Dangerous goods advice- UK regs and ADR

[dieseldave]

FROM ANOTHER THREAD: (HERE)

I:
All I can say for a fact is that there’s to be a big meeting in Glasgow tomorrow (18th) due to kick-off at 10:30.

Then

gsm31:
Dave,any updates on what,if anything, was decided at the meeting?

Copied, pasted and answered here to avoid hijacking an OP with an unconnected topic.

Hi gsm31, it was a consultation meeting, so nothing concrete was decided.

Background. The UK is a member of ADR. When a country joins ADR, it must appoint somebody, usually a Government department, to be the Competent Authority (CA) for all ADR matters upon that country’s territory

In the UK, the CA function is performed by the Department for Transport (DfT.) In turn, the DfT has ‘subbed out’ some of the functions, for example the Scottish Qualifications Authority (SQA) are the examining body, and they’re responsible (to the DfT) for the approval and continuous monitoring of ADR courses, premises and instructors. SQA also marks the exams and transmits the results to DVLA, Swansea. The authority to print and issue ADR licences is given to DVLA Swansea, but DVLA is still answerable to the DfT and must perform as per the DfT contract. There are other ‘subbed out’ functions, but they’re not relevant to this discussion. However, the DfT remain in overall charge.

Proposals One of the proposals was that the idea of ‘pick-and-mix’ training as done in the UK should be got rid of on the grounds that the UK is in breach of ADR with regard to driver training. For many years, it has been possible (in the UK) to do a ‘pick-&-mix’ of the ADR modules. For example, the bottled gas (LPG) industry typically had Core, Packages and UN Class 2, because that’s all their guys needed to carry gas cylinders. In the same way, the petrol delivery industry just did Core, Tanks and UN Class 3, which covered them for flammable liquids carried in tankers.

Although there are some ‘vested interests’ who asked me to come up with a counter argument to this, I was unable to come up with a legal argument against it. Since this was a consultation meeting, I’d say it’s far from decided yet, because the DfT might tell us that it’s OK to carry on as we are. Personally, I hope they do, but I’m prepared that they might not.

Another proposal was that we get rid of the present idea of the way that ‘refresher’ training is carried out. The present system allows that a person may renew their ADR entitlement by attending a ‘cut-down’ (by approx 50%) version of the original course they attended. The proposal is to get rid of the idea of ‘cutting-down,’ but to retain the idea of refreshing but by attending the full version of the original course. My own opinion of this is that I agree that a 50% cut down after almost 5 years isn’t helpful to the candidate, because it places far too much strain on both them and the instructor to adequately ‘refresh’ that knowledge, when we take into account all changes in the law in that 5-year period. The statistics seem to prove that guys doing refreshers under the current system are struggling to pass the exams. In my opinion, this is due to the way we have to ‘blitz’ the refresher training. Again, we must wait for the DfT to make the final ruling.

Another proposal is to shorten the initial ADR course to Core, Packages and seven classes to three days including taking the exams, compared to the 3.5 days we have at present. In the same way, it’s also been proposed to shorten the tanker module to one day, rather than the 1.5 days we have at present. This proposal, if adopted, will potentially affect my income.
You can have a guess at my opinion of that, but there won’t be any prizes if you guess correctly.

Having said the above, it’s all speculation until the DfT says what is going to happen, since it was a consultation meeting for SQA to get the views of the training industry before submitting their proposals to the DfT for inclusion in forthcoming legislation.

[dieseldave]

This question was originally asked by steamer HERE,
but answered here in order to avoid going off a topic in the newbies’ forum.

steamer:
I know this is a complex question, but what do they teach you on the ADR courses. Is there anywhere I can have a look to see exactly what they show you and examine you on?

Hi steamer, yes mate it is without doubt a complex question.

Info on the exact content of a UK ADR course isn’t generally available on the Internet.
Although nobody has ever told me why this is the case, I can find no regulation which actually forbids publishing such info on the Internet.

So I engaged my brain ( which is quite risky these days ) and I’ve come up with some possible reasons for why nobody has done.

