ADR question re emergency life craft

yes there is…refuse to take it.

as we are on the subject of dangerous goods and adr licences does the adr supersede the need for a epp licence. Also at the point of delivery should the driver be filling in the relevant parts of the customers licence

I confess I have little knowledge of Aussie rules, though I’ve discovered it was available to download FOC. I can see you have EQs and LQs as we do, and these look very similar to ADR, but where we have Transport Categories , it appears you have something similar - Placard Load (Minimum Quantities) - which I imagine also offers similar “get out clauses” to full regulation

That was new to me " Licensing for home users of poisons and explosive precursors" :open_mouth: I have to ask: Who has a legitimate “home use” for these things as a member of the public?

I doubt an ADR cert would trump an EPP licence, as the former is for work purposes and the latter for… ? What? Playing “Mad Scientist” at home? Look kids, Daddy’s going to be the next Robert Oppenheimer :joy:

you strike me as a practical person i realise i dont know the first thing about you but im guessing if you could do something yourself you would rather than pay someone else to do it and possibly get a poor result.

i know some one that uses nitric? acid for copper plating. i wanted some acitic acid (pure) to clean a toilet that suffers with lime scale you cant even get brick wash with any guts anymore. however it seems you can get pure acetone no issue (not sure about the 5.1) or even what about soda crystals not allowed that any more.

only once when i was doing the adr job did i come across somthing that made me stop and think. I had to deliver a lot (20 5 gallon containers) of acetone to a house in the middle of a council estate and the person that took the delivery had chemical burns on her arms and face and looked completely out of it.

then can we not carry epp then anymore? or anything over 10% as from what i read you need an epp to carry it sell it or buy it and the seller is supposed to mark it down on their ticket.

Ah… You’re thinking some kind of “cottage industry” situation, fair enough, I hadn’t considered that, my thoughts went to a guy that was in the news last year, obesssed with “home chemistry”, to the detriment of his neighbours :joy:

I’m just guessing, but if for work you’re delivering to someone who did have an EPP licence, that sounds like it would likely be legitimate. Maybe @dieseldave might have better info

im no chemist but any chemical at any strength can be dangerous if improperly used or stored. I wouldnt want acid thrown on me if it was diluted to10% or not i assume it would still blind and burn me.

Depending on the quantity, which isn’t specified here but Flares fall into Class 1 ADR surely.
( They do at the RNLI in Poole)
So a driver with adr and class 1 qualifications would be required and relevant safety ppe.

If the mass of each package was <40KG and only contains less than 120ml of liquified gas to activate the device then Special Provision 296 applies, and then not subject to ADR.

OP has said they were about 120kg so the section of SP296 you’re referring to would not apply:

Life-saving appliances packed in strong rigid outer packagings with a total maximum gross mass of 40 kg, containing no dangerous goods other than compressed or liquefied gases of Class 2, group A or group O, in receptacles with a capacity not exceeding 120 ml, installed solely for the purpose of the activation of the appliance, are not subject to the requirements of ADR.

Nor would it apply if the SDS indicated it contained any 1.4G flare substance, as in the example SDS I linked to, though SP296(b) states 1.4S would be permissible up to 3.2g

In any case, either the consignor or the carrier should be able to inform a driver of when an SP applies, so the driver can be confident he’s not being BS’ed into a situation that could cause problems, which the reported comment from the unnamed TM strongly suggests.

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What about something a bit less than 10%? There’s a strong possibility you already have around your house some acetic acid 5% solution - bog standard vinegar

You can harm yourself simply by mixing household bleach (which contains sodium hypochlorite, a Class 8 corrosive) with anything acidic (toilet disinfectant, stuff like “Toilet Duck”), the acid can liberate chlorine gas which is toxic, as well as oxidizing and corrosive (2.3, +5, +8)

Going back to your EPP point of yesterday, I won’t say too much for fear of inciting dangerous behaviour which could attract the attention of counter-terrorism police, but it is possible to make even more dangerous products such a class 1 explosive from various products you could legitimately have around the home. Fortunately most “kitchen scientists” would poison themselves via the toxic fumes long before the Class 1 product was prepared.

that was kinda my point. the excuse i read for bringing in epp was to stop nutters throwing acid or other terrorist acts. the point i was trying to make is the license means nothing as its over 10% strength that is controlled.

