Question: Our company uses horse and trailer trucks to transport concrete slabs manufactured using cement, polystyrene and fibreglass within and across Provinces. These concrete slabs are not classified as Dangerous Goods.

And we, therefore, do not have Fire Extinguishers on the outside of the truck and trailer but rather one inside of the horse.

  1. Are we correct not to categorize the concrete slabs as dangerous goods?
  2. Are we correct to have only one fire extinguisher inside the truck and none on the outside?
  3. What does the law say about trucks and fire extinguishers?
  4. Lastly, can you please give me the reference in the law on this issue? Which is the relevant law and which section/clause is exactly in the law?

Thanking you in advance.

Answer: 

1. If the product does not have a UN number it is not dangerous goods. You must check the classification in terms of SANS 10228.
2. If dangerous goods are transported, SANS 1518 determines that you require fire extinguishers. Details are in the spec on sizes and numbers.
3. Apart from the above requirement, the NRTA only requires fire extinguishers for buses and minibuses used for reward. Normal goods vehicles are not required to have fire extinguishers in terms of the NRTA. Reg 260 applies.
4. Please note there are towns with by-laws under the Fire Services Act that may require fire extinguishers. The legislation only applies to the specific municipality.

There are 211 municipalities and unfortunately, I do not know which of them have such a provision. I have had enquiries from truckers saying they were prosecuted in terms of such by-laws.

Fire extinguishers
Reg 260.

(1) Every mini-bus operating for reward shall carry in a readily accessible position at least one fire extinguisher which shall be of—

(a) the dry powder type with a capacity of at least one kilogram; or
(b) the halogenated hydrocarbon type (BCF) with a capacity of at least one kilogram, and which shall be in good working order.

(2) Every bus operating for reward shall carry in a readily accessible position at least one fire extinguisher which shall be of—

(a) the dry powder type with a capacity of at least two and a half kilograms; or
(b) the halogenated hydrocarbon type (BCF) with a capacity of at least one kilogram, and which shall be in good working order.

Regards/Groete
Alta
Alta Swanepoel and Associates CC