Uderstanding Fuel Bowser Towing.

Tilly Pass have been leading the industry in agricultural towing and are delighted to share this work that has been produced in conjunction with

The Carriage of Dangerous Goods Practitioners Forum.  Agri Towing is very much in the public eye at the moment with a growing number of life changing and  fatal incidents reported across the UK over the last few weeks. A better understanding of the Agricultural Exemption must be shared if we are to see an improvement in our Farm Safety record. A package up to 1000 liters for agricultural use only, to be towed at no more than 40km/h anything outside of this must comply with the ADR requires general awareness training and operators licence.  See below for ful details.

BOWSERS

There is no definition of bowser.  It is not a term recognised by ADR. For the purposes of this guidance a bowser is regarded as wheeled trailer fitted with a "tank" for carrying dangerous goods such as diesel or kerosene. They are commonly used for moving fuel to construction sites, forestry operations etc. For on the road operations “bowsers” have to be either liquid certified Intermediate Bulk Containers (IBCs) or certified as a Fixed or portable tank. Different transport regulations apply to each.

HOW TO DETERMINE IF A BOWSER IS AN IBC OR A TANK

A Certified IBC will have an approval mark that starts with   followed by a code such as 31A/Y/12.03/GB/FW-3348/5207/2893. The mark may be found on a metal plate fixed to the IBC. The last set of digits is the maximum gross mass of the filled IBC, the second to last set may be the single digit 0 in which case the IBC cannot be stacked in transport.

Packaged Goods rules apply as normal for marking and labelling so for instance for diesel Class 3 label (diamond) and UN1202 must be displayed on the IBC on two opposite sides.

A Certified Tank – will have a metal plate attached with full details including initial and periodic inspection dates, tank serial number, tank pressures, unladen mass, MPGM, manufacturer. It will also have either   and a T code or an ADR code starting L

Tank rules apply and treat as a tank vehicle (normal tanker), unless purged full regulations apply.

NO IBC OR TANK CODE – RECEPTACLE NOT SUITABLE FOR CARRYING DANGEROUS GOODS

Diesel and gas oil

Diesel and gas oil (UN 1202) are in scope up to flash point 100 deg C.  Diesel/fuel oil is in Transport Category 3, so up to 1000 litres may be carried in packages (IBC) without application of much of the regulations (small load exemption) applies so a driver requires general awareness training and a 2kg fire extinguisher that is in compliance with ADR. If 1000 litres is exceeded on the vehicle (including a trailer) then full ADR regulations apply.   

There are many types of bowser which are certified as IBCs, and they may look like tanks so care needs to be taken in deciding what rules apply. If the bowser is a properly certified IBC it can be used to carry kerosene (inc jet fuel) and be treated as a package.

In all other respects carriers of diesel are now subject to the standard ADR and CDG Regulations requirements.   

Petrol (UN1203)

Petrol is not routinely tested for vapour pressure and special packaging provision B8 prohibits the use of IBCs for petrol anyway. (see ADR 4.1.4.2 IBC02 B8 BB2)

Towing vehicles

When the vehicle such as a van, 4 x 4s etc. is towing a Tank the towing vehicle must meet the AT or FL standards as appropriate for the substance being carried (ADR 9.1.2.3).

No vehicle requirements are laid down for packaged dangerous goods i.e. IBCs.

There is a complete exemption from the requirements where the towing vehicle is an agricultural or forestry tractor and it is not travelling in excess of 25 mph.

Dangerous goods directive – 2008/68 EC.

Article 2, para 4 states:-

‘vehicle’ shall mean any motor vehicle intended for use on the road, having at least four wheels and a maximum design speed exceeding 25 km/h, and any trailer, with the exception of vehicles which run on rails, mobile machinery and agricultural and forestry tractors that do not travel at a speed exceeding 40 km/h when transporting dangerous goods;

This doesn’t define agricultural or forestry tractors per se, however it does state “THAT DO NOT TRAVEL AT A SPEED EXCEEDING 40 KM/H”. This does not mention design speed, or maximum permissible speed of the vehicle. We know that modern tractors are capable of exceeding 40 km/h (24.85 mph). The legal speed limit for an agricultural motor vehicle is 40 mph. However, the construction and use regulations 1986 limits the speeds the vast majority can actually travel because they do not meet the requirements- mainly for suspension, amongst others. At present I am only aware of two vehicles that can legally travel at the max speed- JCB Fastrac and the Mercedes Unimog.