Hello everybody
Today I carried car batteries in a mixed load, on 4 pallets, 36 batteries per pallet.
Is adr required for this please?
Thanks
SD
- The movement of lead acid batteries - whether new or used - comes under ADR. However, there is a specific derogation under Special Provision 598 of the European Agreement Concerning the International Carriage of Dangerous Goods by Road (page 610) which allows lead acid batteries to be moved WITHOUT ADR regardless of quantity if they fulfil certain conditions. Likewise, if they DO NOT fulfil these conditions, then they MUST be moved under ADR regardless of quantity.
The conditions that mean lead acid (storage) batteries are not subject to the requirements of ADR are:
For new storage batteries when:
they are secured in such a way that they cannot slip, fall or be damaged;
they are provided with carrying devices, unless they are suitably stacked,
e.g. on pallets;
there are no dangerous traces of alkalis or acids on the outside;
they are protected against short circuits;
Used storage batteries when:
their cases are undamaged;
they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
there are no dangerous traces of alkalis or acids on the outside of the articles;
they are protected against short circuits.
“Used storage batteries” means storage batteries carried for recycling at the end of their normal service life.
Speedy Duck:
Hello everybody
Today I carried car batteries in a mixed load, on 4 pallets, 36 batteries per pallet.Is adr required for this please?
Thanks
SD
Hi SD,
Sorry, but there’s not quite enough info for anybody to give you a good answer.
ADR has a large number of Special Provisions (SPs) one of which I can think of would get you out of the need for an ADR Card.
A good answer will depend on the type of batteries, and the way that they were palletised.
This info would be on your Transport Document ( = delivery note), so the UN number would be a good start to get you a good answer because anything else is guesswork.
If you’re an employed driver… one good thing about this is that if your boss told you that you didn’t need an ADR card for that job, then ADR allows you to believe him/her because ADR makes HIM/HER (not you) responsible for that decision.
If you own your vehicle, then that’s a different matter.
Tagging on, as DD says there is not enough info.
HarryMonk provides the relevant SP for car batteries under ADR. (One thing I will point out is that if there was less than 1000 kg of batteries then there would be an exemption under 1.1.3.6.3 ADR 2023 Vol I. I am quoting this as this is how DGSA’s should quote the references in ADR to back up their position).
However at 4 pallets and 36 batteries per pallet I estimate the load to be in excess of 1000 kg. (10 kg per battery, 10 x 36 x 4 =1440 kg). So, that does not IMO apply.
I am prepared to say that if the pallets of batteries you carried were in “original, untouched, undamaged packaging, new. without any sign of damage and on pallets” then ADR probably (i.e. >50% IMO) does not apply. If there is any sign of damage to the pallet or packaging of the batteries then I would not like to say.
If you collected the batteries from or taking to a waste facility I (personally) would need a lot of convincing that ADR does not apply to the load.
On the plus side as DD says, if you are the employed driver then put it in the “Not My Problem” file. If you are the Owner/Operator then you need a DGSA that you pay for to advise you and not some randos on the internet.
I used to regularly pick up 20’ containers of car batteries from Southampton Container Terminal and take them to Euro Car Parts in Tamworth, we didn’t need ADR for that. There were diamond stickers on the containers but that was just for the sea journey.
Also used to bring back 26 pallet loads of shotgun cartridges from Spain to the UK, again no ADR required.
It may have changed now.
Harry Monk:
I used to regularly pick up 20’ containers of car batteries from Southampton Container Terminal and take them to Euro Car Parts in Tamworth, we didn’t need ADR for that. There were diamond stickers on the containers but that was just for the sea journey.Also used to bring back 26 pallet loads of shotgun cartridges from Spain to the UK, again no ADR required.
It may have changed now.
I do not doubt that HarryM. From your description above legal to transport the batteries without ADR. [Terms and Conditions apply,to testify in court I would have needed to see the load and the goods in question].
Shotgun cartridges? Well… as DD would say do you have the UN Number? Honestly, although I am qualified to advise on Class 1 Dangerous Goods I do not.
As an aside I always found it odd that I qualify as a DGSA for Classes 1 to 9 by an “All Classes” at the DGSA exam but needed as a driver to do additional training for Class 1 and 7. (There are very few, almost no questions on the DGSA exam on Classes 1 or 7 and if there are then I avoided them).
As to Maritime (IMDG) regs, can we just not go there?
DGSA2:
If you collected the batteries from or taking to a waste facility I (personally) would need a lot of convincing that ADR does not apply to the load.
I researched this recently, a couple of my TM clients are in the waste industry. Waste Lead Acid batteries can be exempt but whoever is packing them needs to know the requirements:
Their cases are undamaged;
they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
there are no dangerous traces of alkalis or acids on the outside of the articles;
they are protected against short circuits.
SD, if you were shown a safety data sheet for the batteries that would probably provide the necessary info. If you’re doing it again, your main issue is making sure your load security is up to spec.
