Dangerous goods advice- UK regs and ADR

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

Hi Dave, or anybody else that might know.

Under ADR it says that tankers that are divided by partitions or surge plates into sections of more than 7500 litres must not be filled less than 80% or not more than 20% of their capacity, however do you know of any exemptions? Is there anything under ADR which allows a tanker that does not meet those regulations to be filled to a level between 20% and 80%? I am having a debate about this subject; I am being assured by a work friend that if a vehicle/tanker with sections greater than 7500liters reaches its legal road weight but is only 75% filled, then it is legal. This seems a load of old balls to me as it would rubbish the original regulation. I seem to remember not being able to load heavy products like caustic and acids in some tanks because there was not enough baffles and they would only be at 65% full when loaded.

Thanks

2

steptoe:
Hi Dave, or anybody else that might know.

Under ADR it says that tankers that are divided by partitions or surge plates into sections of more than 7500 litres must not be filled less than 80% or not more than 20% of their capacity, however do you know of any exemptions? Is there anything under ADR which allows a tanker that does not meet those regulations to be filled to a level between 20% and 80%? I am having a debate about this subject; I am being assured by a work friend that if a vehicle/tanker with sections greater than 7500liters reaches its legal road weight but is only 75% filled, then it is legal. This seems a load of old balls to me as it would rubbish the original regulation. I seem to remember not being able to load heavy products like caustic and acids in some tanks because there was not enough baffles and they would only be at 65% full when loaded.

Thanks

Hi Steptoe, I know it’s a different Dave you were asking but I think you might have the rule the wrong way round. Should it not be that tanks should not be filled to than more than 80% and not less than 20%? You need to make room for the liquid expanding with temperature hence not filling it more than 80% and if you were to drive with less than 20% in the tank the sloshing effect would be too great.

3

Hi Dave75,

Thanks for the reply; I know where you are coming from but the question is the right way around. For any product to increase by 20% and fill the ullage space due to thermal expansion is highly unlikely. Some products expand at a greater rate than others, some gasses (propane for one) has an expansion rate 10 times that of water and can still be loaded to 87%, some operators load propane to 92% if road weight is still legal. Basically I want to know if I can load a 30,000 litre tank with 2 baffles to 70%. With 2 baffles I would have 10,000 litres capacity between baffles and bulkheads. If the same 30,000 litre tank had 3 baffles I would have 7500 litres capacity between baffles and bulkheads, 7500 litres being the magic number in the ADR regulations, I want to know if there are any exemptions. It is not a question about product expansion or movement, but about the legal requirements for running tankers part loaded under ADR, could I split a 7600 pot of petrol and leave half on the vehicle for example?

4

Sorry Steptoe, that’s way beyond me so we’ll need to wait for one of the big boys to answer that one!

5

Way beyond me too, these baffles are baffling. :laughing:

6

steptoe:
Hi Dave75,

Thanks for the reply; I know where you are coming from but the question is the right way around. For any product to increase by 20% and fill the ullage space due to thermal expansion is highly unlikely. Some products expand at a greater rate than others, some gasses (propane for one) has an expansion rate 10 times that of water and can still be loaded to 87%, some operators load propane to 92% if road weight is still legal. Basically I want to know if I can load a 30,000 litre tank with 2 baffles to 70%. With 2 baffles I would have 10,000 litres capacity between baffles and bulkheads. If the same 30,000 litre tank had 3 baffles I would have 7500 litres capacity between baffles and bulkheads, 7500 litres being the magic number in the ADR regulations, I want to know if there are any exemptions. It is not a question about product expansion or movement, but about the legal requirements for running tankers part loaded under ADR, could I split a 7600 pot of petrol and leave half on the vehicle for example?

This post was removed at the behest of the author, as it was confusing two parts of ADR in the hope of answering a technical question. :blush:

7

steptoe:
Hi Dave, or anybody else that might know.

