Dangerous goods advice- UK regs and ADR

ASK THE EXPERTS SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE
181

jay jonezy:
Having had a time out break from H.G.V . driving class 2 only and only worked in delivering frozen food industry ive joined an agency and am currently working for and a local ish company my question is how much dangerous good can i transport on an 18 tonne 14 pallet wagon in layman terms please i.e how many 20 litre containers of oil or bleach
how many 50 litres drums of oil or chemicals
whats the limit on flammable items i can carry without an ADR
am i legal to carry a ibc container think theyre a 1000 litres, without an ADR ive tried looking online but its confusing , thank you for youre help

Hi jay jonezy,

I’m sorry, but there is no “layman terms” way of answering your question.

I’ll start by telling you that this isn’t your problem to solve, so please don’t worry about it.

ADR (and UK law) requires that anybody who carries any type of dangerous goods needs to have some ADR ‘awareness’ training, and for that training to be documented and relevant to whatever job needs to be done.
(This is NOT the same as an ADR licence, it is ONLY ‘awareness.’)

ADR also requires the carrier (= vehicle owner) to see to it that anybody they ask to move dangerous goods has had AT LEAST the awareness training. Therefore, the carrier should ask you (or your agency) whether you have had ADR ‘awareness’ training before engaging you to carry any dangerous goods.

An agency should see to it that you’ve had ADR ‘awareness’ training and keep a record of it.
Common sense (and the law) dictates that an agency should do this before sending you to a client that wants you to move dangerous goods.

:bulb: It’s all about the right people asking the right question at the right time, because if this is handled in a sensible way, then the ADR ‘awareness’ training can also count as a 7hr topic for your periodic DCPC all at the same time.

==================

In order to get anywhere near a good answer to your question, I’ll explain that ADR has a multitude of exemptions whereby sometimes you could even end up carrying full load of dangerous goods without even the need for anything, including paperwork. :open_mouth:

There’s a lot of mind boggling detail about: the type of dangerous goods, they type and size of packagings and the amount to be carried. It is mind-boggling because ADR deals with this on a substance by substance basis. There’s then also the little problems caused by things like mixtures and solutions as well as the strength of the ‘stuff.’
Strange but true!!

As a (very) rough guideline… if the owner of the vehicle says that a load is not subject to the full requirements of ADR (= ADR licence, orange plates etc etc) then you’re good to go and the responsibility for that being correct rests squarely on HIS shoulders.

:bulb: Without the required ADR ‘awareness’ though, you’d be entitled to form your own opinion of the agency or the transport company.

:bulb: You could go it alone and get your own ADR ‘awareness’ though and count it as part of your legal requirement for 35hrs of periodic DCPC.

I hope this helps. :smiley:

182

Hi , Just an enquiry with reference to carrying Vehicle Batteries Palletised with thick shrinkwrap around the pallets.
The UN Number is UN2794 .
I believe these goods would fall under Transport Cat 3.

Could you confirm the maximum weight of these goods that can be carried per Transport Unit. ( I am an ADR Licence holder and think it is 1000 kg per transport unit ■■? )

I collect from a battery stockholder, in groupage i.e 5+ pallets back to hub where pallets are then trans shipped around the UK. I am an ADR licence holder, yet no ADR plates/extinguisher Etc are supplied on the said collecting vehicle.

Your confirmation of the above movements of goods would be appreciated.
With Thanks. Jon

183

JON LAD:
Hi , Just an enquiry with reference to carrying Vehicle Batteries Palletised with thick shrinkwrap around the pallets.
The UN Number is UN2794 .
I believe these goods would fall under Transport Cat 3.

These goods (UN 2794) are most probably totally exempt from ADR.
UN 2794 has a “special provision” called SP598, which if the consignor fulfills, would trigger the exemption. Now the strange bit: I can see how you got to 1,000kgs by thinking that batteries were goods of UN Class 8, PGIII, but in fact UN 2794 doesn’t have a packing group assigned. :open_mouth:

JON LAD:
Could you confirm the maximum weight of these goods that can be carried per Transport Unit. ( I am an ADR Licence holder and think it is 1000 kg per transport unit ■■? )

If SP598 applies, then there is no limit per transport unit on the basis that the goods are ADR exempt.

