be realised by your business as a result of such alternative
methods?

Note: Any alternative methods would need to ensure the maximum permissible error of the
LPG dispenser does not exceed 1% (as per OIML R 117).

If your company supplies and/or purchases LPG:

8. How many LPG dispensers do you maintain on your site(s)?
9. What is the average quantity of LPG that your company supplies and/or purchases per
year?
10. How frequently is LPG delivered to your site(s)?
11. Does the density of the LPG that you supply and/or purchase vary from delivery to delivery?
12. Are you able to supply information on the range of LPG densities that your company
supplies and/or purchases?

Next Steps
NMI will undertake a thorough review of all submissions received to this discussion paper, and
release a response paper. Depending on the nature and content of the submissions received to this
discussion paper, subsequent consultation processes may be required in order to complete the
review.
NMI will advise all interested stakeholders of any subsequent consultations if and when they occur.

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