In last month's edition, Hentie van Jaarsveldt, FleetWatch's correspondent on Dangerous Goods, dealt with the responsibilities of the driver and consignor in terms of the Operational Requirements for Road Vehicles contained in SANS 10231-2006. In this article - Part 3 of the Series - he takes a look at vehicle inspections and maintenance. This is the last article in the series.

How often does one hear the comment from an Operator: "We find it so difficult to get the driver to inspect the vehicle?"

Most operators will maintain - or attempt to maintain the vehicle - as it is the job of the mechanic to service the vehicle. After all how can he refuse to do his job? He gets paid to do it!

As detailed in the earlier parts of this series, the vehicle needs to undergo pre-trip inspections as required by SANS 10231. And SANS 10231 is law. So, if the pre-trip inspection of the vehicle is included in the job description of a driver and he is sufficiently trained in how to perform the inspection, how can he refuse to do it? Apart from company disciplinary issues, he is also breaking the law if the inspections are not performed.

Vehicle inspections, apart from the safety and regulatory objectives, whether they are performed pre-trip, during-trip, post-trip or at other regular intervals, is an inherent part of preventive maintenance. One cannot divorce inspections from the maintenance function. Even at a vehicle service, if done properly, one will first perform a detailed inspection of the vehicle and then continue with the physical repair and servicing actions required.
 

The missing brake shoe is a clear sign of a lack of the required truck inspection and maintenance procedures. This operator is breaking the law and thus criminally liable!

An example of poor inspection and maintenance. This broken electrical junction box represents a very dangerous condition. The vehicle also passed an annual fire permit inspection in this condition. The inspector could not have been competent!

Inspections required by SANS 10231
In general, the inspection requirements are covered in section 6.2. It contains requirements for packaged goods vehicles, containers portable tanks and tankers. In the "General" section covering all vehicles and tanks (6.2.1), we find the following important requirements:

• The design and construction of the vehicle will comply with the requirements of the relevant standards at the time of construction.

• All Dangerous Goods vehicles (not only heavy vehicles!) will undergo inspections in accordance with annexure E.1 of the standard.

• Detailed records will be kept of all inspections

• The inspection schedule contained in E.1 will be completely restarted following major maintenance and repairs.

These are some very far reaching requirements. The problem, however, is that the requirements referred to in E.1 are not very clear, are open to wide interpretation and, to say the least, not that well written. Just look at the last requirement above. What constitutes major maintenance or major repairs?

There are two specific sections governing specific inspection requirements. The first (6.2.2) covers packaged goods vehicles, containers and portable tanks. The second (6.2.3) covers the cargo containment area of a road tank vehicle (no definition given).

If we consider just the latter section 6.2.3, we also find some very interesting requirements such as:

- That the tanker must be presented in a gas-free condition with a gas-free certificate to a test station or competent authority.

Does this ever happen currently? The answer is seldom.

- Inspections shall be carried out by a competent person who will ensure that the design and construction of the tank vehicle comply with SANS 1518. If the tank vehicle was manufactured before the publication of SANS 1518, it shall comply with 6.2.1.1 (meaning the relevant standard at time of construction).

As can be seen from the following part detailing the contents of the inspection schedule, it is not clear when this inspection will take place. The only direct reference is for the 48-month inspection.

Whether one agrees with them or not, the above requirements are the Law and must be complied with!

All the inspection requirements are listed in SANS 10231 Annexure E. Again, as detailed earlier in the series, Annexure E is regarded as "Normative". It thus must be complied with in order to comply with the requirements of SANS 10231.

The inspection requirements are basically as follows: (Refer to the standard for the exact requirements)
 

Potential disaster An example of a critical defect detected through regular inspections. This crack in the drawbar Aframe could have resulted in a disaster.

1.  Before placing the road tanker into service
According to SANS 1518, the tankers need to be approved by a Competent Authority to verify the design requirements in accordance with SANS 1518.

Apart from this, one also requires verification of the design features by an appointed competent person (A person with the necessary skills and knowledge to carry out a specific task). There are many features, client and operation specific requirements that the Competent Authority will not be aware of nor skilled to inspect and approve. It is thus essential to inspect the tanker prior to placement into service to ensure that it will meet all of the operational requirements.

2.  During operation
These inspection requirements are contained in annexure E2 of the standard.

The objective of this inspection is to ensure basic roadworthiness and loadworthiness of the tanker. Annexure E.1 states that this inspection is the responsibility of the driver or in-house staff. However, the main body of the standard states in 4.3.2.2 that the driver will, prior to loading, ensure that the tanker is roadworthy and at the start to the journey, or after every overnight stop, will inspect the tanker in accordance with annexure E.2.

