Transporters of Dangerous Goods face upcoming SANS 1518 Deadlines
09 May 2016
The transport of dangerous goods in South Africa is a complex affair. It is regulated by the National Road Traffic Act (Act 93 of 1996 as amended). This Act requires compliance to a National Standard, namely SANS 1518:2011 Edition 4 – "Transport of dangerous goods — Design, construction, testing, approval and maintenance of road vehicles and portable tanks". SANS 1518 in turn requires compliance to specific sections in the "European Agreement concerning the International Carriage of Dangerous Goods by Road", commonly referred to as the ADR.
SANS 1518:2011 contains the following key dates and associated requirements:
The Last Day of Use
The reference within the standard to the "Last Day of Use" does not necessarily mean that this is the end of the road for these tankers. SANS 1518:2011 does make provision for continued use of the tankers subject to a specific approach and required outcomes which are detailed in the standard. This process is commonly referred to as recertification or revalidation.
However, road tankers and portable tanks that do not comply with the recertification and revalidation requirements above, are at considerable risk in relation to this looming deadline. There is growing consensus among facility owners to indicate that they will not allow non-compliant vehicles to load or deliver product to their sites as of1 August 2016, which could put non-compliant road tankers off the road.
What should transporters of Dangerous Goods be doing?
- Confirm the history of your vehicles as far as practically possible i.e. check manufacturing dates, last inspection dates, maintenance history and records. Those falling within the specified deadlines up to 1 August 2016, should contact a competent authority for assistance with the process of recertification or revalidation. Note that the standard defines a "competent authority" as an approved inspection authority according to the Pressure Equipment Regulations of the Occupational Health and Safety Act.
- Ensure that you allow sufficient time for the process to be completed by 1 August 2016.
- Discuss the matter with your clients if you are unable to meet the deadline and ensure that there are no contractual default or liability clauses that could harm your business. If there are, you should discuss these with your contracts specialist or seek legal advice.
- Implement a properly documented compliance plan going forward so that the "newer" tankers are on a schedule for when their 15 year period arrives.
Intertek is well equipped to assist companies with managing their risk and ensuring compliance with legislative and customer requirements. We are accredited by SANAS (South African National Accreditation System) as a competent authority, allowing us to engage in work related to SANS 1518. With a robust approach towards road tanker recertification we can ensure optimal turnaround times based largely on in-house capabilities. Our knowledgeable technical team is able to assist with unforeseen occurrences and provide recommendations on possible courses of action based on significant experience with road tankers.
Visham is a Professional Engineer with more than 20 years' experience in the engineering and inspection fields. He was part of the core group that compiled the Pressure Equipment Regulations (PER) and its companion document, SANS 347 – "Categorisation and Conformity Assessment Criteria for all Pressure Equipment". He is also the Technical Manager of Intertek’s ASME Authorised Inspection Agency with its global headquarters in South Africa.