gazzaman58:
A little off topic this but I know of nowhere else that has a cluster of ADR experts.
working on an agricultural job and they have 3x1100 litre diesel tanks full bunded and with no marking on them. They strap these onto trailers and take them behind a tractor out to the fields to refuel combines etc.
They say they are exempt from ADR as the regulations say
Exemptions arising from the Dangerous Goods Directive
34. Regulation 16 provides that the main parts of the regulations do not apply where carriage is “not undertaken by a vehicle”. This links to the directive’s definition of vehicle and the practical outcome is that the regulations do not apply to:
Agricultural or forestry tractors that do not travel at a speed exceeding 40 km/h when transporting dangerous goods; or any trailer being towed by such a vehicle. There is no definition of “agricultural or forestry tractor”. Cases will have to be judged on their merits. There are certain tests that can be applied, including taxation class, legal use of “red diesel”, and fittings common to tractors such as PTOs and three point linkages for attachment of agricultural implements. Subject to any Court decision, vehicles, such as Land-Rovers, Range Rovers and other 4x4 road vehicles are not regarded as agricultural or forestry tractors.
So behind a tractor OK …
Hi gazzaman58,
You’ve neatly provided your own correct answer up to where I’ve quoted above, but that’s contained in UK Regs, currently CDG 2009 Reg.16, but I’m afraid the next bit isn’t quite right:
gazzaman58:
… but on the flatbed of a Landy is illegal even if they only had say 900 litres in the tank as the tanks capacity is the issue not how much is in it?
On the flatbed of a landy would come under ADR, because there’s no UK exemption for the landy.
Here’s how it plays out…
You have another quite separate exemption for the landy and flatbed, but this exemption comes from ADR itself and has force of law in the UK because of CDG 2009 Reg.5
The ADR exemption you have for the landy is based on how much Diesel you have on board at any one time. In the case of Diesel fuel, the exemption limit is 1,000 liters, so 900 liters would fall within the exemption, as would 1,000, but not a drop more!! (You don’t count the fuel in the landy’s own fuel tank.)
If you choose to take advantage of the 1,000 liter ADR ‘freeby’ allowance for Diesel fuel, the only ADR requirement that you’d have to obey is the need for an ADR compliant 2kg dry powder fire-extinguisher as I’ve described in my first post on this page:
Dangerous goods advice- UK regs and ADR - SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE - Trucknet UK
If you read that, please just read the part about “carriage below threshold” and “other requirements” for fire-extinguisher compliance details.
gazzaman58:
So its 60 km/h down the lane - 40 km/h past the VOSA check point and then 60 km/h to the field - how do you guys see it ■■
Yes, that’s about the size (or speed) of it. 
gazzaman58:
And the tanks don’t need any markings on either ?
I’d be wary of calling those things “tanks,” because ADR does not regard them as any kind of tank.
The correct name for them is IBCs (Intermediate Bulk Containers) and the exemption I mentioned above comes from the fact that they are regarded as packages.
If you really need to carry 3,000 liters of Diesel fuel at a time with the landy, then I’m afraid you’ll need an ADR licence valid for at least UN Class 3 in packages and both you and the vehicle would need all the other things required for full ADR compliance too.
There’s no limit to how many trips you undertake per day if you carry <1,000 liters, but please don’t forget the fire-extinguisher. 
gazzaman58:
And the tanks don’t need any markings on either ?
IBCs need to be indelibly marked on two opposite sides as follows:
UN 1202
I hope this helps. 