1. Nobody could be bothered to do it, or
2. People would start doing their own research, whilst having absolutely no idea of the level of knowledge or scope required for each subject area.
3. The law requires that an ADR course is an attendance course, so the publishing of info would be a waste of everybodies time, cos the candidates must attend anyway.
4. An ADR course requires approval from SQA before it can be used.

That’s why I stick to just answering questions rather than attempting to provide a whole on-line course.

In order to fully answer your question, I’d write the subject areas, then somebody else is bound to start asking for details on some/all points raised, then I’d sit here typing for hours and hours…
WADR mate, that’s not going to happen, but please don’t be offended.

For reason #2 above, I strongly advise candidates NOT to undertake their own research.

General info:
The ADR course is graded as a level 2 course; which means that, in terms of the difficulty of the exam questions, it’s approximately the same as a GCSE or NVQ2.

Having said that, the exam questions are ALL multi-choice. They are short non-technical questions just like on ‘Who wants to be a millionaire’ with the options being a choice of A, B, C or D which you indicate on an answer sheet that looks a bit like a lottery ticket.
There’s no writing to do on the answer sheets, apart from copying your name and driver number from your driving licence, which must be on your desk during the exam.
You indicate your chosen answer by simply drawing a line in a box.

Anybody with a DVLA Swansea issued driver number is eligible to take the ADR exams, and the ADR certificate is automatically valid for whatever driving licence class you hold. If you do a driving licence upgrade eg. you hold a car licence, then pass Cat “C” at a later date, there’s NO further action needed on your part in connection with your ADR certificate, it simply ‘follows’ you.

I hope this answers your question, at least in part anyway.
I also hope that you understand that I needed to draw something of a line at some point on this topic, because anything more than the above would be counter-productive IMHO.
I hope I struck the right balance.

[steamer]

Thanks for the answer. Understand the reasons - it could all get a bit out of hand so to speak. What you say in your reply gives enough info on the subject. Cheers again.

[dieseldave]

steamer:
Thanks for the answer. Understand the reasons - it could all get a bit out of hand so to speak. What you say in your reply gives enough info on the subject. Cheers again.

Hi steamer, thanks for your understanding mate, I appreciate that.

I’m still here to answer questions though, and quite happy to do so.

[dieseldave]

This post is copied in from the Newbies’ Forum

Hutchie:
Whats the ADR catagories? i know 2 of them but unsure what the rest are?

Class 1 - Explosives
Class 2 - Gas

Hi Hutchie, You’re spot-on up to now mate.

ADR has 5 “transport categories,” which aren’t the same thing as the “9 danger classes.”

The classification system (classes) comes from the UN, and is valid for all modes of transport.
The idea is that it covers ships and aeroplanes worldwide, not just EU trucks and ADR.

Class 1 Explosive substances and articles
Class 2 Gases
2.1 Flammable gases
2.2 Non Flammable, Non-toxic gases
2.3 Toxic gases
Class 3 Flammable liquids
Class 4.1 Flammable solids, self-reactive substances and solid desensitized explosives
Class 4.2 Substances liable to spontaneous combustion
Class 4.3 Substances which, in contact with water, emit flammable gases
Class 5.1 Oxidizing substances
Class 5.2 Organic peroxides
Class 6.1 Toxic substances
Class 6.2 Infectious substances
Class 7 Radioactive material
Class 8 Corrosive substances
Class 9 Miscellaneous dangerous substances and articles

Here are the relevant danger warning signs for the 9 classes:

UN Class 1

UN Class 2

UN Class 3

UN Class 4

UN Class 5

UN Class 6

UN Class 7

UN Class 8

UN Class 9

[dieseldave]

Hi BuzzardBoy, I have every sympathy for your plight when people look at your ADR certificate, but the simple answer is that they MUST accept your certificate as being perfectly valid.
The easy answer to your question is to say that SQA were spot-on with the answer they gave you.

