It’s All Over For Old Diesel Bowsers
There has been an authorisation in place since 2004 to allow the carriage of certain dangerous goods (UN1202, DIESEL FUEL, GAS OIL, HEATING OIL, LIGHT) in ‘bowsers’.
The purpose of this authorisation was to allow industry time to adapt to new requirements and this 15 year transitional period ends on 9 May 2019.
Essentially, bowsers made prior to 10 May 2004 were authorised to be regarded as an intermediate bulk container (IBC) so long as certain conditions were met.
The key points aside from the built by date were: a maximum capacity of 3000 litres, designed for mechanical handling and not to be fixed permanently to a motor vehicle or trailer. There are several more conditions listed on the Authorisation notice – see link below.
What did this mean? Effectively, these old bowsers were unregulated and are used typically by drivers who have only received ‘awareness training’ for dangerous goods. Although the maximum capacity of these could be 3000 litres if there was any more than 1000 litres loaded then a certified ADR driver would be required.
A key point of the use of the bowers were that they are to be considered as IBCs which in ADR terms means it is a package rather than a tank. A tank would require a qualified ADR driver (in tanks) for any volume plus the towing vehicle would need to meet either AT or FL spec (ADR 22.214.171.124). You can see why referring to these bowsers as ‘tanks’ would be burdensome.
Since 10 May 2004, newer bowsers would be required to meet the ADR standard for an IBC and would need to be tested as such at 2.5 and 5 year periods.
The revised Authorisation No 1 can be viewed here.
The Future:These old bowsers will not be allowed from 10 May 2019 and so plans should be made to check and remove these from service. Any bowser manufactured from 10 May 2004 to the present time is required to meet the standard of an IBC under 6.5 of ADR.
A bowser is different to an item of machinery of which a typical example might be a generator which in ADR would be considered (in diesel terms) as UN3528 (or possibly UN3530). The generator would be not subject to ADR by virtue of SP363 – there are conditions attached to this which are new for ADR2019 and affect machinery/generators with more than 1000 litres of diesel on board.
Following this press release we have seen a surge in enquiries and completed successful orders based on removing the old unit hassle free, while also providing a minimum contribution amount towards the new tank. Everyone wins, from the customer to the environment.