This is the most important inspection of the operation. In many operations, this inspection is not done thoroughly or is done by people not suitably skilled and vehicles are thus allowed to operate in conditions that are not conducive to safe operation. And if defects are reported, these are often not attended to timeously. A big-bang approach is applied once a year when the statutory roadworthiness inspection is done or when the consignor performs a Safe Loading Pass inspection.

For these inspections to be successful and have the desired results, the drivers need to be properly trained. The inspection results need to be properly documented and the required corrective action managed diligently. The standard refers to a "Typical" daily inspection schedule. One would thus draw up relevant inspection schedules and documentation to suit the equipment used and the operation. It is not intended for the contents of E.2 to be applied verbatim.

3.  Six-monthly inspections
SANS 10231 requires one to perform a six-monthly inspection of the tanker in accordance with Annexure E.3. It also states that one needs to check the valves and gaskets and the thickness of the tank material on a corrosive products tanker. The content of Annexure E.3 is virtually 100% aimed at roadworthiness with only one requirement for checking for signs of chemical attack.

One finds it strange that the driver's daily inspection is detailed and includes a number of loadworthiness-related items but none of these are contained in the six-monthly inspection! One could argue that the driver is doing a daily inspection so all defects should be attended to on a daily basis. But so he is for general roadworthiness!

It is thus strongly proposed that items that affect the loadworthiness of the tanker be included in the six-monthly inspection.

It is a requirement of the standard that a record be kept of this inspection and that it is signed by "the operator" or the competent person.

Every second six-monthly inspection requires the statutory annual roadworthiness inspection in accordance with SANS 10047 performed by an accredited roadworthiness testing station.

In addition to this, the tanker requires "certification for current use to this standard". This part has to be performed by a competent person. It is unclear as to what is meant by the stated clarification. Does it mean that it needs to be inspected for compliance say with SANS 1518 and SANS 10232 as these are normative references contained in SANS 10231? It is also not specifically stated that records must be kept of this inspection, but logically one should.

4.  Inspection after 36 months of service
This inspection has the same requirements as for the annual inspection, with two important additions:

- On all tankers, except those used exclusively for the carriage of diesel, petrol and kerosene, all valves must be stripped and reconditioned by a competent person.
- Inspection and testing of a tank of a pressure vessel in accordance to national regulations carried out by a competent authority.

It will be interesting to see how many operators of tankers (other than diesel, petrol and kerosene tankers) actually adhere to the requirement to recondition valves every three years!

5.  Inspection after 48 months in service
The requirement is for the same inspection as carried out every 24 months and in addition:

- More stringent leak tests might be called for in the case of normal pressure vessels
- The tank of the tanker requires inspection and testing to the tank manufacturing standard.

It will also be interesting to see how many operators inspect and test the tank to the relevant design standard every four years.

Maintenance requirements of SANS 10231
For all the details included dealing with inspections, the maintenance requirements are contained in one paragraph only, this being:

"6.2.1.3 - Regular preventative maintenance shall be built into the working schedule of the operator and shall either be carried out at the operator's depot by suitably qualified staff, or be subcontracted to a competent workshop. Detailed records shall be kept of all maintenance and inspection work done on every vehicle."

Inspections are part of preventive maintenance but again, other than the daily inspections prescribed for drivers, no detailed requirements are given. Should the tanker be involved in a serious incident with the matter ending up in court, who will determine whether the operator performed adequate preventive maintenance? It is thus strongly suggested that operators look at their maintenance systems and procedures in an honest manner in order to determine whether they are dong what they should regarding maintenance.

A further issue is the use of competent persons to overhaul, recondition or repair, specifically product handling and containment equipment on the vehicle. In-service failure of such equipment can have catastrophic results. It is thus extremely important to ensure that persons doing work on such equipments (bottom valves, sensors, vents, manhole covers, pumps and meters, to name few) are trained and work in accordance with the manufacturer's requirements.

If one looks at SANS 1518, one will see that the various types of equipment are covered by specific supplementary standards. One can thus not ignore the standards that the new equipment needs to comply with when doing refurbishments or repairs.

It is also essential to keep accurate records of maintenance actions and repairs - especially regarding the tanker equipment and the tank. The law requires this!

Conclusion
Simply put, the operator has to inspect, has to maintain and has to keep records. He has no choice. He must also ensure that persons performing the inspections are competent and that repairs and maintenance are carried out by competent persons.

The standard does need work in order to make it more clear and precise. In the meantime, however, SANS 10231 - with its blemishes - is the law.