Fuel Delivery Exclusion Zones: What Actually Counts as Compliant?

Key Takeaways

• Cones and stickers alone do not make an exclusion zone compliant if they do not physically control entry.
• Regulators focus on whether the zone is actually effective, not just visibly marked.
• ADG Code 7.9 and EPA guidance require ignition sources and the public to be kept out of the transfer area.
• The main compliance risk is the gap between marking a zone and preventing access to it.
• Sticker-based systems have limits in visibility, placement, and enforcement.
• WHS duties require the highest reasonably practicable level of control.
• Physical barriers like containment fencing provide stronger, defensible access control than cones alone.
• Signage is more effective and compliant when attached to fencing rather than cones.
• A compliant system must combine visibility with physical prevention of entry.
• The key test is whether the exclusion zone would still hold under real operating conditions.

If you’re a fuel transport operator, you already know the drill. The tanker pulls up, cones go out, and the transfer begins. Job done.

The problem is that many exclusion zones are set up in a way that may look organised without giving the operator a strong compliance position if something goes wrong.

This is not about nitpicking. It is about what happens when a vehicle enters the transfer area, a customer gets too close, or a regulator starts asking whether the control was actually effective.

The gap between “we put cones out” and “we controlled access to the exclusion zone” is wider than many operators realise.

Here’s what you need to know.

What the Regulations Actually Say

Service station forecourts are not informal loading zones. They are active traffic environments where customers, staff, pedestrians, and vehicles move around the tanker while dangerous goods are being transferred.

In NSW, the Road Rules note that a road-related area or adjacent land can include a service station. In Queensland, the road rules apply to vehicles and road users on roads and road-related areas, including public parking areas. That matters because fuel delivery controls need to work in a real traffic environment, not just on paper.

Operators are not dealing with one rulebook. They are dealing with dangerous goods requirements, environmental guidance, road traffic control requirements, and WHS duties at the same time.

ADG Code 7.9: Keep People, Vehicles, and Ignition Sources Out

ADG Code 7.9, Chapter 10.2, became mandatory from 1 October 2025. It governs the bulk transfer of Class 3 dangerous goods, including petrol.

For petrol transfers, the operational point is clear: ignition sources need to be kept away from the transfer area. NSW EPA guidance states that all vehicles are sources of ignition, all ignition sources must be excluded for 3 metres from hose connections while tankers are transferring fuel, and the exclusion zone must be clearly marked with cones or other barriers that prevent vehicle entry. 

A cone that suggests “please don’t enter” is not the same as a control that prevents entry. If a customer vehicle can easily slip between cones into the transfer area, the operator may have a weak position if asked to show how entry was controlled. 

NSW EPA: The Zone Must Be Physically Protected

The NSW EPA does not simply ask operators to mark an exclusion zone loosely. Its guidance says the exclusion zone must be clearly marked with cones or other barriers that prevent vehicle entry.

It also states that where underground tank fill points are within the service area, the lane on the outlet side of the tanker must have bowsers shut down and be blocked off while the tanker is transferring fuel.

The real question is not, “Was something visible?”

The better question is, “Was entry controlled?”

A few cones and a hopeful staff member waving cars away may not be enough to demonstrate that. 

WHS Act Section 19: Visibility Is Part of the Duty

The WHS Act Section 19 requires a PCBU to ensure, so far as is reasonably practicable, the safety of workers and members of the public.

In an incident investigation, the issue will not be whether the site “usually” has a process. The issue will be whether the control in place at the time was adequate, visible, and effective. Where controls are found to be inadequate, businesses may also face regulatory penalties, fines, and enforcement action under WHS obligations. 

That detail matters.

A marking that disappears at night, washes out in rain, or cannot be seen from a driver’s seat does not pass the reasonably practicable test. If the warning cannot be relied on when conditions are poor, it is not much of a warning.

The December 2026 WEL Transition Raises the Stakes

The WEL transition will increase scrutiny on airborne contaminant exposure, including petrol vapour risks. From 1 December 2026, Australia will adopt the Workplace Exposure Limits list, replacing the current Workplace Exposure Standards framework.

Benzene remains a chemical under further impact analysis before its WEL limit is updated. Safe Work Australia lists benzene among the chemicals requiring additional impact analysis, separate from the 33 identified non-threshold genotoxic carcinogens.

The practical point still stands. Petrol vapour exposure is a serious risk, and exclusion zones should not rely on weak controls that allow public entry during transfer. 

AS 1742.3 and the Queensland MUTCD: Cones Are Not a Blank Canvas

Traffic cones are traffic control devices, not spare advertising space. The Queensland MUTCD Part 3 states that logos and markings may be used on cones and bollards for identity purposes only and must be limited to the non-retroreflective surface areas of the device. That is a major issue for sticker-based warning systems.

If a warning sticker is placed on a cone, the operator needs to be able to show that it does not cover or interfere with the retroreflective band, does not alter the approved function of the cone, and remains visible enough to support the intended control.

That should not be assumed. It should be checked against the relevant standard, state traffic control guidance, the actual cone design, and the site conditions.

A cone is not compliant just because it is orange. A warning is not effective just because someone printed it in bold.

The Problem With Stickers

Some operators add a sticker to an existing traffic cone because it feels cheap, simple, and practical. The problem is that a sticker may not be enough to demonstrate effective exclusion.

Here’s why.

