A question for the ADR boys.
Are there any legalities involved if a non ADR trained/qualified driver pulls a box/trailer/truck marked up with the 4 stickers and UN codes after it’s been tipped/running empty ?
They have to be removed, you cannot run with them on with no ADR licence.
dambuster:
A question for the ADR boys.Are there any legalities involved if a non ADR trained/qualified driver pulls a box/trailer/truck marked up with the 4 stickers and UN codes after it’s been tipped/running empty ?
Hi dambuster, yes mate, there are some legalities involved…
If a vehicle or ISO container isn’t carrying dangerous goods, then all of the dangerous goods markings must be removed or effectively covered.
Given that you’ve mentioned “a non ADR trained/qualified driver” was driving it, he/she probably wouldn’t know the importance of removing/covering the four placards. The fact that no dangerous goods were being carried means that it is completely irrelevant whether the driver has an ADR licence or not. It doesn’t necessarily follow that just because an ISO container needs placards, an ADR licence is also required.
Just for now, it’s best to think of the ISO container and the carrying vehicle as two separate items…
ISO Container
If any amount of any kind of dangerous goods are in an ISO container, then under ADR the ISO container requires to have the relevant placards on all four sides.
Now let’s put the ISO container on a road vehicle… (The ISO container is already correctly marked now. 
)
ISO Container carrying vehicle
Normal ADR rules apply.
The ADR vehicle markings (simply an orange plate at the front and another at the rear) might be required, depending on the ADR Transport Category of the dangerous goods AND the total amount loaded on the vehicle (in the ISO container.) If the orange plate requirement is triggered, then the vehicle driver also needs an ADR licence, correct paperwork, 2X fire-extinguishers and all other relevant PPE and equipment.
Now for a surprise…
The UN number of the dangerous goods being carried is only required by IMDG (the Regs for carrying dangerous goods BY SEA) and isn’t required by ADR. Under IMDG, (the Regs for carrying dangerous goods BY SEA) the requirement to display UN numbers is (normally) triggered when the amount of dangerous goods (in an ISO container OR on a road vehicle being carried on a ferry) exceeds 4,000 Kgs. At this point, the load may still not be subject to ADR if the goods aren’t regarded as dangerous BY ROAD.
Case study
Let’s imagine that petrol (in drums) is to be carried in an ISO container on a road vehicle.
Petrol is in ADR Transport Category 2, so the ADR ‘trigger’ limit is 333 ltrs.
(More than 333 ltrs means orange plates, ADR licence etc etc)
Due to the fact that there’s an ISO container on the carrying vehicle, there is an additional requirement for only standard UN Class 3 placards on all four sides of the ISO container. (Just four of the placard at the bottom left in the picture below.)
If the road vehicle carrying the ISO container (or just the ISO container) goes on a ferry or boat, then it’s already correctly marked for the sea journey (under IMDG.) IMDG does not recognise ADR’s orange plates, so theoretically, the orange plates could be removed for the sea journey, but nobody bothers about doing so.
If there’s more than 4,000Kgs of petrol going in an ISO container (whether on a road vehicle or not) then the following marking rules apply BY SEA: (There’s no preference, BOTH methods are acceptable under IMDG.)
Just because the UN number on an ISO container isn’t required by ADR on the road, it doesn’t mean that it’s illegal to have them on display for the purpose of obeying IMDG. By road, displaying a UN number simply means that you’d be ‘overmarked’ ie. above minimum spec.
Your question was a good one mate, and I don’t think it’s been asked before. 
Did I manage to ‘untricky’ container markings for you 
Dave, you know how i appear and muddy the waters for you. 
Call me Rog if you like…
About 1979/80 I was driving for a small company, mainly on ISO Tanks, although we had some road barrels and would do anything that paid at the time.
