Inspection and Testing of Dangerous Goods Road Tankers

Road tankers carrying fuels, chemicals and gases are designed, constructed and maintained in accordance with the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR), unless otherwise provided for under national legislation. The ADR sets out how dangerous goods must be transported nationally and internationally, while national legislative provisions provide some flexibility within the otherwise prescriptive provisions of ADR for the purposes of national transport only.

There are currently a number of national provisions affecting the use, testing and certification of road tankers which set different standards by which certain road tankers operating within Ireland only may be operated. The HSA, in consultation with stakeholders, has developed some legislative proposals to bring these national provisions more closely in line with the international standards of ADR.

These proposals will affect the way tanks designed and built to ADR standards must be treated. To date, operators have had the choice to treat these tanks in accordance with national provisions, or in line with ADR. The difference between the two systems is that national tanks may be periodically tested by a competent person as opposed to an *accredited person. The competent person is effectively a self-declared competent service provider and is defined as one who has the relevant qualifications, training and experience, whereas an accredited person is independently assessed and formally approved. Additionally, there are differences in the actual testing requirements of tanks under both systems.

The first step in the proposed changes is to amend the national ADR legislation due to be transposed by mid-2015, to make it mandatory to maintain all new ADR tanks as ADR tanks, removing the option for national use only status. This principle will be extended to all existing ADR designed tanks, i.e., those constructed since 1 July 2003. This will affect a large number of existing tanks, but will not take effect until 2018.

The provisions will be implemented on a phased basis, such that when a tank is due for its next periodic or intermediate inspection it will be carried out by an accredited tank inspection body and certified to ADR standards. Older tanks constructed prior to 1 July 2003, will be unaffected, and may continue to be tested and certified for national use only by competent persons.

Accreditation for tank testers is a requirement already specified in ADR, but the services of an accredited body is only presently available from service providers based outside of Ireland; this is partly due to the low demand for this service in Ireland. This situation will hopefully change as a result of the increased demand for accredited service providers.

In the long term, bar a few exceptions, all road tanks carrying dangerous goods operating in Ireland will be designed, tested and certified to the international standards of ADR.

*Accreditation is provided in Ireland by the Irish National Accreditation Board

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