1. The usable space is limited 

Because markings need to stay off the retroreflective areas of the cone, the available space for a warning message may be limited. On many cone designs, that leaves little room for a message that can be read quickly by a driver moving through a forecourt.

Operators should verify the cone model, sticker placement, and visibility requirements before relying on a sticker-based warning. 

2. The message may sit outside the driver’s natural line of sight 

A sticker placed low on a cone can be easy to miss, especially once a vehicle is already approaching the exclusion zone.

Forecourts are visually busy. Drivers are dealing with pumps, signage, pedestrians, other vehicles, turning space, headlight glare, and weather. A small message on a cone does not always get seen when it matters.

3. The sticker may not perform at night or in poor weather 

If the sticker must sit on a non-retroreflective part of the cone, it may not give the same visibility as the cone’s approved reflective treatment.

That matters at night, in rain, or under forecourt glare.

A warning that cannot be relied on in poor conditions creates a weaker compliance position than a physical control that remains obvious and effective.

4. Stickers communicate. They do not physically control access. 

This is the main issue.

A sticker can help communicate a warning, but it does not stop a vehicle from entering the transfer area. If vehicles can still drive between cones, the setup may still fail the practical test: Was vehicle entry actually controlled?

That is where sticker-only systems become vulnerable.

5. It may still fall short of the NSW EPA test 

The NSW EPA test is practical: the exclusion zone must be clearly marked with cones or other barriers that prevent vehicle entry.

A small sticker on a cone may help communicate a warning, but it may not be enough by itself if vehicles can still drive between cones into the transfer area.

What a Defensible System Actually Looks Like

ADG 7.9 and NSW EPA guidance do not prescribe one exact layout for every site. They do, however, point operators toward an effective system of work that clearly identifies the exclusion zone and controls entry.

The standard to aim for is simple: Control the entry points. Physically restrict vehicle access. Make the warning visible.

The WHS Act hierarchy of controls matters here. A sticker on the base of a cone is an administrative control, the lowest rung of effectiveness. It relies on a driver seeing and reading a small, non-reflective marking at ground level. That is a weak position to be in when a regulator is asking questions.

Physical containment is a higher-order control. It does not rely on a driver choosing to stop. It stops the vehicle. Under the hierarchy, that is where your primary control should sit.

Both Transport for NSW and Queensland Transport and Main Roads confirm that the safest option for service station forecourts is the elimination of the risk of entry. Their guidance specifically identifies containment fencing, bunting, safety flagging, and barrier mesh combined with signage as the appropriate approach for physically restricting access to a work area.

The Containment Fencing Solution

The fix is straightforward. Your existing orange traffic cones stay where they are. What changes is how they are connected and what is attached between them.

1. Keep the standard cones for the perimeter

Your existing cones continue to mark the exclusion zone perimeter. They remain untouched, compliant with AS 1742.3, and doing the basic delineation work they were always intended to do.

2. Connect them with containment fencing

Containment fencing barrier mesh or safety flagging is run between the cones to form a continuous physical barrier around the exclusion zone. This transforms the setup from a row of individual delineation devices into a connected hard barrier that a vehicle cannot simply drive between.

This is the critical difference. Cones alone delineate a space. Cones connected by containment fencing help restrict access to that space. That distinction is the difference between an administrative control and an isolation control under the WHS hierarchy.

Containment fencing, barrier mesh, bunting, and safety flagging are commonly recognised in traffic and worksite control guidance as ways to help separate people and vehicles from work areas. Operators should confirm the exact device and setup against the relevant state guidance and applicable standards.

3. Attach compliant signage to the fencing, not the cones

Signage must identify the hazard and communicate the exclusion. Under both NSW and Queensland requirements, signs must not be attached to the traffic cones themselves, as this would cover the reflective band or alter the approved device configuration. The wording, visibility, symbol selection, and placement of safety signs all affect how clearly a hazard is communicated in a live traffic environment.

Instead of modifying the cones or covering reflective areas, attach signs to the containment fencing.

That allows the cones to keep doing their traffic-control job while the fencing carries the exclusion warning.

The sign message should be unambiguous, for example, NO ENTRY or FUEL DELIVERY IN PROGRESS, and should face approaching traffic from both directions.

4. Why does this satisfy each standard

5. Setup remains fast

The fencing clips or ties to the cones as they are placed. No tools required beyond what is already part of the driver’s setup kit. The addition of fencing adds minimal time to the cone-out process while materially lifting the compliance and defensibility of the system.

The Bottom Line: Before Something Goes Wrong

A non-reflective sticker on a traffic cone is not an exclusion zone.

It may help communicate a warning, but it does not physically prevent entry. If the sticker is small, low, hard to see, or placed where it cannot be read in real driving conditions, it may offer limited protection in an incident investigation.

Cones alone delineate. They do not necessarily exclude. The containment fencing system addresses that directly. The cones stay. The fencing connects them. The signage identifies the hazard at eye level. The zone is physically controlled, not just suggested.

If you are responsible for fuel delivery operations, the question is simple: if something went wrong tonight, could you defend the controls you had in place?

Review your current setup. Check whether your exclusion zone physically prevents vehicle entry, whether your signage is visible at night, and whether you can demonstrate that the control you chose was at the highest reasonably practicable level. If the answer is unclear, it is time to tighten the system.

Get in touch with us to review your exclusion zone setup and find out how the containment fencing system can bring your forecourt controls up to standard.