The following is written in the knowledge that I know you do international work, meaning that we can totally ignore the UK dangerous goods Regs, because ADR applies “door-to-door” in full, apart from any period you spend on a ferry.
If you’re ever doing ‘UK only’ work, I can come up with a quote that says your ADR licence is still valid for that too.

Here are the legal reasons for me saying that people MUST recognise your ADR certificate:

BuzzardBoy:
My ADR License is in German, as i took the course in Swiss, although the company that did the course are based in Lichtenstein, so it has an FL country stamp on it, and is in German.

Here is a list of the countries who are contracting parties to the ADR agreement:

……the Contracting Parties are Albania, Austria, Azerbaijan, Belarus, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Kazakhstan, Latvia, Liechtenstein, Lithuania, Luxembourg, Morocco, Netherlands, Norway, Poland, Portugal, Republic of Moldova, Romania, Russian Federation, Serbia and Montenegro, Slovakia, Slovenia, Spain, Sweden, Switzerland, The former Yugoslav Republic of Macedonia, Ukraine and United Kingdom. [EDIT] To which we can now add: Eire.

BuzzardBoy:
Now, i would like to, if possible exchange it for an English ADR license, as it does draw some strange looks when you present it to people when loading ADR, as they cannot understand it!!

TBH mate, I can’t understand how/why the loading people can’t understand your ADR certificate, because it was correctly issued by the Competent Authority of a contracting party to ADR. In the next quote, you’ll see that the ADR certificates are standardised, to avoid exactly the problem you’re describing…

8.2.1.8 All training certificates conforming to the requirements of this section and issued in accordance with the model shown in 8.2.2.8.3 by the competent authority of a Contracting Party or by any organization recognized by that authority shall be accepted during their period of validity by the competent authorities of other Contracting Parties

Due to this quote, the format and layout of your ADR certificate is provided in ADR, the UN class numbers are the same, as is whether (or not) you’re qualified to drive a tanker.
Anything with a cross covering it means that you can’t do it.

8.2.2.8.3 The certificate shall have the layout of the model below.

Your ADR certificate is written in German, which isn’t actually a problem, because ADR covers ‘strange’ languages in the following way:

8.2.1.9 The certificate shall be prepared in the language or one of the languages of the country of the competent authority which issued the certificate or recognized the issuing organization and, if this language is not English, French or German, also in English, French or German…

I might have some sympathy if the loading people had to read an ADR certificate that’s written in Russian, but guess what?? The format and language requirements are covered above and Russian numbers are the same as ours, so we’d know exactly what a Russian driver could or couldn’t carry on a vehicle.

I’ve gone into some depth of detail on this, because I hope it avoids you thinking that you might have to enrol on an ADR course in the UK, whilst you still hold a perfectly valid ADR certificate.
There might then potentially be an additional issue depending on which country issued your driver’s licence.

I hope this helps.

[dieseldave]

youngwithaclass1:
Anyway my question is that i currently don’t have a adr, and at palletways your not allowed out your cab to watch whats being loaded so every now and again i get 4-5 pallets of oil drums on my trailer.
what i’m worried about is that cos i don;t have an adr i’m not certifcated to carry such goods, just wondering weather anyone could shed light on this?

Hi youngwithaclass1, There is a very simple answer to this, but first I have to ask what’s written on your paperwork, and whether there are any labels on the drums??

If you read my explanation below, I hope you’ll discover why I asked you the two questions above.

Transport document
Dangerous goods must be correctly noted on your Transport Document.
All dangerous goods are allocated a “UN Number” consisting of four digits with the letters “UN” written first.
The “UN” number tells us that it’s something dangerous, and the fact that the letters “UN” MUST be written first saves us from getting a four-digit number confused with a phone number for a hot date.
UN numbers are the same for the same ‘stuff’ by all modes of carriage all around the world.

Next, the Proper Shipping Name (PSN) must appear, followed by the “Class” number, followed by the Packing Group (PG) if one is allocated. For this explanation, it’ll look something like this:

UN number, PSN, Class and PG
Those four pieces of information must be written in that order, then that gets around the problems caused by foreign languages, because the system is standardised worldwide.

