To stay legally compliant and reduce risk to your business it is imperative that dangerous goods tanks are inspected and tested at regular intervals. You should plan & implement a combination of ‘periodic’ inspections, ‘intermediate’ inspections and, finally, ‘exceptional’ checks following repairs or damage that may affect the safety of the tank, or tank container.
A common question we’re asked is: When are ADR ‘exceptional’ checks required and by whom? So, we have briefly set out the issues that you need to consider:
The relevant standards
ADR tanks, portable tanks (RID/IMDG tanks) and UK tanks are all subject to inspection under EN12972:2007, or the VCA Procedures for Inspection Bodies Testing and Inspection of UK Tanks. These set out the requirements for ‘exceptional’ checks. This is soon to be supplemented by guidance (that British Engineering Services has been involved in writing), in conjunction with government departments and other industry partners (operators, owners, manufacturers, Approved Inspection Body (AIBs) and repairers).
Section 184.108.40.206 EN12972:2007 states that an exceptional check must be made “when the safety of the shell or its equipment is liable to be impaired by a repair, alteration or an accident.” The VCA has issued Guidance for the Application of EN12972:2007 (the Guidance), that assists operators in determining when incidents will impair the safety of the tank.
What constitutes safety impairment?
Annex A of the Guidance provides a useful summary of when repairs and alternations will be deemed to have impaired safety, what tests need to be performed and by whom.
- Repairs which may not have impaired safety (Group 1) are those involving replacement with a component from the original equipment manufacturer (OEM), or an equivalent specification component
- Alterations which may not have impaired safety (Group 2) are those that involve changes to components that do not require hot work
- Repairs which may have impaired safety (Group 3) are those that involve repairs or replacements with non-OEM or different specification components
- Alterations which may have impaired safety (Group 4) are those that involve changes to components that require hot work.
All Group 3 & Group 4 repairs require exceptional testing which must be carried out by, or at least under the supervision of, an AIB. Section 4.5 of the Guidance expands on this further, stating:
“Exceptional checks may only be performed by an AIB [Approved Inspection Body] that has been accredited and appointed to inspect tanks after accidents, alterations or repairs that may have impaired the safety of the tank and/or the service equipment …”
Finding an Approved Inspection Body
The Department for Transport has a list that operators can search to find an AIB: BODIES APPOINTED TO INSPECT ROAD AND RAIL TANKS IN THE UK
British Engineering Services is a Type A AIB for ADR/IMDG/RID and UK Tanks and is also approved for other directives such as the Pressure Equipment Directive (PED), Transportable Pressure Equipment Directive (TPED) and the Machinery Directive. We have been certifying and inspecting transportable equipment for many years.
To find out more about the legislation and requirements for UK and ADR tanks, including certification and inspection periodicities, download our ADR and UK tank guide.