ADR type approval for a MEGC: the complete document pack

A Multi Element Gas Container is not a container. Legally it is pressure equipment that happens to be transportable, and it sits at the intersection of two regimes: TPED for the pressure equipment and ADR for carrying dangerous goods by road.

That means paperwork. Rather more of it than most first-time buyers expect, and the consequences of a gap are not administrative — an incomplete pack means the unit cannot be registered, cannot be insured properly, and in the worst case is stopped at a roadside inspection with gas on board.

This is the full list, in both directions: what the manufacturer needs to obtain approval, and what you as the operator must hold for the life of the unit.

Part 1 — Documents required to apply for ADR type approval

This is the manufacturer’s side. You will not normally assemble these yourself, but you should know they exist, because a supplier who cannot name them has not done this before.

Document	What it establishes
Type approval application	The formal submission to the competent authority
Scope of supply	Exactly what is in the approved configuration, and what is not
Technical specification	Pressures, volumes, materials, temperature range, cylinder type
Design basis	The standards and calculations the design is built on
Serial numbering philosophy	How individual units and cylinders are identified traceably
Nameplate draft	The physical plate, exactly as it will be stamped
Document register / MDR template	The index of the whole Manufacturing Data Record

Two of these are worth dwelling on.

Serial numbering philosophy sounds like bureaucracy and is not. It is what lets you trace an individual cylinder back to its batch, its proof test and its approval fifteen years from now, when it comes up for periodic inspection and somebody asks. Get it wrong at the start and it cannot be fixed retroactively.

The nameplate is the unit’s legal identity. Everything on it must match the approval exactly. A nameplate that disagrees with the certificates is a unit that fails inspection, and re-stamping is not a five-minute job.

Part 2 — Documents required to operate the equipment

This is the pack that must be handed over with the container, and that you must be able to produce on demand.

Document	Why you need it
EU Type-Examination Certificate	The approval itself — the legal basis for operating
Certificate of Conformity	Declares this unit conforms to that approved type
P&ID	The piping and instrumentation diagram — required for any modification, repair or hazard assessment
ATEX report	Explosive atmosphere assessment and zone classification
Detail component overview list	Every valve, fitting and safety device, by manufacturer and type
Equipment certificates	The individual certificates behind every item on that list
Cylinder proof test	Pressure test records for each cylinder
Manifold proof test	Pressure test record for the manifold assembly
Initial inspection	The first statutory inspection, before entry into service
In-house inspection certificate	The manufacturer’s own quality record
Paint layer inspection	Coating thickness and adhesion — the corrosion protection record
Lifting instructions	How the unit may be lifted, and how it may not
User manual	Operating limits, filling and offloading procedure, maintenance intervals

The ones people discover they are missing

In our experience four documents are the usual gaps, and they are the ones that are hardest to obtain after the fact:

The detail component overview list, with its certificates. When a valve fails in year six and you need an identical replacement to stay within the approval, this list is the only thing that tells you what it was. Without it you are reverse-engineering a fitting from a photograph.

The ATEX report. Often skipped by suppliers who treat the MEGC as a transport item rather than as an installation. You will need it the moment the unit is parked at a site and becomes part of someone’s zone plan.

Paint layer inspection. It sounds trivial next to a burst test. It is the record that governs the corrosion protection of the frame, and on a steel frame that spends its life outdoors it is the difference between a twenty-year asset and a ten-year one.

The P&ID. Any modification, any repair to the pipework, any serious hazard study needs it. Reconstructing one from a built unit is expensive and never quite trustworthy.

What to ask a supplier before you sign

Three questions. The answers tell you a great deal.

1. “Send me your MDR index for a unit you have already delivered.” Not a promise of what will be included — the actual index from a real delivery. A supplier who has done this properly can send it the same day.
2. “Which competent authority issued the type approval, and what is the certificate number?” Then check it.
3. “Is the approval for this exact configuration?” An approval covering an 11-cylinder 20 ft does not automatically cover an 18-cylinder 40 ft, and it does not cover a different cylinder or a different manifold. Configuration changes need the approval to follow them.

A container is straightforward to build compared with getting it approved. If a quotation is notably cheaper than the alternatives, this is usually where the difference is hiding. The unit arrives, and then you find out what you are missing.

How Gaznet delivers it

Every Gaznet MEGC ships with the complete pack above, indexed to the Manufacturing Data Record, cylinders certified to EN 12245 and the unit approved under TPED and ADR. The serial numbering carries through from the individual cylinder to the nameplate, so periodic inspection in year ten is a lookup rather than an investigation.

When you specify a unit with us, ask for the MDR index up front. It is part of the delivery, not an extra, and seeing it before you sign tells you more about a supplier than any brochure will.

Talk to our engineers →