Just as an example, let’s imagine that we need to carry some petrol in drums.

The paperwork must describe it accurately, like this:
UN 1203 PETROL, 3, PGII
(The law allows the letters “PG” to be left out, cos they make no difference. That’s another reason for the use of ROMAN numerals. )
I’ve covered the UN number and PSN, so now we need to understand the “Class” number. There are 9 classes of dangerous goods, but they aren’t a league table of danger, they just tell us what the type of danger is, and this can be discovered by looking at the symbol in the top half of the diamond. Eg. Flammability, Poisoning or Corrosivity. Again, this gets around the language barrier, so the system is understandable in any country and in any language. This is achieved by the correct use of the appropriate colours, numbers and danger signs. A label in a foreign language, or with no writing on it is perfectly legal, because if the colour, number and danger sign are correct, the text isn’t actually needed.

Here are the 9 danger Classes:

UN Class 1

UN Class 2

UN Class 3

UN Class 4

UN Class 5
…[NEW 5.2 LABEL ]

UN Class 6

UN Class 7

UN Class 8

UN Class 9

Next, we need to understand the meaning of Packing Groups (PGs)
A packing group is the way that we can discover how dangerous something is, and it also tells the people who fill packages what standard of packaging to use. There are three PGs. The PGs are ALWAYS indicated by using ROMAN NUMERALS, which neatly avoids any possible confusion with the class number.

PGI = High Danger,
PGII = Medium Danger
PGIII = Low Danger

Up to now, what I’ve written is legally required and is valid for the worldwide transport of dangerous goods by all modes of carriage. This comes in books published by the United Nations (UN.)

The regulatory bodies for the various modes of carriage then take these ‘basics’ and develop them into Regulations specific to the mode of carriage.

ADR is valid for international transport of dangerous goods in road vehicles in the whole of the EU, plus a number of other countries on the European mainland including Russia, Kazakhstan, Norway and Switzerland.
Ships, aeroplanes and trains have their own sets of dangerous goods Regs called IMDG, IATA and RID respectively.

For ADR purposes, once the dangerous goods have been correctly identified, we should realise that ADR gives ‘freebies’ when the ‘stuff’ comes in packages. The amount of the ‘freebies’ depends on how dangerous the goods are. If something is VERY dangerous, it will be regulated either straight away, or once there is only a small amount on board the vehicle. If the goods are only ‘a bit’ dangerous, then they’re allowed to be carried in larger amounts before the Regs need to be obeyed. That’s the point at which the ADR licence and the displaying of the orange boards on the vehicle is required. It’s only really ADR that adopts this ‘layered’ approach. The other sets of Regs don’t normally have the concept of ‘freebies’ so their Regs begin to bite quite quickly and will affect quite small quantities of dangerous goods, but do not affect truck drivers.

It’s also partly one of the reasons that you don’t see orange boards on ships or aeroplanes.

In the above example of petrol in drums, the ADR ‘freebie’ is 333 ltrs, because petrol is Class 3, PGII. Up to that amount, you can carry it without needing an ADR licence or displaying orange boards. Now let’s imagine that we’re going to carry Diesel Fuel in drums.
Correctly written, it looks like this:
UN 1202 DIESEL FUEL, 3, PGIII

We all know that diesel isn’t as dangerous (flammable) as petrol, so that’s why the PG number is different.
In the case of diesel fuel, the ADR ‘freebie’ is 1,000 ltrs, due to the fact that there’s less danger.

Both petrol and diesel have the same danger (flammability) so either one of them would need the appropriate class label on the drum(s) ie a red label with a figure three on it and a flame symbol in the top half like this:
From this, you can tell what the danger is, but not how dangerous it is.
If there are any markings on the drum other than the diamond type above, then the ‘stuff’ isn’t dangerous, and you needn’t worry about it.
Other markings might be Eg. an orange square with a cross on it or an orange square with a dead fish lying next to a tree. These have NO relevance to ADR, or to taking the stuff on the roads. They are simply a different set of Regs that apply to those who actually use the ‘hazardous’ stuff in their work. The diamond and the UN number on the drum(s) is the clue as to whether the ‘stuff’ inside counts as ‘dangerous.’
“Hazardous” and “dangerous” have different legal definitions.

