Today i was given a back load of emergency life craft out of Banff. These are the type encased in a white cylindrical plastic shell that inflate when you pull the tender. On arrival i was asked if I had an ADR ticket as the rafts still had their changes fitted along with Flares and C02 cylinders. My TM gave me the immortal line " we’ve loaded there before " to which i replied " i don’t care if Prince William collected them, im not until you put it in writing that the goods are either non hazardous or LQ Hazardous. Otherwise you’d better call Bonny Prince Billy to come get em. Eventually they sent me the confirmation but one of the Survitech technicians who held an ADR ticket was " positive ‘’ the ELRs were classed as Class 6 hazardous goods. Can anyone add to this?
class 6 is infectious and toxic substances. i doubt very much anything to do with life rafts.
i seem to remember that life rafts came under class 1 as well as several other categories. one of the dgsa’s will be able to advise further
Erm, yes, definitely not Class 6 .
Assuming they fit the bill as something similar to the product in the SDS in the link below (look at section 14) these are UN2990, Life saving appliances, Self inflating, Class 9 Miscellaneous Dangerous Substances and Articles (these being “articles”), and if you had more than 1000kg of them, would be fully ADR regulated - there are no LQs allowable with this article.
UN2990 life saving appliance , class 9 , there is an exemption for a lot of SOLAS equipment ,used to move them a lot , was it from the airfield site at Banff airfield ?
ADR 2023 contains no exemptions for these products, apart from minor things to do with packaging, and the “small loads” limit of 1000kg as they are Transport Category 3
section 13 of your link…
Incineration is the preferred method of disposal of pyrotechnic materials. Any compressed gas released will
dissipate into the atmosphere and leave no hazardous waste…
ummm correct me if im wrong but isnt incineration burning… surly the burning of compressed gas cylinders and flares isnt good
Compressed gas bottles go “boom” when heated in a fire 
A fantastic example of Boyle’s Law regarding pressure/volume relationships. I suspect that part was just talking about the small amount of UN0403, Class 1.4G and not the UN1013, Carbon Dioxide, Compressed.
1.4 - Goods and substances with no significant explosive hazard. Explosive effect mostly contained by packaging.
Group G of Class 1 - Pyrotechnic substance or article containing a pyrotechnic substance, or article containing both an explosive substance and an illuminating, incendiary, tear-producing or smoke-producing substance
There was 78. Some small, some larger. With average weight ± 120kg. Which IS under 10000kg.
So in summary, its a non hazardous load?
I think a relevant question is:
120Kg is the weight of each raft package?
So each raft will contain what weight of hazardous material?
The amount of life raft is not really relevant, only the amount of hazardous goods, surely?
And Zac’s post says 1000kg not the 10000kgs in your post.
And you are both naughty: 1,000 or 10,000 is clearer.
The limit for Transport Category 3 is 1,000kg, not 10,000kg: 120kg multiplied by 78 = 9,360kg, so is very much a full-regulated ADR load.
Although in conversation people might use the phrase “small load exemptions” (referring to the flexibility provided by Transport Categories 1, 2, and 3, more accurately ADR 1.1.3.6.3) that can be very misleading and generally, DGSAs tend to avoid the use of the word “exemptions”.
As for being non-hazardous, that doesn’t apply here; loads are either “fully-ADR-regulated” or “do not attract full ADR regulations”.
isnt it the consignors responsibility to make sure all requirements are met. ie driver turns up and asked if he has adr (im assuming he doesn’t) it doesn’t matter what his boss says its down to the company that is sending the stuff,
its the packing quantities that does my head in if you have 2000 of x its ok if packaged into 1000 kg lumps but put it all in one package and it isnt.
and in this case as the hazardous materials are “packaged” in life rafts and not un approved boxes/containers are they separated under adr
■■■■ knows. What’s really ■■■■ is that there isn’t provision for non ADR trained drivers to keep themselves safe.
There’s a lot of non-compliance in the industry generally speaking and a surprising amount in the world of ADR. When dealing with consignors I frequently find that checking a driver’s ADR cert isn’t necessarily always done, just like many of them are totally unaware that they need a DGSA (since Jan 2023), many of them are also blissfully unaware of their responsibilities to ensure appropriate UN approved packagings are used
Yes but the liferaft is packaged very well and I’d imagine that hard plastic clamshell packaging far exceeds the UN testing requirements.
As I believe dangerous goods regulation is all but universal, United Nations codes are a bit of a clue, there are only minor detail differences, between jurisdictions.
My interpretation would be as no single quantity exceeds 1,000kg/1,000litre, it would be classed as packaged goods and therefore not fall under Dangerous Goods legislation.
Happy to be corrected.
It’s the mass of the whole consignment that dictates whether it is eligible to be considered a TC3 “small load” or not. The whole consignment is almost ten times the 1000kg threshold, so it is fully regulated
Thanks Zac, seems we have a situation like our National road rules, there are different interpretations from six states and two territories, making a mockery of national rules.
Here, we need a DG licence to carry< 1,000 kg/lt of a regulated dangerous substance, but no special licence is required for a full load, providing each container holds below the threshold.
It does seem stupid that to carry 1,001 litres of motor spirit, in a dedicated fuel tanker requires a DG licence, yet no qualification is needed to carry 200 x 200 litre drums of petrol, on a flat top trailer.