New guidance on towing fuel bowsers 

A bowser or intermediate bulk container (IBC) package with capacity up to 1,000 litres for agricultural use only, can be towed at no more than 40km/hr. 

Anything outside of this must comply with the ADR (International Carriage of Dangerous Goods by Road),which requires general awareness training and an operator’s licence. 

Tilly Pass, in conjunction with the Carriage of Dangerous Good Practitioners Forum, has put together new guidance to clarify the regulations on towing fuel bowsers/IBCs.

This brings bowsers/IBC packages that are used in agriculture in line with the construction industry standards, allowing for crossover between the two industries for hire or buy. 

Key points in the guidance include…

Bowser definition

Whilst there is no official definition of a bowser, the guidance defines it as a 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.  

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. 

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

If there is no IBC or tank code, the receptacle is not suitable for carrying dangerous goods.

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Diesel and gas oil

Diesel and gas oil (UN 1202) are in scope up to flash point 100ºC.  Diesel/fuel oil is in Transport Category 3, so up to 1,000 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 1,000 litres are 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 which rules apply. If the bowser is a properly certified IBC it can be used to carry kerosene (including 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.   

Petrol 

Petrol is not routinely tested for vapour pressure and special packaging provision B8 prohibits the use of IBCs for petrol. 

Towing vehicles

When the vehicle (e.g. a van, 4x4s etc) is towing a tank, the towing vehicle must meet the AT or FL standards as appropriate for the substance being carried.

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 is not travelling in excess of 25mph.  

Dangerous Goods Directive 

Article two, paragraph four of this directive defines ‘vehicle’ as any motor vehicle intended for use on the road, having at least four wheels and a maximum design speed exceeding 25km/hr, 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 40km/hr when transporting dangerous goods.

This does not define agricultural or forestry tractors per se, however it does state “that do not travel at a speed exceeding 40km/hr. This does not mention design speed, or maximum permissible speed of the vehicle. 

We know that modern tractors are capable of exceeding 40km/h (24.85mph), the guidance notes. The legal speed limit for an agricultural motor vehicle is 40mph. 

However, the Construction and Use Regulations 1986 limit the speeds the vast majority can actually travel because they do not meet the requirements – mainly for suspension, amongst others. 

At present, the JCB Fastrac and the Mercedes Unimog are the only two vehicles known that can legally travel at the max speed, the guidance concludes.

For further information contact tillypass@gmail.com or cvu@suffolk.police.uk 

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