All a driver ever needs to learn is the class system ie. colour, number and danger sign and that this is found on packages, + the idea that the PG represents the degree of danger and that this is found on the transport document.

The rest of everything else I’ve written is either the responsibility of the consignor (= sender,) or the carrier ( = vehicle owner.)
The law defines a consignor as the sender of the dangerous goods, even if they provide the service without actually owning the dangerous goods, so the pallet hub IS the consignor, whether they realise it or not, and whether they like it or not.

As for you not being certificated to carry dangerous goods, I can tell you that you can carry a very wide range of dangerous goods perfectly legally WITHOUT being certificated.
The ‘freebies’ I mentioned above depend on a combination of several factors including, the size/type of package(s,) the degree of danger and the total amount loaded on the vehicle.
We should now understand that there are approx 3,200 dangerous goods listed in ADR, and that the system I’ve described is potentially different for each one of them, because some dangerous goods have certain other exemptions too.
It is the vehicle owner’s legal responsibility to understand this and in most cases to appoint a qualified Dangerous Goods Safety Advisor (DGSA,) whose legal responsibilities are defined in ADR.

For those thinking of doing an ADR course, reading the above (carefully) will be very helpful in passing the exams.

I hope this helps.

[stringy]

Dave, I’ve heard that ADR regs will change from 01/01/09 and that tremcards will be more generic and responsibility will lie more with the carrier than the consignor. Can you clarify exactly what will change please?

[dieseldave]

stringy:
Dave, I’ve heard that ADR regs will change from 01/01/09 and that tremcards will be more generic and responsibility will lie more with the carrier than the consignor. Can you clarify exactly what will change please?

Hi stringy, There will be some changes to ADR for 2009, and you’re spot-on, because ADR 2009 comes into force on 01/01/09.

However, you don’t need to worry, because the changes you speak of are to be the vehicle owners’ (carrier’s) responsibility [NOT the driver.] You also needn’t worry on another point either, because the changes don’t have to be obeyed exactly until 01/07/09 due to the perfectly normal six month changeover period. In other words, for the first six months of the validity of a new version of ADR, the participants may do things the ‘old’ way OR the ‘new’ way. That’s ADR’s fair way of not expecting changes to happen overnight.

The ‘Tremcards’ will change as you suggested.
For the 2009 edition of ADR it has been agreed that the Instructions in Writing are for the driver, rather than for the emergency services. (Up to now, there has been doubt about this.) Generic Instructions in Writing will be carried on board the vehicle, which list the actions to be taken in the event of an accident by the driver, so it seems that the ‘tremcard’ will be simplified somewhat. For some time, emergency response teams have had their own (much more detailed) version of a ‘Tremcard,’ which is known as an ‘Ericard’ (Emergency Response Intervention CARD)

There are said to be some additional UN Class specific guidance for the driver, as well as some general requirements for emergency intervention and personal protective equipment to be carried (as at present.) This fits on to four sides of A4 and will need to be carried in the cab. They are to be provided by the carrier for the vehicle crew, in a language that the crew can understand.

My own view on this is that some TMs might be in for a surprise, but it shouldn’t be too bad, cos their DGSA will take care of it for them.
Yea, right.

As they say on Crimewatch, please don’t have nightmares.
As a driver, and in relation to your question, you’ll just notice that some of the paperwork will change a bit.

I hope this helps.

[stringy]

Thanks Dave, very clear and helpful information

[dieseldave]

From another post.

hankthejeweller:
… at what point do i need the adr, [when carrying propane gas cylinders for FLTs]… and it got me wondering****

Hi hankthejeweller,

The gas for FLTs is normally propane, so the ‘freebie’ limit before ADR springs into action is 333kgs Nett weight of gas.
That means that you DON’T count the empty weight of the cylinders.
Just go by the stated weight on the cylinder, usually 18kg, 19kg or some can be 21kg. (Other weights are possible too.)

