Carrying LQ's of DG's

ASK THE EXPERTS SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE
1

I’ve got a feeling Diesel Dave will be answering this one…

I had a job last week of getting a box loaded with LQ’s for export. I’m not worried about if it was LQ’s or not as 99.9% of the companies that we deal with are large blue chip companies that wouldn’t ■■■■ about with anything like that, and all the shipping and DG notes we get for the sea journey all state LQ’s and gives a load of bumpf with it. For those that don’t know dangerous goods by sea (IMDG) are a hell of a lot stricter than by road and not many companies in the world are willing to flaunt them as the penalties can be very very severe.

I was given all the relevant signage (4 in total) for all four sides (total of 16 stickers) of the box and trundled off to put them on the box, the stickers were the
limited quantity sticker,

class 3 flammable,

class 8 corrosive

and marine pollutant.

As I was sticking them on my box a driver from a different company came over and asked me what I was doing. I told him I was putting the stickers on as it was a LQ load. He said I didn’t need to put the other stickers on and just put the LQ sticker on and put the rest on at the port. I told him I was putting all the stickers on as it warns anyone in the event of me having an accident that it is limited quantities and what form of limited quantities I was carrying. He said I was being stupid and wasting my time and wandered off (which showed what a ■■■■ he was being really) but it got me thinking as to who was right and who was wrong, or was we both right and there is nothing laid down as such to do with labelling of LQ’s apart from the actual LQ sticker?

So do I stick just the LQ sticker and do the rest at the docks or just whack em all on before leaving the place of loading?

One final question, as it is LQ’s (dangerous goods but not dangerous goods) should I have my orange boards up? I’m guessing I don’t have to as I drove past leatherhead with VOSA sat on the hard shoulder prowling just before the junction and they never tugged me for it, or were they just chasing foreigners that day?

2

I’ll follow this thread with interest because I sometimes have to take trailers containing limited quantities of hazardous goods to the ferry ports.

As far as I’m aware the stickers are for port/shipping use only and are not required on public roads, in fact in the past I’ve been told by the office bods (experienced and knowledgeable drivers) to put the stickers on when arriving at the port and not before.

When collecting the returned empty trailers we have to take the stickers off before leaving the ferry port, they reckon it’s an offence to have the stickers on whilst on public roads and that the stickers were purely for port/shipping purposes.

I’m sure dieseldave will be able to put us right though :wink:

3

I used to take LQ to Dublin and I didn’t even get the stickers until I arrived in Holyhead.

4

Coffeeholic:
I used to take LQ to Dublin and I didn’t even get the stickers until I arrived in Holyhead.

We didn’t used to get the stickers at all, it went on the dock with just a LQ sticker on it and all was sorted, but recently apparently there has been a change in legislation (or something has happened) and now when we get to the ports with Lq’s the docks were charging our company £8 a sticker as we cant take them on the docks without the proper class stickers on them now

5

Lee G:

Coffeeholic:
I used to take LQ to Dublin and I didn’t even get the stickers until I arrived in Holyhead.

We didn’t used to get the stickers at all, it went on the dock with just a LQ sticker on it and all was sorted,

Sorry, I meant I just got the LQ stickers at the docks, none of the other ones such as Flammable. Because Stena charge £10 for 4 stickers some of our guys used to just stick them on by the four corners then peel them back off when they disembarked in Dublin so they could use them next time.

6

Generally if there are 4 placards it will mean IMDG which means Maritime, but that is too simple a rule for everything. Containers require 4 placards whether ADR or IMDG, other vehicles only require 3.

Normally with LQ there is no need to show Orange Plates or carry additional paperwork for ADR

Dave will pick holes in this tomorrow. :blush:

7

Lee G:
I’ve got a feeling Diesel Dave will be answering this one…

Hi Lee,

This is an extremely tricky subject to explain in writing, so I’ll do my best to present the info clearly.

:bulb: I’m sticking rigidly to the subject of the question, which relates to the multi-modal carriage of LQs in an ISO container on a journey that involves carriage by both road and sea.

Lee G:
I had a job last week of getting a box loaded with LQ’s for export. I’m not worried about if it was LQ’s or not as 99.9% of the companies that we deal with are large blue chip companies that wouldn’t ■■■■ about with anything like that, and all the shipping and DG notes we get for the sea journey all state LQ’s and gives a load of bumpf with it. For those that don’t know dangerous goods by sea (IMDG) are a hell of a lot stricter than by road and not many companies in the world are willing to flaunt them as the penalties can be very very severe.

You’re not kidding there Lee, some of the fines are quite eye-watering!!

As an example, this is what happened to a driver who thought he might try getting away with not declaring to a ferry operator that he was carrying dangerous goods:
:arrow_right: Truck driver fined £5,757.98
He was only carrying 383 Kg. Ouch!! :open_mouth:

Lee G:
So do I stick just the LQ sticker and do the rest at the docks or just whack em all on before leaving the place of loading?

Since you’ve spoken of a road journey which ends up at the docks for further shipment by sea, most people seem to know that there are two sets of Regs involved, BUT where there are differences between those two sets of Regs, it can cause some confusion. Your question on vehicle and ISO container markings covers an area where there are some differences between the ADR and IMDG Regs.

