a We operate a number of draw-bar
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trailers for the storage of hydrogen for use in the manufacture of our products. These are basically flat trailers with three or four hydrogen cylinders permanently fixed on them giving an unladen weight of 3 to 4 tons.
Once a week a replacement trailer is moved to the premises of a subsidiary company situated 2 miles from our base. The only other movement is once per fortnight when we cover 100yd an the public highway to a supplier situated next door.
We consider these trailers as engineering plant and therefore exempt from the Plating and Tasting Regulations May we have your opinion?
AMuch depends on the legal interpretation
of engineering plant. Certainly on the information you give us these vehicles appear to be standard road tank models and therefore not exempt from the Plating and Testing Regulations on this ground.
You do not state what type of braking system is employed, but trailers with no other brakes than a parking brake and brakes which automatically come into operation on the overrun are specifically exempted from plating and testing.
Also specifically exempted are vehicles freed from duty, subject to taxation authority approval, under section 6, sub-section 6 of the Vehicle (Excise) Act 1962. and any trailer drawn by such a vehicle. These are vehicles (trailers), which are used only in passing from land in the occupation of the operator to other land in his occupation, and for distances not exceeding in the aggregate 6 miles in any calendar week. Both provisos must be satisfied and in your case much will depend on the linkup with your subsidiary company. Is it a wholly owned subsidiary? Of course, the fortnightly trip next door is a different matter.
If in fact your vehicles are already working under the tax exemption you need not worry further. If not. your best plan is to apply to the tax authority for such exemption giving details of your full operating cycle.