You add up the number of Nett weights together, then to keep within the ADR ‘freebie’ limit, you need to have less than 333kgs Nett on board at any one time.
Empty cylinders DON’T count, so you can carry as many of those as you like.

If you can stay below 333kgs Nett, all you need is 1 X (proper) 2kg dry powder fire extinguisher.

Anything more than 333kgs Nett of propane per vehicle needs an ADR licence and orange boards and all the other Regs also kick in at that weight in the case of propane.

ravanoli is spot-on about private carriage in a car, but that would equally apply to any other vehicle. It’s the fact that it’s private carriage that allows you to take advantage of the private carriage exemption, the vehicle size is actually irrelevant.
The part of this that most people forget is that the goods MUST ALSO be packaged for retail sale.
The key considerations here are that there’s no connection with ‘work’ and the type of packaging.

Here’s a fact that might seem strange…
The large (approx chest height) propane cylinders are usually around 47kgs, so you would do the math like this:

7 X 47kgs = 329kgs, therefore a driver without an ADR licence can carry seven of these, cos there’s less than 333kgs on board.

Another way of achieving compliance is to divide 333 by the weight of the cylinders to be carried.
Eg. 333 divided by 18kgs = 18.5, so you could carry 18 X 18kg cylinders perfectly legally without orange boards or an ADR licence.

The above works for propane, but other chemicals and gases have different ‘freebie’ limits AND different methods of calculation.

I hope that helps you Hank.

[dieseldave]

INFO SOURCE

Dangerous Goods Training Approved for Driver CPC
DSA are pleased to announce that elements of dangerous goods training for LGV drivers can be counted as part of their Driver CPC periodic training.

Driver CPC is a new qualification which will affect all LGV drivers from 9 September 2009. All drivers will be required to complete 35 hours of periodic training related to their profession within consecutive five year periods.

The following elements of ADR training will count towards their periodic training:

Up to a maximum of 21 hours of the basic course
7 hours of the core module refresher course

Please note: the specialist modules that are delivered outside of the basic course will not be accepted for periodic training, as it is considered the syllabi for these modules are too specialist and do not map readily across to the Driver CPC syllabus.

The specialist ADR modules that will NOT count towards the driver CPC are:
The explosives module (UN Class 1)
The radioactives module (UN Class 7)

Training centres and courses will need to be approved in line with the regulations. Existing centre and course approval fees will be applied.
IF you wish to use the ADR training hours to count towards your CPC, the ADR training provider must be approved for BOTH the Driver CPC & ADR. So it’s very much in your own interest to ASK before booking the course.

For more information on Driver CPC please visit transportoffice.gov.uk/cpc

17 December 2008

The comments in blue have been added by dieseldave & ROG

[dieseldave]

Please remember that ADR is valid for international journeys by road.

The UK uses its own “domestic” set of Regs for UK national journeys involving the carriage of dangerous goods. (Presently “CDG 2007.”)
So, what follows is primarily for international journeys at this time, but it is very likely that the UK will fall in line with some/all of this when the new CDG 2009 comes into force in July.

If you are carrying dangerous goods on an international journey, you obey ADR exactly, whilst ignoring CDG completely.

ADR 2009 comes into force on 01/01/09, BUT there is a six month transitional period for most of the new provisions lasting until midnight on 30/06/09 at the very latest.
To take advantage of the transitional period, the job must be done exactly as per ADR 2007.

So, what are the main changes that drivers might notice?
There will be some changes to your ADR documentation and to the labelling on some packages. The PPE and equipment to be carried on board vehicles subject to full ADR Regs will also change slightly.

