Tanker design and inspection issues: Design Approvals, DG trailer registration, EIP’s and Drive Away Protection
The NBTA wishes to raise with CAP four issues to do with DG tanker design approvals, registration and the interpretation of rules to do with EIP’s and drive away protection.
DG tanker design approvals
WorkSafe Victoria has changed their practices and now requires a considerable level of detail before signing off on design approvals for new tankers. This information request is, in the NBTA’s view, onerous and we wish to clarify the reason for this increase in detail as well as the decision to approve designs by UN number and not by class. These changes are adding significant cost to manufacturers. The reasons behind these changes have not been explained and we seek clarification as to the necessity to add this administrative burden to tanker approvals.
The NBTA view is that Competent Authorities should place the onus on the tanker manufacturer to sign off as to the compliance against the code and standard. Separate design reviews should not be necessary.
DG trailer and barrel registration
WorkSafe Victoria require the plating of tank trailers and barrels and have followed a process that results in a significant delay between registering the vehicle for road use and issuing of the DG plate for the trailer or barrel. The process followed in NSW can be carried out the same day and there is no delay between road registration and barrel registration. Queensland have dispensed with plating issue altogether.
The NBTA seeks a nationally consistent approach to this practice.
EIP’s and drive away protection
The NBTA is opposed to any ruling that interprets “substantially vertical” as “vertical” for EIP’s. This issue deserves a more considered discussion as the cost consequences are very high and the likely safety benefits are, in our view, almost negligible.
EIP and drive-away protection are both currently subject to a VCAT challenge in Victoria. We believe that CAP should wait until the VCAT has deliberated on this before further considering this issue. They should also consult with the Hazmat division of AFAC to obtain their views. NBTA has already held informal discussions with this group and does not believe there is strong support for a “vertical” position.
For more information contact:
Rob Perkins, Executive Director, National Bulk Tanker Association Inc.
Tel 0411 402 832, firstname.lastname@example.org