Testing and Inspection of Old Tanks

1 IntroductionThe Carriage of Dangerous Goods and Use of Transportable Pressure EquipmentRegulations 2009 (CDG 2009) bring Directive 2008/68/EC on the inland transport ofdangerous goods (DG Directive) into effect in GB. The DG Directive brings together therequirements for the rail and road transport and adds requirements for inland waterways.The DG Directive requires tanks to comply with provisions of RID and ADR for bothconstruction and for use. The DG Directive permits tanks constructed to nationalrequirements and not to the provisions of RID or ADR. These tanks known as ‘old tanks’in GB and NI, are restricted to national transport unless there is agreement betweenindividual states to allow cross border traffic. Old tanks may continue in service, providedthey are properly maintained and are safe for the remainder of their working lives.Tanks for the carriage of dangerous goods in GB and NI that were not RID or ADR tankswere inspected by a ‘competent person’ to a ‘written scheme of examination’. Thismethod of examining tanks does not require the competent person to be appointed andthe owner/ operator of the tank has the responsibility to write a suitable written schemeof examination and to ensure that it is carried out. On 2 July 2006 inspections bycompetent persons ended with inspections now being carried out by inspection bodiesappointed by the Secretary of State for Transport.These procedures replace the individual written schemes of examination with anapproach based upon the requirements of RID and ADR but taking account of thedifferent constructional differences that may exist between old tanks and RID or ADRtanks. The requirement for old tanks to be maintained to a written scheme ofexamination is set out in the Carriage of Dangerous Goods; Approved Derogations andTransitional Provisions (Approved Derogations). These procedures and must be usedand applied in accordance with the Approved Derogations including any transitionalprovision in the Approve Derogations.The competent authority for the appointment of tank and pressure receptacle inspectionbodies is in GB, the Secretary of State for Transport and HSENI in Northern Ireland.Compliance with these procedures is necessary for appointment and continuation ofappointment as an inspection body. These procedures cannot cover all situations andwill be amended in the light of experience and changes in legislation.That success in the inspections and tests conducted in accordance with theseprocedures, and the allocation of a certificate does not authorise the use of a tank forany dangerous goods. The tank instructions, published in the various modal regulationsmust also be complied with as must all other relevant requirements of the modalregulations.4