Under ADR it says that tankers that are divided by partitions or surge plates into sections of more than 7500 litres must not be filled less than 80% or not more than 20% of their capacity, however do you know of any exemptions? Is there anything under ADR which allows a tanker that does not meet those regulations to be filled to a level between 20% and 80%? I am having a debate about this subject; I am being assured by a work friend that if a vehicle/tanker with sections greater than 7500liters reaches its legal road weight but is only 75% filled, then it is legal. This seems a load of old balls to me as it would rubbish the original regulation. I seem to remember not being able to load heavy products like caustic and acids in some tanks because there was not enough baffles and they would only be at 65% full when loaded.

Thanks

Hi steptoe,

This should help settle your work friend’s thoughts about “legal road weight.”

ADR 4.3.2.2.4
Shells intended for the carriage of substances in the liquid state or liquefied gases or
refrigerated liquefied gases, which are not divided by partitions or surge plates into sections
of not more than 7 500 litres capacity, shall be filled to not less than 80% or not more
than 20% of their capacity.

As your work friend will see, there’s no mention of “legal road weight,” so if he has a reference for what he says, I’d be very interested to see it please.

Sometimes, people have difficulty with the word “shell,” so here’s the definition:

“Shell” means the sheathing containing the substance (including the openings and their closures)

Another way to express the above is:
If a tank (or compartment of a tank) has no baffles and has a capacity of more than 7,500 litres, then the above applies.

So if you have the type of tank or compartment that’s greater than 7,500 and it has no baffles, then you can’t fill it to more than 20% unless you carry on filling it until it contains more than 80% of its capacity.
Equally, you can’t discharge that type of tank/compartment to less than 80% unless you carry on discharging it until you have no more than 20% of its capacity remaining before you set-off back on the road.

Obviously, this can present problems on multi-drop work, so some careful planning is required.

:bulb: The above does not apply to tanks or compartments of 7,500 litres or less, nor does it apply to large single compartment tanks if they have baffles.

8

dave75:

steptoe:
Hi Dave, or anybody else that might know.

Under ADR it says that tankers that are divided by partitions or surge plates into sections of more than 7500 litres must not be filled less than 80% or not more than 20% of their capacity, however do you know of any exemptions? Is there anything under ADR which allows a tanker that does not meet those regulations to be filled to a level between 20% and 80%? I am having a debate about this subject; I am being assured by a work friend that if a vehicle/tanker with sections greater than 7500liters reaches its legal road weight but is only 75% filled, then it is legal. This seems a load of old balls to me as it would rubbish the original regulation. I seem to remember not being able to load heavy products like caustic and acids in some tanks because there was not enough baffles and they would only be at 65% full when loaded.

Thanks

Hi Steptoe, I know it’s a different Dave you were asking but I think you might have the rule the wrong way round. Should it not be that tanks should not be filled to than more than 80% and not less than 20%? You need to make room for the liquid expanding with temperature hence not filling it more than 80% and if you were to drive with less than 20% in the tank the sloshing effect would be too great.

Hi Dave.

I’m Dave. :smiley:

Steptoe did indeed have the question the right way around, but I think I can see how you were thinking.

Some substances are loaded to 97% without it causing problems, but the main thing is that there must be a gap left for safe expansion of the product Eg, for if the sun shines on the tank.

Different substances expand at different rates, so without going into some very complicated maths, the coefficient of cubical expansion and density of the substance has to be known, then there’s a complicated formula to be calculated to allow the correct expansion space for the substance (a.k.a ullage space.)
It’s most often the consignor (sender) who deals with this, because it’s not the kind of thing that a driver can usually calculate on the back of a ■■■ packet. :grimacing:

The sloshing effect of less than a 20% load isn’t considered dangerous enough to cause too much of a problem, and a substance loaded in excess of 80% in a tank hardly sloshes at all.

9

steptoe:
Hi Dave75,

Thanks for the reply; I know where you are coming from but the question is the right way around.

Indeed it is. :smiley:

steptoe:
Basically I want to know if I can load a 30,000 litre tank with 2 baffles to 70%. With 2 baffles I would have 10,000 litres capacity between baffles and bulkheads.

