HCOTEG122400 –Marking: Special situations

Emergency marking

Traders should have in place emergency arrangements for marking, in the event of an equipment failure, which have been discussed and agreed previously with their local officer, such as by pouring a quantity of marker by hand into a storage tank.

There must be a compelling reason for doing it, such as the breakdown of equipment to mark heating fuel deliveries in winter. Hand-marking can only be sanctioned short term and in the case of emergencies.

The problems with hand marking are:

• the marker does not disperse evenly throughout the tank (the tendency would be to compensate by over-marking – this in itself could create a risk
• marker will stratify, forming layers at different levels of dilution in the tanks
• it creates health and safety risks to both the marker and the witnessing officer (who should not climb on top of road tankers )
• Emergency marking activity should be subject to a documented risk assessment taking account of guidance in HS2, HS7 and HS 10 and depending on the place where hand marking is carried out, possibly HS12, or HS13 or HS15

Accordingly the circumstances and risk to the revenue must be extreme, and proper measures taken to ensure safe working including a risk assessment (see HS1) should be completed before it is decided to allow hand marking, or to witness this.

In exceptional circumstances we may allow hand-marking directly into a delivery tank, such as the marking of ‘Off-specification’ or contaminated AVTUR prior to its removal from a RAF base by an approved Remote Marker using a Road Tank Wagon.

(This text has been withheld because of exemptions in the Freedom of Information Act 2000)

Marking of AVTUR is also necessary, where a trader intends to use this as furnace fuel. Marking AVTUR re-designates the oil to marked kerosene and the rebated duty rate is allowed with no duty repayment as AVTUR was originally supplied fully rebated.