If yopur groupage load includes other ADR stuff, then the batteries can be ignored when deciding whether the ADR threshold limits are exceeded.

JON LAD:
I collect from a battery stockholder, in groupage i.e 5+ pallets back to hub where pallets are then trans shipped around the UK. I am an ADR licence holder, yet no ADR plates/extinguisher Etc are supplied on the said collecting vehicle.

If SP598 applies, there would be no requirement for orange boards, or extinguishers or even an ADR certificated driver.

JON LAD:
Your confirmation of the above movements of goods would be appreciated.
With Thanks. Jon

No probs, JON LAD, it’s a pleasure.

Please note that it is the consignor, who has to palletise and label-up etc, and the carrier who decides whether the Regs apply, selects a suitable vehicle, and assigns an ADR trained driver, if the regs require it.

If you have any further doubts, I could post SP598, so that you can check whether the consignor is compliant. Please just ask. (It’s not very big or complicated.)

From my experience, SP598 is a very common (and perfectly legal) way of transporting UN 2794 by road.
(It would be a very different matter by sea or air though :wink: )

184

Hi Dave - do you know if the ADR 80/20 rules apply to an older tank, 1998 under CDG/UK tank ?

Cheers in advance

185

Sniffy:
Hi Dave - do you know if the ADR 80/20 rules apply to an older tank, 1998 under CDG/UK tank ?

Cheers in advance

Hi Sniffy,

As a general requirement, the 80/20 rule in ADR applies to tanks (or compartments of tanks) which are greater than 7,500L and have no baffles, or the baffles that it does have are insufficient to divide up the volume between baffles to 7,500L or less.

I’d be very interested to know what marks are on the tank plate, and whether you’re still able to get the tank certificated these days?

186

Hi Dave
I have a question regarding carrying a new employee and giving on the job training. We are sometimes told to take out a new employee and show them how to conduct certain deliveries, using compressors or pumps. Our concerns is what equipment should the new employee have at his/her disposal. I have looked at ADR. 8.1.5.2 and surely they should have more protection than is listed?
Our TM just states he has investigated the issue and is happy for us to take them regardless.
As always your help and assistance is appreciated.

187

Just for information the officers at the Dartford tunnel are actually very helpful and seem to enjoy dealing with anything out of the ordinary.
I have had a few items that have required me to report to the office and then join the escorted convoys.
Even occasionally strange limited quantity stuff that normally wouldn’t require placards but did need an ■■■■■■ !
We used to deliver to a testing lab that sits under the bridge.
If you google the Dartford crossing you can find a pdf that lists all the permitted and prohibited goods and the procedure for transit of the tunnel, it is a copy of the manual that they use in the crossing control office .
Interesting reading for the geeks !
But it can save you unnecessary detours .

Sent from my SM-G903F using Tapatalk

188

grumpyken52:
Just for information the officers at the Dartford tunnel are actually very helpful and seem to enjoy dealing with anything out of the ordinary.
I have had a few items that have required me to report to the office and then join the escorted convoys.
Even occasionally strange limited quantity stuff that normally wouldn’t require placards but did need an ■■■■■■ !
We used to deliver to a testing lab that sits under the bridge.
If you google the Dartford crossing you can find a pdf that lists all the permitted and prohibited goods and the procedure for transit of the tunnel, it is a copy of the manual that they use in the crossing control office .
Interesting reading for the geeks !
But it can save you unnecessary detours .

