TG10 is a dated industry publication
ITCO published TG10: RID-ADR 2023 Chapter 6.8 — Intermediate Inspection and Test in August 2023. It remains useful historical context for the change in inspection arrangements, but later official interpretations must also be considered.
Read the original at the publisher’s link. The current checks below refer to ADR and the official UNECE and OTIF interpretation lists.
What if an intermediate inspection is overdue?
The UNECE ADR Interpretation List records the clarification confirmed in November 2024: after an intermediate-inspection deadline has passed, an intermediate inspection under 6.8.2.4.3 is required, or a periodic inspection under 6.8.2.4.2 may be performed instead. OTIF publishes the corresponding RID interpretation.
Accordingly, TG10’s 2023 statement that a late intermediate test must be replaced by a five-year test should not be treated as the current universal rule. Confirm the inspection scope with the responsible inspection body using the tank’s approvals and history.
This clarification concerns the inspection to perform. It does not create an unrestricted right to fill or use an overdue tank.
Identify the tank before calculating its schedule
ADR 6.8.2.4.3 specifies a general intermediate interval of three years for fixed and demountable tanks and two and a half years for tank-containers and tank swap bodies. An inspection more than three months early affects the calculation of the next intermediate deadline. Special provisions, including those for gases, must also be checked.
Do not transfer those intervals automatically to a Chapter 6.7 portable tank or to a rail tank-wagon. For a tank with several approvals, list each applicable regime and have the inspection body confirm the combined schedule.
A carriage allowance is not a new filling allowance
ADR 4.3.2.3.7 prohibits filling or offering the listed tanks for carriage after the specified inspection date. Its limited exceptions concern tanks filled before that date. Subparagraph (c) permits carriage for up to three months after an intermediate-inspection deadline, subject to the provision’s scope.
Before relying on it, establish the loading date, the type of inspection due and the relevant tank category. A calendar reminder saying “three months’ grace” is insufficient evidence and can lead to the wrong decision.
Documents for an inspection and dispatch review
Provide the tank identification and data plate, type approvals, initial and latest inspection certificates, the recorded due dates, and details of repairs or modifications. Add the goods, route, proposed loading date and any road, rail or sea legs.
Ask the inspection body to confirm the required inspection and the next dates in writing. Separately, ask the parties responsible for dispatch and carriage to confirm the conditions for the planned movement.
Contact DGSA to review the dangerous goods transport aspects of your operation in Spain. For connecting sea transport, consult our IMDG guide; its requirements need their own assessment.
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