Thanks Dave, I’ll have to investigate further. It’s all UK work.
Dave - the Elephant has gone 
ROG:
Dave - the Elephant has gone
No ROG, it’s still there. Maybe you’re scrolling too quickly after the page opens… 
One for dieseldave, when carrying limited quantities (I am ADR / Haz pak qualified).
A) Am I right in assuming you only need to display placards saying “limited quantities” only if that is the product you are carrying plus your “tremcard”.
B) you must still show Orange Markers front and rear but don,t need to show class labels and product under transport eg. non-flammable gas class 2.
Thanks
Nej…what size of vehicle are you driving?
Glesgabill I drive a Class 1 44t.
GlesgaBill:
Nej…what size of vehicle are you driving?
That makes no difference to the question…
NEJ:
One for dieseldave, when carrying limited quantities (I am ADR / Haz pak qualified).
Limited Quantities makes you exempt from the ADR regs. So whether you’re ADR qualified makes no difference, since anybody can carry any amount of LQs – No ADR licence, no orange plates, no paperwork.
NEJ:
A) Am I right in assuming you only need to display placards saying “limited quantities” only if that is the product you are carrying plus your “tremcard”.
If all you have on board is LQs, then nothing else of ADR applies, including placards or tremcards.
NEJ:
B) you must still show Orange Markers front and rear but don,t need to show class labels and product under transport eg. non-flammable gas class 2.
If all you have on board is LQs, then nothing else of ADR applies. I’m not sure what you mean by “show” class labels or “product under transport.”
Labels are 100 x 100 mm and are placed on packages.
Orange plates are never required when carrying LQs
Please see my reply to Mr Flibble on page 1, because the priciple of LQs is often misunderstood. Since you mentioned “non-flammable gas class 2,” I can tell you that there’s NO LQ exemptions for gas cylinders. Or are you thinking of aerosols??
I’m sorry NEJ, but there isn’t much of a clue in your question.
I’ve a feeling that you might mean that you’re carrying a “below threshold” load.
I can sort this out quite quickly if you could please tell me the following:
UN number
The name of the gas
The UN class (I’m guessing it’s 2.2 with a green label)
Whether it’s gas cylinders or aerosols (They have different rules.)
The number and size of cylinders or the approx weight.
Sorry if I appear confused, it’s because I am…until I know a little more info from you
I’ve read the above few posts, and all is understood Dave…ignore my post above 
On the subject of ADR, i watched a lorry getting loaded today with several containers of class 9 “stuff”. I thought to myself, “that must be well over a ton now” as the forkie continued to load.
Did the lorry have orange boards, extuinguishers etc? Did it flip. The old driver guy looked like a villain from Scooby Doo and the forklift driver was a miserable b@stard…who am i to tell them their jobs?
Sorry for being confusing “dieseldave” but what I was carrying at the time was (I am told) small aerosols of saline solution (in a 40ft container) which I can,t remember the UN code but for some reason was given a “tremcard” by our office and when I picked up the container at Seaforth it had labels stating non-flammable compressed gas 2.2 so to be safe I put up orange plates front & rear and when got to the Mersey tunnel that is when they found that in their Haz. manual they had no record of the product I was carrying and to play safe they made me wait until after 10 am (tunnel regs don,t allow Haz on orange plates to travel between 07.30 & 10am & 1500 to 1730) then decided to turn me away anyway because they hadn,t been notified by our co.
The main question was could I have removed the 2.2 labels and not used orange plates and stayed legal ?
Sorry to be confusing, as I was issued with a tremcard I assumed that the load required haz. markings as I don,t want to run foul of the law in the event of an emergency I took what I thought was the right (obviously wrong now) and play safe way of doing the job.
The reason the markings were such on the container is because presumably, the load had travelled by sea under IMDG regs. In which case, i understand that the load of which you speak would be required to carry such markings as part of that leg of which would appear to be a multi modal journey.
The difference comes when the load travels by road-and it is possible that the load you described may well not come under ADR at all. (IMDG regs have applied…but that’s a different set of rules for a different mode of transport remember)
The way i see it, it’s possible that your load may well have not came under ADR and in any case, you would not require or have to alter any of the markings/placards.
I’ll bow as always to Dave’s superior knowledge when he reads this 
GlesgaBill:
The reason the markings were such on the container is because presumably, the load had travelled by sea under IMDG regs. In which case, i understand that the load of which you speak would be required to carry such markings as part of that leg of which would appear to be a multi modal journey.The difference comes when the load travels by road-and it is possible that the load you described may well not come under ADR at all. (IMDG regs have applied…but that’s a different set of rules for a different mode of transport remember)
The way i see it, it’s possible that your load may well have not came under ADR and in any case, you would not require or have to alter any of the markings/placards.
I’ll bow as always to Dave’s superior knowledge when he reads this
No bowing necessary mate.
You’ve hit the nail on the head and saved me some typing
I’ll clarify just one thing although you didn’t get it wrong. (Well, only slightly )
If a container arrives/departs by sea, and needs placards, (depends on how much “stuff” is inside it) the placards must remain in place ie. on the container for the initial/final road leg of the journey.