Determined nutters will probably still find a way to do their “nuttery”

Hi Mark,

Although what Zac has said is correct, I’m no scientist so I’ll do my best with my plain English attempt to explain… from the info you gave, your question is about:

UN 2990 LIFE-SAVING APPLIANCES, SELF-INFLATING, 9
NO Packing Group is allocated but UN 2990 is assigned to ADR Transport Category 3, so the ADR ‘small load’ threshold quantity in this case = 1,000Kg

For UN 2990, there is NO possibility to use LQ exemption.

Dave’s note on LQs: The LQ exemption is self-contained at ADR 3.4 and so has NO connection or even any passing similarity to the ADR ‘small load’ partial exemption at ADR 1.1.3.6. LQs are normally used for the kind of dangerous goods that can be bought/sold in a retail shop AND packaged for retail sale, so not applicable in this case.

ADR Special Provision 296 applies to UN 2990:

SP296 applies to life-saving appliances such as life rafts, personal flotation devices and self-inflating slides. UN No. 2990 is for self-inflating appliances and UN No. 3072 applies to life-saving appliances that are not self-inflating. Both types of life-saving appliances may contain:

(I’ve reworded the nitty gritty of SP296 to remove what I think is distracting technical language so as to hopefully leave it in plain English for easy reading)

(a) Some articles of UN Class 1 (flares and smoke signals)

(b) A very small (other) article of UN Class 1 used to set off the self-inflating mechanism

(c) Some (various) Class 2 gases (neither flammable nor toxic)

(d) Electric storage batteries (Class 8) and lithium batteries (Class 9);

(e) First aid kits or repair kits containing small quantities of dangerous goods (e.g.: substances of Class 3, 4.1, 5.2, 8 or 9); or

(f) “Strike anywhere” matches packed in packagings that prevent them from being inadvertently activated.

So, a self-inflating life raft may contain some or all of the above, my guess is that any varitions of this would depend on the manufacturer’s exact intended application.

As can be seen, ADR treats the subject of this question as a single dangerous article rather than the individual dangerous components.

Dave’s ADR Trivia:
ADR treats the non-self-inflating type of life rafts in the same way but with appropriate modifications to the above SP296.

And now for the best bit… It is NOT an employed driver’s responsiblity to know whether a load is/isn’t subject to ADR. This resonsibility is squarely on the carrier (your boss) as written in ADR:

[Carrier responsibilities] ADR 1.4.2.2.1(a) Ascertain that the dangerous goods to be carried are authorized for carriage in accordance with ADR;

… so all of this wasn’t your problem to start with. :slightly_smiling_face:

THANK YOU!! Finally something i can understand. Brilliant . Thanks Dave. The thing that irked me was that my TM couldnt actually tell me anything useful ither than " we’ve done it befoe, if you’re refusing the load, then park the lorry up" and had to wait 2 hours for him to put it in a text message .
So im now in the black book for delaying the process. So i was like " oh its my xxxxing fault that there was no data sheet, or you ( the TM) hadn’t a baldy what was actually in the load!"
Anyway, nil desperandum … im leaving them next week

Just to lighten this up a bit;
A driver from the company I worked part time for was tasked to blue anchor to collect a single raft for a hot shot delivery to a vessel held by the MCA.
Raft , Banff Vessel , Poole Dorset.
Is part of the contract so has to be done .

Boss decides in the interests of economy this raft can/will be stuffed into the VW cady, no pallet as no room but a single halfords ratchet strap.
Give the driver his due he was at the quayside at the required time.
Lets say he was a little tired, pulling on the loose bit of rope did not drag the raft from the van.

After they had cut the raft out of the van he returned to Aberdeenshire in a reshaped vehicle.
I’m so glad I wouldn’t do hot shot stuff.

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Pity there wasn’t a picture, :grin: A couple of “You don’t want to do that!” slides brighten up any ADR course