Sent from my SM-G903F using Tapatalk

Like this.Tapatalk Cloud - Downlaoad File Dartford%20ADR%20List%20%20%28Website%29.pdf

Sent from my SM-G903F using Tapatalk

189

Ubiquitous:
Hi Dave
I have a question regarding carrying a new employee and giving on the job training. We are sometimes told to take out a new employee and show them how to conduct certain deliveries, using compressors or pumps. Our concerns is what equipment should the new employee have at his/her disposal. I have looked at ADR. 8.1.5.2 and surely they should have more protection than is listed?
Our TM just states he has investigated the issue and is happy for us to take them regardless.
As always your help and assistance is appreciated.

Hi Ubiquitous,

At first sight, the actual equipment specified in ADR 8.1.5.2 does seem to be woefully inadequate, so I can see why you asked this question.

We need to see that there’s a world of difference between ‘legal requirements’ and ‘Site Rules’ (= company policy.)

The minimum legal requirement “for each member of the vehicle crew” is per person on board the vehicle whilst out and about on the roads.

:bulb: Enforcement Officers can only ask to see those items, which should keep delays at checkpoints to a minimum because there’s not that much for them to ask to see. :wink:

Site Rules and Company Policy may require a whole pile of extra PPE and equipment to be carried in order to allow access/working at the different loading and unloading sites you may visit.

As to the letter of the law, I’m in broad agreement with your TM on this one as long as he’s considered whether he’d like you and your trainee to have a bit more kit as the result of a general risk assessment and Safe System of Work (SSW.)

190

grumpyken52:
…If you google the Dartford crossing you can find a pdf that lists all the permitted and prohibited goods and the procedure for transit of the tunnel, it is a copy of the manual that they use in the crossing control office .
Interesting reading for the geeks !
But it can save you unnecessary detours .

That’s very good, thanks for that. :smiley:

191

Hi Dave
Thanks for your advice I’ll share your answer with the other drivers, its something that needs to be sorted.

192

dieseldave:

8wheels:
For example, could I move a 3000l tank with 1000l in it.

Using the words “tank” or “package” the answer is: 'fraid not. It’s decided by the nominal capacity, rather than the amount actually in it. It’s academic in your case, but the maximum allowed size for an IBC is 3,000 litres. Without an ADR licence, you’ll still be caught by the 1,000 litre limit per vehicle though, because an IBC is counted as a package.

Dave

I always understood this to be the case i.e. capacity not contents but I couldn’t find that rule recently in the ADR books. You haven’t got a reference have you?

Pete.

193

dieseldave:

8wheels:
For example, could I move a 3000l tank with 1000l in it.

Using the words “tank” or “package” the answer is: 'fraid not. It’s decided by the nominal capacity, rather than the amount actually in it. It’s academic in your case, but the maximum allowed size for an IBC is 3,000 litres. Without an ADR licence, you’ll still be caught by the 1,000 litre limit per vehicle though, because an IBC is counted as a package.

Peter K:
Dave

I always understood this to be the case i.e. capacity not contents but I couldn’t find that rule recently in the ADR books. You haven’t got a reference have you?

Pete.

Hi Pete,
Sorry mate, but I can’t quite tell which quote you’re asking for, or which “ADR books” you are using.
In any case, your question doesn’t relate to any part of a driver’s duties, unless the driver also owns the truck, since it’s for the “carrier” and the “consignor” to decide whether the Regs apply. BTW, both the “carrier” and the “consignor” must have a properly qualified (by examination) DGSA, unless they’re exempt from that requirement.
:blush: It’s possible that I haven’t correctly understood your question, due to a large number of variables. :blush:

The eventual answer to your question will depend upon whether you’re asking about a liquid, a solid or a gas (you’d need to do this by quoting the “proper shipping name”) and which type of receptacle/package/tank is to be used. I’m afraid it isn’t as straightforward as “nominal capacity” in all cases. That’s the reason that you couldn’t find the rule that you’re looking for. I’m also afraid that the UK doesn’t blindly follow ADR at all times, especially on a particularly “British” question, like a “UK journey.” In cases when we don’t follow ADR, we have a set of Regs called "The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007. (We shorten this to CDG 2007.) Sometimes, we have further exemptions granted by the DfT.