Yes, on the basis that the tank has baffles, but the amount between baffles makes no difference.

steptoe:
If the same 30,000 litre tank had 3 baffles I would have 7500 litres capacity between baffles and bulkheads, 7500 litres being the magic number in the ADR regulations, I want to know if there are any exemptions.

The 7,500 litres is the size of the tank or compartment. The amount between baffles makes no difference.

steptoe:
It is not a question about product expansion or movement, but about the legal requirements for running tankers part loaded under ADR, could I split a 7600 pot of petrol and leave half on the vehicle for example?

Under ADR, the answer is “no.”
However, ADR doesn’t automatically apply to all UK national carriage, so there may be something tucked away in a UK petrol-specific ACOP.

Have you been asked to split a 7,600 pot in this way?

10

Hello Dave

Thanks for that. I must have been glazing over at that point on my ADR course, the instructor talked about 20% and 80% volumes in tanks but obviously I wasn’t tuned in properly! I’ll get my coat :confused:

Dave

11

dave75:
Hello Dave

Thanks for that. I must have been glazing over at that point on my ADR course, the instructor talked about 20% and 80% volumes in tanks but obviously I wasn’t tuned in properly! I’ll get my coat :confused:

Dave

Hi Dave,

Maybe it wasn’t you who was glazing over. :grimacing: :wink:

12

Dave. It was the word unless in my snip that I have trouble with. Please explain where I am coming from or use your powers of Teacher to delete my post if it is misleading or unhelpful.

I went through “the Book,” looking for this and got sidetracked by Propylene Oxide and “dry break” couplings.

13

Wheel Nut:
Dave. It was the word unless in my snip that I have trouble with. Please explain where I am coming from or use your powers of Teacher to delete my post if it is misleading or unhelpful.

Hi Malc,
IMHO, it’s possible that you got sidetracked rather more than you thought, because your reference is to portable tanks when the question is about fixed tanks (tank vehicles.) ADR’s definitions of “tanks” in 1.2.1 needs to be read with great care. (Follow the italics. :wink: )

The meaning of ‘unless’ in your quote is to make it an offence to offer a non-baffled non-compartmented portable tank for carriage if the degree of filling is in excess of 20% but less than 80%.
Or in other words, if a portable tank has either compartments or baffles, then the 80/20 rule doesn’t apply.
However, the consignor and carrier of a portable tank must also have regard to the viscosity and temperature requirements, if applicable.

Wheel Nut:
I went through “the Book,” looking for this and got sidetracked by Propylene Oxide and “dry break” couplings.

My suggestion here is that you ‘go through the book’ at a time other than when looking for a specific answer.
I’ve seen people doing exactly that in a DGSA exam and it’s almost always fatal to their chances of passing, because they run out of time doing something other than addressing the question asked.
Strangely, I’m OK at being very focused when looking in ADR, but I admit I get sidetracked if I look up a word in a dictionary. :blush:

14

Dave.

Thanks for your quick and complete response.

I used the split pot as an example, it was the best I could come up with, I havnt driven a petrol tanker or split a pot for a few years now, too much like hard work. :laughing:

15

Hello Hello Hello. What have we here then?

And what would be the advice today?

16

Wheel Nut:
Hello Hello Hello. What have we here then?

And what would be the advice today?

Butoxyethanol - An organic solvent.

Does it come under ADR regs still?

17

dar1976:
Does it come under ADR regs still?

Hi Malc and dar1976,

Yes, but the way that ADR classifies substances and places warning signs on vehicles has changed greatly since that photo was taken including the fact that the UN number “2369” is no longer in use.

Whether that ‘stuff’ is subject to ADR isn’t straightforward and will depend on whether it counts as dangerous goods, which will in turn depend on the formulation and concentration of dangerous ingredients. If the ‘stuff’ to be carried for a particular job counts as dangerous, the transport document entry for Butoxyethanol should now be written like this:
UN 2810 TOXIC LIQUID, ORGANIC, N.O.S. (ETHYLENE GLYCOL MONOBUTYL ETHER), 6.1, PG III

Since the photo was taken, the info required on the orange plates for an international journey has also changed.