A vehicle or unaccompanied trailer may have its placards removed for the road legs of the journey. For vehicles, there’s no compulsion to remove or exhibit placards.
NEJ:
Sorry for being confusing “dieseldave” but what I was carrying at the time was (I am told) small aerosols of saline solution (in a 40ft container)
An aerosol has a lengthy definition, but saline isn’t dangerous in any case, so I’m imagining that there was maybe some kind of pressurised propellant, which could mean that these “things” might count as aerosols. IF that’s the case, the UN number was probably UN1950. Do you see how difficult this is without proper details??
NEJ:
which I can,t remember the UN code but for some reason was given a “tremcard” by our office and when I picked up the container at Seaforth it had labels stating non-flammable compressed gas 2.2
Containers are frequently “over-marked” by those without an understanding of IMDG.
Some IMDG requirements are significantly different to ADR’s.
Very often, people in transport offices give out “tremcards” unnecessarily
NEJ:
so to be safe I put up orange plates front & rear and when got to the Mersey tunnel that is when they found that in their Haz. manual they had no record of the product I was carrying and to play safe they made me wait until after 10 am
If it was UN1950, the tunnel regs DO list that UN number, and there are no restrictions on it. Given that there are no restrictions, I can’t see why they delayed you. But then again, they couldn’t find the UN number
NEJ:
(tunnel regs don,t allow Haz on orange plates to travel between 07.30 & 10am & 1530 to 1730) then decided to turn me away anyway because they hadn,t been notified by our co.
Blimey NEJ, I haven’t a clue where these “rules” are coming from. I’ve corrected the times you gave (in red.) I also think that what you were told about orange plates relates only to tankers. Your company’s DGSA is supposed to deal with this stuff as he/she has access to the info. I could also do it, but I need more help (solid info) please mate
NEJ:
The main question was could I have removed the 2.2 labels and not used orange plates and stayed legal ?
Insufficient info, I’m afraid. If you can supply the info in my last answer to you, I could at least make a start
NEJ:
Sorry to be confusing, as I was issued with a tremcard I assumed that the load required haz. markings as I don,t want to run foul of the law in the event of an emergency I took what I thought was the right (obviously wrong now) and play safe way of doing the job.
I don’t blame you for your cautious approach, but you really should enquire as to who your DGSA is and how you can contact them, since there is clearly much confusion in somebody’s office… The container people need a DGSA as does your company. Brown stuff might hit a large fan next time one of you carrying dangerous goods is checked by VOSA/police, because one of the questions they might ask is “please supply contact details for your DGSA…?”
As I said, if you get me some good info, I can help.
Thanks guys for the info as I seem to remember the UN possibly was UN 1950 but it was definitely Aerosols, as my mate (who went earlier than me) was told by the tunnel police to open the container to check what was on board.
They still couldn,t find a reference to what he had on board so let him go when they saw it was only saline solution in small aerosols but for some reason their sergeant said an emphatic NO till after the deadline.
I thnk the gas was a propellant for the aerosol that is where the 2.2 label came in .
I see the point about IMDG regs being different and placards having to remain on the container and as the regs are a minefield I didn,t want to run the risk of
running with none just in case, as my view is with any haz. load is to err on the safe side as our boss says better to have labels on just in case whether needed or not as we are not the emergency services and I wouldn,t like to think that someone was injured or worse for trying to pull a fast one.
NEJ:
I seem to remember the UN possibly was UN 1950 but it was definitely Aerosols
I thought so.
NEJ:
They still couldn,t find a reference to what he had on board so let him go when they saw it was only saline solution in small aerosols but for some reason their sergeant said an emphatic NO till after the deadline.
The book of Regs for tunnels is called “The British Toll Tunnels Handbook (13th Edition)” That covers the Dartford, Tyne and Mersey tunnels.
In there, they’d have found what they needed to know
NEJ:
I thnk the gas was a propellant for the aerosol that is where the 2.2 label came in .
That sounds right to me
NEJ:
I see the point about IMDG regs being different and placards having to remain on the container and as the regs are a minefield…
That’s the whole point of DGSA NEJ. The Regs are perfectly clear to those who are trained and qualified— DGSA isn’t a fancy job title dished out on a boss’s whim. It’s a proper (formal) qualification. Your company needs to have one appointed. It’s that simple, so where’s this “minefield” at then??
NEJ:
…I didn,t want to run the risk of running with none just in case, as my view is with any haz. load is to err on the safe side as our boss says better to have labels on just in case whether needed or not …
Please have another think about that NEJ, if everybody did that, they’d totally devalue the idea of hazard signs-- far more dangerous IMHO.
I’ve seen many people “err on the safe side” but in this case I’d ask: The safe side of something they know nothing about is where 
Since we’re talking about the “safe side,” does your firm/boss have orange plates on their cars?? (Petrol and Diesel are dangerous goods )
That’s where it all gets silly. They seem to invent “rules” that aren’t there and ignoring ones that are, all whilst strenuously avoiding reality. Worse than that, they’re not even consistent about doing whatever it is that they’re doing or not doing.