I do apologise if I appear vague, but 8-wheels’ question was about a specific substance in a specific type of package being carried in the UK. Not all of my answers to his questions can be found by looking in ADR :wink: If you’re using ADR on its own for UK journeys, you’re possibly commiting one or more offences.

I’m steering away from quotes at the moment, until I know exactly which books you’re using and I’m happy that I’ve understood your question correctly. Believe me, if I start with quotes and you’re not using the full set of current law-books, the quotes won’t mean anything to you. :wink:

I hope this helps :confused: (I have a feeling that this one might go to PMs :wink: )

194

Hi Dave,

I’ll try and explain what I mean, but of course if you would prefer me to go to PM I will. I’m going on from 8wheels question, if he was to carry UN1202 diesel in say drums with 200 ltr capacity but with only 100 ltrs in each drum, then for the purposes of the load size thresholds would the amount to be used for the calculation be the capacity or the contents? In the past it was definitely the capacity but I can’t see that anywhere in the regulations now. I have access to ADR 2007 so if you had a reference I could find it.

Thanks
Pete.

195

Peter K:
Hi Dave,

I’ll try and explain what I mean, but of course if you would prefer me to go to PM I will. I’m going on from 8wheels question, if he was to carry UN1202 diesel in say drums with 200 ltr capacity but with only 100 ltrs in each drum, then for the purposes of the load size thresholds would the amount to be used for the calculation be the capacity or the contents? In the past it was definitely the capacity but I can’t see that anywhere in the regulations now. I have access to ADR 2007 so if you had a reference I could find it.

Thanks
Pete.

Hi Pete.
Now I understand the question- thanks for the clarification. :wink:

The reference you need is ADR 2007 1.1.3.6.3

If the drum(s) had been normally drained of dangerous goods, (ADR calls this “nominally empty.”) there would of course be some residue of dangerous goods remaining inside. In that case, the drum(s) would be in TC4 and could be carried by an untrained driver in any quantity and without orange boards etc… (Please see the entry for TC4 in the table at 1.1.3.6.3 and note that the load threshold for TC4 is “unlimited.”)

A 200 litre drum containing 100 litres could not be argued as being “nominally empty,” so the load limit for diesel fuel would apply. Diesel fuel is in TC3, so the limit is 1,000 litres. You could therefore load five such drums, before ADR applies in full, since the “nominal capacity” of the drums is 200 litres. This is also in 1.1.3.6.3 just after the table. If you read that reference, you’ll see why I mentioned about whether your question related to liquids, solids or gases. :wink: You’ll also see that gases are treated differently, dependant upon whether they’re liquified. :open_mouth:

To clarify “nominal capacity,” a drum is normally around 205 - 210 litres ACTUAL capacity, but the extra 5 or 10 litres of space is required for possible expansion of the liquid contents due to warm weather. (This extra space is called “ullage.”) Even if the drum is 210 litres actual size, for ADR’s purposes we’d only count 200 litres for the calculation of load thresholds in 1.1.3.6.3.

196

As I mentioned in my other thread - UN2984, Oxidising Agent, “1.5” in the bottom of the diamond, 25-litre barrels. What (if any) LQ exemptions are there?

TIA…

197

Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn’t spotted.

Pete.

198

Peter K:
Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn’t spotted.

Pete.

Hi Pete, no problem mate.
You do have to be careful when reading ADR :wink:
A complicating factor is that the rules for UK journeys are sometimes slightly different, so not all of ADR always applies in the UK.

Not all of the rules can be found by reading, some are “implied.” That’s one reason why the DGSA exams are so difficult to pass. It did get me wondering whether your company were using you as a DGSA. The strange thing is that DGSA isn’t a job title that a boss can just hand out. It’s a very specific qualification, which needs a vocational certificate issued by SQA on behalf of the DfT to prove you have passed the 3 necessary exams.

199

MrFlibble:
As I mentioned in my other thread - UN2984, Oxidising Agent, “1.5” in the bottom of the diamond, 25-litre barrels. What (if any) LQ exemptions are there?

TIA…

Hi Mr Flibble,

This substance is called:
UN 2984 HYDROGEN PEROXIDE, AQUEOUS SOLUTION, 5.1, PGIII.

To take advantage of LQ exemtions, the consignor would have to pack this substance in 1 litre tubs/bottles and place several in a cardboard box. The consignee would also have to be happy to receive his consignment packaged in this way. What works for a retail shopkeeper wouldn’t necessarily be acceptable to a person buying the same substance for industrial use. In this case, the cardboard box isn’t allowed to weigh more than 30kgs. IF that’s complied with, then there’s no load limit per vehicle and the rest of ADR doesn’t apply. (No orange boards, no ADR licence, no specific docs, you could carry a full load etc etc…)

The boxes would look something like this:

For the substance in your question, the boxes would also need a white label (100x100mm) like this:

Since you mentioned 25 litre drums, the question of LQs cannot arise. The maximum LQ size for any substance is 5 litres for liquids and 6kg for solids, but not all of them are allowed to be packed into receptacles of those sizes. For example, the LQ size for UN 2984 is 1 litre as above. There are approx 26 different combinations of inner Vs. outer package sizes for LQs, and the allowed sizes depend upon the particular substance in question. For the substance in your question, the code assigned is: LQ13.

However, there is another way that an untrained (in an ADR sense) driver could legally carry this stuff in packages. This doesn’t rely on package sizes though, so the packages could be the 25 litre drums you mentioned for instance. If this were the case then the limit would be 1,000 litres per vehicle. 1,000 litres (or less) per vehicle would require a 2kg dry powder fire extinguisher to be carried on board the vehicle for a UK journey. If it were an international journey, then there would be an additional requirement for a transport document (Please see my reply to 8-wheeels above) In either case, the carriage of UN 2984 in drums requires special vented caps to be fitted to the drums.
This 1,000 litre exemption ISN’T called LQs :wink:

It would also be dangerous to assume that there’s a blanket exemption of 1,000 litres for all substances. For some substances, the limit would be 20kg/ltr, for others the limit would be 333kg/ltr. For some others, there’s NO exemption whatsoever, and for others, there’s NO LIMIT whatsoever. These limits depend on the particular substance involved. If carriage by sea was involved, the goalposts would move still further :open_mouth:

If the load of UN 2984 wasn’t packaged in LQs, the packages would need correct labelling (see below.) Then if there were to be more than 1,000 litres going on the vehicle, the driver would need an ADR licence and the rest of ADR would apply, such as orange boards, documentation and PPE etc etc…

I’m guessing that there’s a typo at work here MrFlibble, [because class 1.5 is an explosive :open_mouth: ] OR the UN number is wrong. My guess is that the label you saw looked like this:
(With OR without the words “OXIDISING AGENT.”)

Does this help??

200

dieseldave:

Peter K:
Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn’t spotted.

Pete.

Hi Pete, no problem mate.
You do have to be careful when reading ADR :wink:
A complicating factor is that the rules for UK journeys are sometimes slightly different, so not all of ADR always applies in the UK.

Not all of the rules can be found by reading, some are “implied.” That’s one reason why the DGSA exams are so difficult to pass. It did get me wondering whether your company were using you as a DGSA. The strange thing is that DGSA isn’t a job title that a boss can just hand out. It’s a very specific qualification, which needs a vocational certificate issued by SQA on behalf of the DfT to prove you have passed the 3 necessary exams.

Thanks again Dave, I was having a moment , where I couldn’t remember where that note was and didn’t have my books with me. I should have remembered given that I’ve passed my DGSA exams twice, run DGSA courses and act as DGSA to several companies! I also have an ADR centre and would be interested in talking to you about your freelance instruction - are you fully committed? Do you mind if I send you private mail?

Pete.