The top part of the orange board should now show the figure “60,” whilst the bottom part of the board should now show the figure “2810.” These orange boards should be shown on the front and rear of the tanker.
A 6.1 placard should also be shown on both sides of the tanker AND on the rear.

For this stuff, my advice would be to avoid bodily contact with it, whilst especially avoiding breathing the fumes/vapour.
For the carriage of this stuff, a respirator is a mandatory piece of PPE kit to be carried.

18

dieseldave:

dar1976:
Does it come under ADR regs still?

Hi Malc and dar1976,

Yes, but the way that ADR classifies substances and places warning signs on vehicles has changed greatly since that photo was taken including the fact that the UN number “2369” is no longer in use.

Since the photo was taken, the info required on the orange plates for an international journey has also changed.

The top part of the orange board should now show the figure “60,” whilst the bottom part of the board should now show the figure “2810.” These orange boards should be shown on the front and rear of the tanker.
A 6.1 placard should also be shown on both sides of the tanker AND on the rear.

For this stuff, my advice would be to avoid bodily contact with it, whilst especially avoiding breathing the fumes/vapour.
For the carriage of this stuff, a respirator is a mandatory piece of PPE kit to be carried.

I noticed the photo and like a good copper spotting the tax disc was out of date. I immediately noticed the missing Kemler numbers.

The reason I posted it was because of the obsolete UN number. Why would it be taken out of circulation or in this case left in the book but classified not in use?

19

Wheel Nut:

dieseldave:

dar1976:
Does it come under ADR regs still?

Hi Malc and dar1976,

Yes, but the way that ADR classifies substances and places warning signs on vehicles has changed greatly since that photo was taken including the fact that the UN number “2369” is no longer in use.

Since the photo was taken, the info required on the orange plates for an international journey has also changed.

The top part of the orange board should now show the figure “60,” whilst the bottom part of the board should now show the figure “2810.” These orange boards should be shown on the front and rear of the tanker.
A 6.1 placard should also be shown on both sides of the tanker AND on the rear.

For this stuff, my advice would be to avoid bodily contact with it, whilst especially avoiding breathing the fumes/vapour.
For the carriage of this stuff, a respirator is a mandatory piece of PPE kit to be carried.

I noticed the photo and like a good copper spotting the tax disc was out of date. I immediately noticed the missing Kemler numbers.

The reason I posted it was because of the obsolete UN number. Why would it be taken out of circulation or in this case left in the book but classified not in use?

Hi Malc,

I don’t pretend to know the mind of the lawgiver, but I can hazard a guess. (Please forgive the pun. :blush: :blush: )

I think it’s to do with the way they ‘rationalised’ the UN numbers since the changes in classification methods.

Here’s one you might remember…

UN 1270 used to be ‘Petroleum Fuel.’
UN 1271 used to be ‘Petroleum Spirit.’

There could easily be cases when a consignor was in doubt about which UN number to use on a transport document, so after ‘rationalising’ took place, we now have UN 1203 MOTOR SPIRIT or GASOLINE or PETROL, so consignors can choose which word they will use. Eg, Americans would use UN 1203 GASOLINE, whereas we’d usually use the word ‘PETROL’ in the UK.

20

dieseldave:
I don’t pretend to know the mind of the lawgiver, but I can hazard a guess. (Please forgive the pun. :blush: :blush: )

I think it’s to do with the way they ‘rationalised’ the UN numbers since the changes in classification methods.

Here’s one you might remember…

UN 1270 used to be ‘Petroleum Fuel.’
UN 1271 used to be ‘Petroleum Spirit.’

There could easily be cases when a consignor was in doubt about which UN number to use on a transport document, so after ‘rationalising’ took place, we now have UN 1203 MOTOR SPIRIT or GASOLINE or PETROL, so consignors can choose which word they will use. Eg, Americans would use UN 1203 GASOLINE, whereas we’d usually use the word ‘PETROL’ in the UK.

That will do for me, yes I did question the 1270 when I was bringing racing fuel back to Thornton Research Centre. Someone told me I had the wrong numbers up and I assured them it was correct at 1203, having loaded in Hamburg.