TBH mate, it’s far easier to do the job properly that to do it any other way.
It must be very distracting and time consuming for anybody having to spend the time to make up these new “rules.”
NEJ:
…as we are not the emergency services …
Another excellent point NEJ, The Regs exist for the protection of all including the emergency services. The regs say that it’s sometimes legal to carry dangerous stuff in little packages. That’s called “limited quantities” which EXEMPTS you/your firm from the Regs. There are many other exemptions. What your firm is doing might actually be criminal, and even very misleading to the emergency services in the event of an incident. By having unnecessary markings, it suggests that there’s more of the goods than there actually is, or that they come in much larger sized packages. This logic is very baffling, the firm might do something that ISN’T requirerd, whilst possibly ignoring something that IS required.
I’d love to hear your boss’ explanation of why he sticks his head in the sand, whilst hoping that labels mask the possibility that his arse is a fair target
NEJ:
I wouldn,t like to think that someone was injured or worse for trying to pull a fast one.
I absolutely agree with you there NEJ, your firm is pulling a fast one if they don’t have a DGSA and obey the rules correctly, because somebody might get hurt.
( that’s CHECKMATE on your boss I believe )
Hi dave i work for a company who transports fork lift trucks, occasionaly we get asked to collect some fork truck batteries which vary in size from 500kgs to 2000kgs. Ive been told that if they are shrink wrapped or banded to a pallet then we are well in the law to carry them without holding an ADR licence.
trigger:
Hi dave i work for a company who transports fork lift trucks,
There’s actually two questions here trigger, this first one is very straightforward.
A forklift with the batteries assembled and mounted in the normal manner is:
UN3363 DANGEROUS GOODS IN MACHINERY, 9. So that means that it’s dangerous goods of class 9.
HOWEVER, it isn’t regulated by ADR, provided that:
ADR:
measures have been taken to prevent any leakage of contents in normal conditions of carriage
So, if that’s complied with, you’re completely exempt from all other ADR requirements when you carry complete FLTs.
trigger:
occasionaly we get asked to collect some fork truck batteries which vary in size from 500kgs to 2000kgs. Ive been told that if they are shrink wrapped or banded to a pallet then we are well in the law to carry them without holding an ADR licence.
To answer this question I have to ask whether the batteries are filled with (wet) acid or alkali**■■** (Please answer that )
Assuming that they are, then they’re called either:
UN 2794 BATTERIES, WET, FILLED WITH ACID, electric storage, 8
UN 2795 BATTERIES, WET, FILLED WITH ALKALI, electric storage, 8
(Neither of these have a Packing Group.)
You’re spot-on about ADR not applying if the batteries are banded or shrink wrapped onto a pallet.
ADR does not limit the size, weight or number of these “wet” batteries that you can carry.
This is from a partial exemption called SP598(a), but there’s also the following that needs to be correct too:
- 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;
(All batteries follow the quote above, whether new or second-hand and must comply with marking rules below.)
If the batteries are used
The rules are slightly different.
Definition of used:
“Used storage batteries” means storage batteries carried for recycling at the end of their normal service life.
Now you know the definition, are the batteries “used”
Marking rules
If the battery or batteries are not individually marked with the UN number and a class 8 label, then the following applies:
(Because what you’re carrying becomes an “overpack” according to ADR )
“UN 2794” (Or UN 2795) must be written on the shrink wrap, or it can be a sticker like this:
There must also be 2 of these on the shrink-wrap, one on each side:
Or the arrows can be indelibly hand-drawn.
There must also be a “proper” one of these on the pallet too:
And finally, there must also be one of these:
It can be a sticker, or the word “OVERPACK” can be indelibly handwritten.
Since this is only a partial exemption, it needs to be complied with in full, because the bits above DO apply, THEN you don’t need an ADR licence, or orange boards, or extinguishers or, or ,or etc.
Mind you, all of the above is for the sender (consignor) to deal with, your boss (the carrier) only needs to make sure that the consignor has done their bit, otherwise it’s you and your boss who suffer the delay whilst the nice VOSA guy writes you a ticket and maybe a PG9 too
Forgive the long post, but this is a question I get asked very often.
I’ve not covered this subject in the forums yet, the reason why I’ve covered it in such depth for you is so that I can refer others to it in future.
Saves typing.
Before anybody asks, it isn’t Limited Quantities 
Was this helpful
Very helpful Dieseldave but il find out about Acid or Alkali filled and get back to you about that. All the best for christmas buddy.
trigger:
Very helpful Dieseldave but il find out about Acid or Alkali filled and get back to you about that. All the best for christmas buddy.
Cheers for that trigger, it’s nice to know that my efforts are appreciated.
I’ll keep my eye open for your answer
Hello all & a happy new year to you!
Question for you Dave-
What changes have their been to the ADR Regs since 1/1/08 ?
I seem to remember that the amounts of powder in fire extinguishers carried on vehicles over 7.5 tonne will change from the current-
Min 2Kg in the cab
12kg on the body of the vehicle (one must be a minimum of 6kg)
and are there other changes that we should be aware of?
Cheers,
Glesga Bill