ADR regulates dangerous goods journeys by road on road vehicles:

ADR.jpg

IMDG regulates dangerous goods carried by sea:

IMDG.jpg

ADR takes care of the ‘differences’ by accepting what’s written in IMDG and specifically allowing that to be valid for the road leg of a multi-modal journey like this:

ADR 1.1.4.2.1 …, containers, …, which do not entirely meet the
requirements for … placarding …, of ADR, but are in conformity with the
requirements of the IMDG Code … shall be accepted for carriage in a transport chain
including maritime … carriage subject to the following conditions:

For carriage in a transport chain including maritime carriage, if the containers,
… are not marked and placarded in accordance with
Chapter 5.3 of [ADR] they shall be marked and placarded in accordance with
Chapter 5.3 of the IMDG Code. In such case, only 5.3.2.1.1 of ADR is
applicable to the marking of the vehicle itself.

This actually makes it easier for me to answer your question, because I can leave out ADR’s normal requirements, since they ONLY relate to a road journey.

The LQ markings required for the ISO container are exactly as you posted, and it’s correct that you needed one on the front and rear, plus one on each side of the container, making a total of four.

The other driver who spoke to you was correct to say that the other placards that you were given weren’t required for the carriage of LQs. In this case, IMDG says:

IMDG 5.3.2.4
… containing dangerous goods in only limited quantities shall not be placarded nor marked.
[Except with LQ placards. :wink: ]

ADR 5.3.2.1.1 is…

.

Lee G:
One final question, as it is LQ’s (dangerous goods but not dangerous goods) should I have my orange boards up? I’m guessing I don’t have to as I drove past leatherhead with VOSA sat on the hard shoulder prowling just before the junction and they never tugged me for it, or were they just chasing foreigners that day?

I’m not sure about the part you’ve put in brackets, but can I guess you might mean ‘dangerous goods but not subject to ADR’ ?
Yes Lee, you needed to display your orange plates because of my mention of 5.3.2.1.1 above, and your journey being multi-modal involving carriage by sea, but you wouldn’t have needed an ADR licence, ADR equipment or fire-extinguishers etc.

:bulb: The ADR marking rules for carrying DG in LQs in a container on a vehicle ONLY by road are a little different to above.
:bulb: The ADR marking rules for carrying DG in LQs on a vehicle ONLY by road are different to above.
:bulb: The IMDG marking rules for placarding vehicles carrying DG whilst on a ferry are different to above.

8

tachograph:
I’ll follow this thread with interest because I sometimes have to take trailers containing limited quantities of hazardous goods to the ferry ports.

Hi tachograph,
The placarding rules for LQs on unaccompanied trailers for IMDG are the same as the placarding rules for LQs in containers, ie, one on the front and rear, plus one on each side.
However, the vehicle marking requirements for LQs by road are different.

tachograph:
As far as I’m aware the stickers are for port/shipping use only and are not required on public roads, in fact in the past I’ve been told by the office bods (experienced and knowledgeable drivers) to put the stickers on when arriving at the port and not before.

That would be good advice for quantities of DG that wouldn’t be subject to full ADR (transport below ADR threshold quantity) and/or full ADR because you need ‘proper’ Class placards for IMDG, but not for ADR.

tachograph:
When collecting the returned empty trailers we have to take the stickers off before leaving the ferry port, they reckon it’s an offence to have the stickers on whilst on public roads and that the stickers were purely for port/shipping purposes.

It is an offence to leave placards on display if there are no DG on board. (Empty trailer.)
ADR and IMDG are the same in that regard.

tachograph:
I’m sure dieseldave will be able to put us right though :wink:

I can only try, but I can’t guarantee it won’t go to 10 pages if ROG shows up. :unamused: :wink: :grimacing:

9

Coffeeholic:

Lee G:

Coffeeholic:
I used to take LQ to Dublin and I didn’t even get the stickers until I arrived in Holyhead.

We didn’t used to get the stickers at all, it went on the dock with just a LQ sticker on it and all was sorted,

Sorry, I meant I just got the LQ stickers at the docks, none of the other ones such as Flammable. Because Stena charge £10 for 4 stickers some of our guys used to just stick them on by the four corners then peel them back off when they disembarked in Dublin so they could use them next time.

The price of placards can be usually be charged back to the consignor.

IMDG placards are more expensive than ADR placards because IMDG has a stricter quality requirement for their placards than ADR does.
In the context of placards the IMDG requirement is that they will

IMDG 5.3.1.1.1
… be identifiable on cargo transport units surviving at least three months’ immersion in sea water.

10

Wheel Nut:
Generally if there are 4 placards it will mean IMDG which means Maritime, but that is too simple a rule for everything. Containers require 4 placards whether ADR or IMDG, other vehicles only require 3.

That’s a pretty accurate description Malc, but for clarity I’d add “under IMDG” right at the end. :smiley:

Wheel Nut:
Normally with LQ there is no need to show Orange Plates or carry additional paperwork for ADR

It’s easier to use the last paragraph of ADR 1.1.4.2.1 and show orange plates when travelling on the road leg of a multi-modal journey because ADR’s marking rules for LQs on a road only journey are a little trickier.
As for paperwork for LQs by road, you’re spot-on.

Wheel Nut:
Dave will pick holes in this tomorrow. :blush:

No problem Malc, I have time to do it today… :laughing: :smiley:

…but TBF, you didn’t leave me much room. :frowning: :wink: