The Rustler:
If your company are pulling trailers ( only on UK work ) for another company, who don’t do any ADR work ( and don’t want ADR plate permanently fixed to their trl ) … is it LEGAL to just hang orange ADR plate on chains from the back-door handles, to do an ADR load
Had this question at work this week … I got told last year ( not MMTM - he was transport manager of another firm ) that the rules had changed and the plate MUST be “fixed” to the trl ?
Company I currently drive for say it is legal to hang the plate on chains … can any-one clarify
Hi The Rustler,
My opinion as a DGSA is that it’s illegal to hang the orange plates on chains or secure them with cable ties.
Here’s how I get to that opinion:
ADR 5.3.2.1.1 They [the orange coloured plates] shall be affixed one at the front and the other at the rear of the transport unit, both perpendicular to the longitudinal axis of the transport unit. They shall be clearly visible.
I think that takes care of those who prop their plates in the windscreen.
ADR 5.3.2.1.8 … If plates are covered, the covering shall be total and remain effective after 15 minutes’ engulfment in fire.
ADR 5.3.2.2.1 The plate shall not become detached from its mount in the event of 15 minutes’ engulfment in fire. It shall remain affixed irrespective of the orientation of the vehicle.
The blue sentence seems to me to take care of plastic cable ties, but I’d say that it might also have implications for properly mounted (Eg; riveted) plates attached to any plastic parts of the front of a cab such as a grille.
The red sentence specifically mentions the orientation of the vehicle.
Since the orientation is to be taken into account, the plate attached by chains IMHO might not remain showing the orange side if the vehicle were on its side or upside down.
It might seem a bit draconian and rather overly specified, but I’d say the intent of the lawgiver is quite clear.
It’s like most other legal points raised though… the law seems pretty clear, but none of us know how an enforcement officer (or court) will interpret it.
Just for completeness, you mention that it’s UK work.
UK Regs, [CDG 2009 (as amended) and ADTP ] don’t vary anything above.