Provisions for tanks and tank inspection activities

This page outlines the provisions for tanks in Ireland as follows:

• Provisions for tanks in Ireland according to the date of manufacture of the tank

• Tank inspection and tank inspection services in Ireland 
  • Tank inspection bodies appointed by the Health and Safety Authority (HSA) in Ireland
  • HSA requirements for inspection bodies appointed in Ireland
  • UK appointed inspection bodies operating in Ireland
  • HSA requirements for inspection bodies appointed in other EU Member States and in the UK

Provisions for tanks in Ireland according to the date of manufacture of the tank

Tanks in Ireland may be divided into three broad categories:

Tanks manufactured before 1 July 2003

These tanks can continue to avail of the provisions of Regulation 54 and Schedule 4 of the European Communities (Carriage of Dangerous Goods by Road and use of Transportable Pressure Equipment) Regulations 2011 (S.I. No. 349 of 2011), as amended (referred to as “the Regulations”), and can thus be inspected by a competent person as defined in the Regulations.  Such tanks are restricted to national use only.
 

Tanks manufactured between 1 July 2003 and 1 July 2017

These tanks were permitted to avail of the provisions of Regulation 54 and Schedule 4 of the Regulations until 1 July 2017, but following an amendment to the Regulations (see S.I. No. 5 of 2017) they were required to be brought back in line with ADR provisions on a phased basis.  An Information Note provides the background to this amendment.

Since that date, tanks that were manufactured or registered between 1 July 2003 and 1 July 2017 must be inspected by appointed inspection bodies.  For details on tank inspection bodies please see the section below entitled ‘Tank Inspection and Tank Inspection Services in Ireland’.

To allow the phased process of bringing tank-vehicles from being fit for national use only to being in line with ADR provisions, the HSA issued a Competent Authority Exemption CA 02/2017.

This exemption permitted tank vehicles certified for national transport only since 1 July 2003 and up to 30 June 2017 to continue in service until 31 December 2018 and for a further period until the next due date for inspection. Thereafter all affected tanks and tank-vehicles were subject to ADR requirements at the next date for periodic or intermediate inspection. The phased process of bringing the relevant tanks back in line with ADR provisions ended on 31 December 2021.

Tanks brought back in line with the provisions of ADR Part 6 are suitable for the international carriage of dangerous goods.

Tanks Manufactured after 1 July 2017
 

Tanks in this category must be in compliance with the requirements of ADR Part 6.

These tanks are suitable for the international carriage of dangerous goods.

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Tank inspection and tank inspection services in Ireland

Tank inspection bodies appointed by the HSA in Ireland

We currently have four inspection bodies appointed by the HSA for the inspection of road tanks in Ireland:

Table 1

EU and UK appointed inspection bodies operating in Ireland

There are, in addition, some inspection bodies accredited in other EU Member States and in the UK for the inspection and certification of tanks.  Such operations are performed under the control of the accredited inspection facilities.

To date, the HSA has been informed of the following inspection bodies that are operating in Ireland (this list may be updated from time to time - latest update 15 September 2022):

Table 2

HSA requirements for inspection bodies based in other EU Member States

The HSA is prepared to recognise inspection activity of inspection bodies that are accredited in other EU Member States based on the schedules of accreditation issued by the relevant EU accreditation body. However, the HSA must be informed as to the nature of the inspection activity in Ireland, and in addition, of any changes in the schedule of accreditation that would affect the activities of the inspection bodies in Ireland.

HSA requirements for inspection bodies based in the UK

Annex C of the VCA document entitled ‘UK Arrangements for the Appointment of Bodies for the Inspection of Tanks for the Carriage of Dangerous Goods’, last paragraph, states that ‘Appointees must establish the requirements of the competent authority of each country in which they intend to operate before commencing work there for the first time’.

The HSA’s requirements are as follows:

UK appointed inspection bodies (AIBs) operating at fixed locations in Ireland:  

If a UK AIB (type A or type C) is planning to extend its accreditation to operate at a fixed location in the Republic of Ireland (see TankSafe Solutions in Table 1 above), the HSA will formally appoint the inspection activity at this fixed location premises. Such appointment will be based on the UKAS accreditation of the inspection activity at that fixed location. 

Mobile inspection activity by UK AIBs at various places of inspection:

If a UK AIB (type A or type C) performs or witnesses inspection activity at various locations in Ireland (mobile inspection activity) and such activity is performed under the direct control of the UK AIB, then the HSA considers that such inspection activity does not require formal appointment in Ireland.

The HSA is prepared to recognise the UK VCA appointment based on the activities described in the UKAS schedule of accreditation. However, the HSA must be informed as to the nature of the inspection activity in Ireland, and in addition, of any changes in the schedule of accreditation that would affect the activities of the UK AIB in Ireland.   

Recognition of Certificates issued through the VCA database:
 

The HSA has been recognising, and will continue to recognise certificates of inspection issued via the VCA certification database.  This includes certificates of periodic inspection, intermediate inspection and exceptional checks. 

Certificates of refusal (refusal notice) issued through the VCA database will also be recognised.