A Compliance Deadline That Isn't a Date

PESO requires under-run protection devices on gas-tanker fleets. For vehicles already on the road, the deadline isn't a date on a calendar - it's whenever that specific vessel next comes up for testing.

PESO - the Petroleum and Explosives Safety Organisation - requires Rear and Lateral Under-Run Protective Devices on vehicles that transport compressed gases in bulk under the Static and Mobile Pressure Vessels (Unfired) Rules, 2016. The requirement is real, current, and still working its way through the national tanker fleet.

For a vehicle newly licensed from 1 November 2023 onward, the obligation is straightforward: the mounting drawing for the device goes in with the licensing application, approved by a PESO-recognised fabricator, before the vehicle is on the road at all.

For a vehicle already licensed before that date - the majority of the existing fleet - the obligation works differently, and this is the part worth understanding precisely. Installation is required "while conducting periodical Safety Relief Valve / Hydro testing under Rule 18/19 of SMPV Rules, whichever is earlier." Not a fixed date. The vessel's own test cycle.

What that structure actually means

Compressed-gas tankers undergo periodic Safety Relief Valve testing and Hydro testing on cycles set by the vessel's own specification and history - not on a shared national calendar. Two identical tankers, purchased the same year from the same fabricator, can have test dates months or years apart depending on when each entered service and what its specific testing schedule requires.

Which means the under-run protection retrofit obligation doesn't arrive for a fleet all at once. It arrives vessel by vessel, on whatever date that vessel's own SRV or Hydro test happens to fall. A transporter with forty tankers in bulk-gas service could have five vessels retrofitted and certified, thirty still lawfully awaiting their next test cycle, and five more scheduled eighteen months out - and every single vessel in that fleet is in full compliance with what PESO actually requires, because none of them has yet reached its own trigger date.

This next point is inference, not stated anywhere in the directive itself, but it follows directly from how the rule is structured: "is our fleet compliant with the under-run protection requirement" is not a question with a single yes-or-no answer for any transporter operating vehicles licensed before November 2023. The honest answer is a list - vessel by vessel, against each one's own next test date - not a fleet-wide status.

What the certification actually checks

Once a vessel is retrofitted, a PESO-recognised Competent Person verifies and certifies the device's presence, recording it in the "Remarks" column of the certificate issued under Rule 18, 19 or 43. Design and installation must conform to IS-14812 (2005), IS-14682 (2004), OISD-159 and the current Central Motor Vehicles Rules. Vehicles carrying flammable or toxic gases must be de-gassed and purged at a PESO-approved station first. Fabrication and installation can only be done by a PESO-approved pressure-vessel fabricator, and the vehicle's permitted gas-carrying weight afterward is capped at the gap between its RTA gross permissible weight and its unladen weight - the device adds weight, and that weight comes out of payload capacity.

Whether PESO independently audits that certification, or relies on the Competent Person's own sign-off, was not established here and is not asserted either way.

What this means for tracking, not just compliance

The practical consequence isn't that anyone is currently non-compliant - the structure of the rule makes blanket non-compliance a coincidence of timing, not a violation. The consequence is that a compliance function tracking this obligation the way it tracks a single-deadline rule - one line item, one due date, done - is tracking it wrong. The correct record is a per-vessel schedule tied to each tanker's own SRV/Hydro test date, reviewed continuously rather than checked once and closed.

A separate draft amendment to the SMPV Rules (G.S.R. 147(E)) surfaced in February 2026 and remains in draft as of this writing - not yet in force, and not a reason to change how the existing retrofit obligation is tracked in the meantime.

Sources: PESO directives on Rear and Lateral Under-Run Protective Device installation under the SMPV (Unfired) Rules, 2016, as reproduced by regulatory-update services quoting the operative clauses directly. A claim about the current national percentage of non-compliant vehicles was sought and could not be sourced; it is not asserted.