Important legal regulations for mobile tank systems:
Legal basis
Mobile diesel fueling stations are used in many companies. The legal basis is regulated by the ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road), the GGVSEB (Dangerous Goods Regulations for Road, Rail, and Inland Waterway Transport), and the GGBefG (Dangerous Goods Transport Act). If the container is used as a stationary fueling station, the regulations for self-consumption fueling stations apply accordingly (see page 11).
Use of mobile diesel or petrol tank systems / IBC
According to dangerous goods regulations, mobile tank systems do not exist at all. These are intermediate bulk containers (IBCs). The abbreviation IBC stands for intermediate bulk containers. IBCs are used in various industries for the transport and storage of hazardous goods, among others. They are filled with liquid or free-flowing products, but also for bulk goods. These include, for example, fuels for fueling machinery, chemicals, waste materials, dust, as well as foodstuffs, cosmetics, and pharmaceuticals. IBCs have a volume of up to 3,000 liters.
Exemptions in connection with the type of transport Subsection 1.1.3.1 c) ADR – Craftsmen’s Regulation –
If all exemption requirements according to 1.1.3.1 c) ADR are met, a complete exemption from dangerous goods regulations is granted, i.e., dangerous goods regulations no longer apply. This represents a significant relief for agricultural, forestry, landscaping, and craft businesses, as they no longer have to apply the regulations otherwise applicable to dangerous goods.
These are:
- Use of type-approved packaging
- Failure to comply with marking and labelling regulations
- Elimination of the obligation to equip with a fire extinguisher
- Elimination of the obligation to carry an accompanying document (here: transport document)
In practice, this regulation represents a significant simplification, since according to RSEB 1-5.1 (Guidelines for the Implementation of the Dangerous Goods Ordinance by Road, Rail, and Inland Waterway), deliveries for direct consumption of up to 450 liters are exempt from ADR regulations. Transportation for direct consumption means that up to 450 liters may also be transported to the machine by car. They may not be left there; they must be immediately refueled and consumed. Please also refer to our "Tradesmen's Regulations" checklist.
Testing or inspection
From a hazardous goods law perspective, mobile diesel filling stations are predominantly so-called intermediate bulk containers (IBCs). The manufacturer itself sometimes uses other terms for these diesel tank systems, such as containers or tanks. However, these terms familiar from hazardous goods law have nothing to do with the actual definition of packaging under hazardous goods law, namely intermediate bulk containers (IBCs).
Unfortunately, the mobile diesel tank systems used are often not tested or inspected by an inspection body for intermediate bulk containers (IBCs) recognized by the Federal Institute for Materials Research and Testing (BAM). Such tests and inspections are required by regulations and laws such as the ADR (European Agreement Relating to the International Carriage of Dangerous Goods by Road), the GGVSEB (German Regulation on the International Carriage of Dangerous Goods by Road), and the GGBefG (German Dangerous Goods Transport Act), respectively, at intervals of two and a half and five years from the date of manufacture.
Check the nameplate of your mobile diesel tank system. If it's been more than two and a half years since the last inspection, you should have it checked/inspected by a recognized inspection center as soon as possible.