I was given a collection note and told to go to Rentco to get a 20’ skelly then onto North Sea Ferries to Wood International. The girl looked at the note and sent me straight onto the dock with me asking if the container was cleared, yes she replied it is empty, here are your notes and tremcards
In a thick envelope she had given me were lots of paperwork and a CMR, the nett weight was less than 50kg and there was a huge bolt seal on the door. I set off and called in the depot for diesel, the boss came out and checked the seal, he said, “oh pity, the last seal was broken.” "What is in it? “Nothing” he said, “its empty, and going for incineration.” I was impressed, "how do they incinerate a new 20’ container, and why?
I was sent off on my way, to a company called Rechem in Larbert near Falkirk.
There was more stickers on this container than the tankers I was used to carrying, more than i had seen, but I didn’t need any extra markings or documents. At Larbert I handed the paperwork in and was told to drive around the back of the shed. There a fork lift was waiting with a pallet, a man stopped me cut the seal and opened the door, he was wearing a green chemical suit, and a particulate mask.
He climbed inside, took out 2 new looking spansets, and a couple of pieces of 4x4 timber, swept the floor, and sprayed a garden spray inside the box. He closed the doors and told me to go to the reception. He came round, still wearing his green suit, signed my papers and explained the container had been carrying a generator and it was contaminated with PCB’s.
I loaded the container from Glasgow and dropped it off in Hull
It was 10 years later when I discovered how bad Rechem was, they closed that one and a plant in South Wales due to local people and animals suffering from birth defects
Wheel Nut:
Dave, you know how i appear and muddy the waters for you.
Oh no Malc, I couldn’t call you “ROG” because there’s only one of those…
Halleluja and eureka all at once!! I’ve discovered evidence that there is a God after all!
Wheel Nut:
About 1979/80 I was driving for a small company, mainly on ISO Tanks, although we had some road barrels and would do anything that paid at the time.I was given a collection note and told to go to Rentco to get a 20’ skelly then onto North Sea Ferries to Wood International. The girl looked at the note and sent me straight onto the dock with me asking if the container was cleared, yes she replied it is empty, here are your notes and tremcards
In a thick envelope she had given me were lots of paperwork and a CMR, the nett weight was less than 50kg and there was a huge bolt seal on the door. I set off and called in the depot for diesel, the boss came out and checked the seal, he said, “oh pity, the last seal was broken.” "What is in it? “Nothing” he said, “its empty, and going for incineration.” I was impressed, "how do they incinerate a new 20’ container, and why?
I was sent off on my way, to a company called Rechem in Larbert near Falkirk.
There was more stickers on this container than the tankers I was used to carrying, more than i had seen, but I didn’t need any extra markings or documents. At Larbert I handed the paperwork in and was told to drive around the back of the shed. There a fork lift was waiting with a pallet, a man stopped me cut the seal and opened the door, he was wearing a green chemical suit, and a particulate mask.
He climbed inside, took out 2 new looking spansets, and a couple of pieces of 4x4 timber, swept the floor, and sprayed a garden spray inside the box. He closed the doors and told me to go to the reception. He came round, still wearing his green suit, signed my papers and explained the container had been carrying a generator and it was contaminated with PCB’s.
I loaded the container from Glasgow and dropped it off in Hull
It was 10 years later when I discovered how bad Rechem was, they closed that one and a plant in South Wales due to local people and animals suffering from birth defects
I couldn’t comment on Rechem, or what was or wasn’t known at the time, but…
Polychlorinated biphenyls (PCB) are now known to be carcinogenic on a good day, however on a bad day if they are involved in a fire, PCB bubbles and boils and gives off dioxin, which isn’t very nice stuff at all.
PCBs can be either liquids or solids, but both (UN 2316 or UN 3432) are in UN Class 9 PGII.
However, by road, both of those UN numbers are automatically in ADR Transport Category 0, which means that ADR applies in full (and a shedload of special provisions) even if there’s only a single microgram of PCB being carried on a road vehicle.
Either of the UN numbers of PCBs can be carried in a tanker or tank container, but one of the (unsurprising) requirements is for fully hermetic seals.