Is your business following the updated fuel bowser regulations? Despite being enforced on May 9th, 2019, the new regulations were no surprise to the construction industry. In 2004, red diesel (gas oil) and white diesel (derv) were reclassified by the British government as flammable and combustible liquids. This new status meant they now fell under the European Agreement on the Carriage of Dangerous Goods by Road (ADR). The industry was allowed a 15-year exemption period by the Department of Transport to switch to internationally approved Intermediate Bulk Containers (IBCs). Now this period has elapsed, all fuel bowsers in use in the construction industry must conform to the current standards.
During this period, certain bowsers were authorised for use as IBCs provided they met certain criteria. Obviously, few businesses could afford to replace their fuel containers wholesale, and this was intended to allow the phasing out of unsuitable bowsers. Those in use at the time were allowed if they met the following requirements:
These transitional rules only applied to bowsers manufactured before May 10th, 2004. Any bowsers produced after this date were type-approved to meet ADR regulations and IBC standards. These ensured safe transport of fuel with no chance of leaks or spillage causing environmental damage or risk of fire.
All fuel bowsers produced after 2004 should be classed as an IBC under ADR regulations. The documentation and certification that came with the bowser at point of purchase should state whether it is classed as an IBC or a tank. The container itself should have approval or manufacturer plates on its external surface confirming its status as an IBC. If this is the case, it should also feature the UN packaging symbol or the embossed ‘UN’ letters. These will be accompanied by codes designating the type of IBC the bowser is. If the container is classed as a tank, it is no less usable, it is just not legally roadworthy. It can still be used to transport fuel on site or for fuel storage provided it meets the legal requirements under current regulations. The updated regulations are as follows:
This may seem counter intuitive as nothing can possess a volume of 110%. It means the tank should be capable of holding 110% of its described maximum volume. This allows for expansion in hot conditions and prevents over filling. Bunding is an extra inner layer inside a tank that prevents toxic contents coming into contact with the skin of the tank. This also prevents corrosive contents from eroding the outer surface, weakening the skin and causing leaks or ruptures.
A double skin protects the fuel within in two ways. Any damage to the tank during transportation that weakens or breaks the outer skin will not lead to leaks as an additional internal barrier is in place. Similarly, any leaks due to stress or weakness in the internal container will be contained by the outer layer. Single skinned bowsers are no longer allowed to transport fuel on public roads.
This will ensure the integrity of the bowser and avoid some of the issues outlined above. Large volumes of liquid can place huge stresses on the material of the bowser and pressure testing replicates this effectively. Any weakness detected can then be rectified before it causes dangerous spills or leaks.
While diesel itself is not a corrosive material, the presence of conductive materials in it can cause corrosion. Internal inspections, though rare, can alert the owner to potential problems that could weaken the inner skin.
If the bowser lacks this and the manufacturer and approval plates, it is unlikely to be an IBC. If you are unsure, further information is available here – https://unece.org/fileadmin/DAM/trans/danger/publi/adr/adr2005/English/Part6_ch6-5.pdf
When pressure testing and inspections are performed, proof of roadworthiness must be recorded. All test results must be logged, and the documentation kept safe for future reference. If these documents cannot be produced in the event of a Department for Transport inspection, the bowser will be deemed non-compliant with ADR regulations. As a result it will not be considered safe for transport on public roads and the owner could face prosecution.
One exemption to ADR regulations is still in place for the farming industry. Tractors pulling towable fuel bowsers at speeds below 40mph are still exempt. The bowser must still be safe and roadworthy and only filled to its maximum design capacity. This only applies to bowsers towed by tractors, other vehicles such as 4x4s still fall within the scope of ADR regulations.
SERV Plant Hire are plant and machinery specialists offering a huge variety of construction equipment and tools for hire to the North West of England. This includes towable bowsers with capacities up to 2000 litres and a range of Transcube site fuel bowser allowing storage of up to 3000 litres. All our bowsers are regularly tested and inspected and fully compliant with ADR regulations. Whatever your fuel transport and storage needs may be, contact us. We will be happy to answer any questions and ensure you have the best equipment for the job.