DGSA2:
As an aside I always found it odd that I qualify as a DGSA for Classes 1 to 9 by an “All Classes” at the DGSA exam but needed as a driver to do additional training for Class 1 and 7. (There are very few, almost no questions on the DGSA exam on Classes 1 or 7 and if there are then I avoided them).
Yes, I found that bizarre too “I can tell you how to do it but I can’t do it myself”? 
DGSA2:
As to Maritime (IMDG) regs, can we just not go there?
Curious, I spoke to Dave about that some while ago and though admittedly I don’t have the IMDG books, I was under the impression they aren’t radically different to ADR.
Zac_A:
DGSA2:
As an aside I always found it odd that I qualify as a DGSA for Classes 1 to 9 by an “All Classes” at the DGSA exam but needed as a driver to do additional training for Class 1 and 7. (There are very few, almost no questions on the DGSA exam on Classes 1 or 7 and if there are then I avoided them).Yes, I found that bizarre too “I can tell you how to do it but I can’t do it myself”?
DGSA2:
As to Maritime (IMDG) regs, can we just not go there?Curious, I spoke to Dave about that some while ago and though admittedly I don’t have the IMDG books, I was under the impression they aren’t radically different to ADR.
I’m quite happy to do IMDG, RID and ADR.
I’ll answer some of the points in the above posts when I get chance. 
Just for now, I also used to do a full load of shotgun cartridges 22t at a time as a backload from Frosinone, Italy for Olin Winchester and deliver them to a place near Kidderminster.
The shotgun cartridges I carried were UN 0012, 1.4S and so can be carried in any amount without an ADR card or placards because 1.4S is in ADR TC4, so unlimited. (ADR 2023 1.1.3.6)
Dave’s ADR Trivia
UN 0012 can be carried as LQs.
(ADR 2023 3.2.1 table ‘A’ and 3.4)
We don’t do page numbers. 
Thank you all for your pertinent and informative responses.
It is for a major motor manufacturer in the midlands and their primary logistics provider.
The only hint of anything is a hazardous stamp on the del note. We also carry seat belts and air bags similarly notated.
As a side issue, cars were once hazardous according to shipping lines because of fuel residue / fumes even when drained, and batteries, and then they weren’t, according to shipping lines. Not sure if they are now or not. Shipping lines decide these things for their rates, outside of the imdg blue book.
Zac_A:
DGSA2:
As an aside I always found it odd that I qualify as a DGSA for Classes 1 to 9 by an “All Classes” at the DGSA exam but needed as a driver to do additional training for Class 1 and 7. (There are very few, almost no questions on the DGSA exam on Classes 1 or 7 and if there are then I avoided them).Yes, I found that bizarre too “I can tell you how to do it but I can’t do it myself”?
DGSA2:
As to Maritime (IMDG) regs, can we just not go there?Curious, I spoke to Dave about that some while ago and though admittedly I don’t have the IMDG books, I was under the impression they aren’t radically different to ADR.
Two points I would like to make Zac_A.
- I am an advisor. I do not tell anyone what to do, just advise them. The advisee can take my advice or throw it in the bin. I don’t care.
- IMDG. Well… as an example. UN1327 Hay, 4.1, not subject to ADR. (ADR 2023 Table A 3.2.1) However UN1327 HAY, is subject to IMDG. I can see why as a load of hay on fire at the side of a motorway is an inconvenience, on a ferry could be a larger problem? (Yes, ok, I am being dramatic).
The point I am making is that although IMDG and ADR/RID and IATA regultions are slowly becoming more harmonised (in tune) there are differences to catch the unwary.
As a further example can you tell me the name of a formally qualified “Danagerous Goods Safety Advisor” under IMDG?
DGSA2:
- I am an advisor. I do not tell anyone what to do, just advise them. The advisee can take my advice or throw it in the bin. I don’t care.
It was a lighthearted comment, doesn’t really need that kind of response, the kind of thing you see on that pointless BADGP forum
DGSA2:
2) IMDG. Well… as an example. UN1327 Hay, 4.1, not subject to ADR. (ADR 2023 Table A 3.2.1) However UN1327 HAY, is subject to IMDG. I can see why as a load of hay on fire at the side of a motorway is an inconvenience, on a ferry could be a larger problem? (Yes, ok, I am being dramatic).
Yes I’m well aware of the IMDG Hay/Straw/Bhusa issue, Diesel Dave posted that on here many years ago.
DGSA2:
The point I am making is that although IMDG and ADR/RID and IATA regultions are slowly becoming more harmonised (in tune)
Seriously? You think “harmonised” needs to be defined to someone who is a qualified DGSA 
DGSA2:
As a further example can you tell me the name of a formally qualified “Danagerous Goods Safety Advisor” under IMDG?
I’m well aware that there isn’t a DGSA qualification for IMDG.
But if you want to play prattish top trumps, perhaps you’d like to give me the chemical equations which explain why oxygen behaves the way it does? Hint: it involves multiple reductions of molecular oxygen into other Reactive Oxygen Species, such as singlet oxygen and the superoxide radical. This is my specialist subject, I spent three years researching ROS for my biochemistry PhD