Limited Quantities (LQs)
Alterations for 2011
There is a pre-warning that the rules for carrying LQs will change slightly (in 2011) in that there will be a ‘trigger’ limit for displaying marker boards based upon the weight of LQs carried (>8t) and the permitted GVW of the vehicle (GVW >12t.)
Vehicles having an authorised GVW of <12t will carry on as per the present LQ rules.
There’s still no mention of anybody needing an ADR licence to carry LQs.

Vehicles of >12t authorised GVW carrying LQs will need to display a marking on the FRONT and REAR.
The normal ADR orange coloured plates may be used for carriage of LQs as above (FROM 2011,) but the vehicle marking requirement for the carriage of LQs may alternatively be met by the use of boards/plates bearing “LTD QTY” in BLACK lettering of at leat 65mm height on a WHITE background.

=============================================================
Excepted Quantities
New concept
From 01/01/09 it will be possible to carry some types of dangerous goods packaged in a certain way without most of the ADR Regs applying to the job.
Excepted Quantities has been the way that the dangerous goods by air Regs (IATA) dealt with the idea of ‘Regs’ not applying to small quantities of dangerous goods that present only a low danger. Problems have arisen in the past for truck drivers when carrying air freight that was deemed ‘excepted quantities’ by air, but which (on a technicality) required to be regulated by ADR. The whole idea of ‘excepted quantities’ (by air) and ADR’s version ‘Limited Quantities’ (LQs) by road were actually legally inconsistent with each other !!

Now that the legal inconsistency been realised by the regulatory bodies who give us these Regs, this is their way of getting everybody to sing from the same hymn-sheet, so they’ve even included ‘excepted quantities’ in the Regs covering the carriage of dangerous goods by sea (IMDG.)

The new rules for excepted quantities are that all dangerous goods are given an excepted quantity code in the dangerous goods list. This code ranges from E0 to E5 inclusive.
There are limits per inner receptacle AND per package AND an overall limit of 1,000 packages per vehicle or container.
Overpacks are permitted. (Eg. palletised packages with shrink-wrap.)

Packages/overpacks containing excepted quantities must be marked by the consignor with the following label:

The minimum size of this label is 100mm X 100mm
The hatching and symbol may be shown in red OR black on a white OR suitable contrasting background.
The first (single) asterisk will be replaced by the UN Class number.
The (lower) pair of asterisks will be replaced by either the consignor OR consignee’s name, but only if this is not already shown elsewhere on the package. In this case, the lower part of the label would be left blank.

New label for packages of dangerous goods packaged in Excepted Quantities:

=============================================================
Environmentally hazardous substances.
These are substances (usually) of UN Class 9 which are known to be a pollutant to the aquatic environment.
Such substances will require an extra label on the package(s.)
I think of this as ADR’s equivalent to the ‘marine pollutant’ mark in IMDG.

This label must be a minimum of 100mm X 100mm.
The symbol (fish and tree) can only be black on a white OR suitable contrasting background.
New “Fish and Tree” label

Changes to ADR Documentation

New generic IIW
The Instructions In Writing (IIW) [Tremcard] will change dramatically in 2009.
Previously, you’ll remember that you had to have a separate IIW for each dangerous substance/article on board your vehicle and that the IIWs were specific to the substance/article.
Then you needed an IIW to cover the languages spoken in the country of departure, destination and all countries transited on that journey…
All rather ■■■■■■■■■■■

The new IIW will consist of four sides of A4, which MUST be printed in colour. This will cover you for any and all dangerous substances/articles and will only be needed in ONE language, even for international journeys. That language MUST be a language that the driver can understand.

Transport Document.
The entry on the transport document will change slightly, because from 2009 it must include the Tunnel Code, which indicates which type of tunnels the particular dangerous goods are allowed to transit. (See below for “Driving in Tunnels.”)

As an example, if you carry petrol the ‘old’ entry would appear like this:
UN 1203 PETROL, 3, PGII

In 2009, the entry for petrol will change to:
UN 1203 PETROL, 3, PGII, (D/E)

Driving in tunnels

As mentioned above, the transport document entry will be slightly different in that it must include the relevant tunnel code for the particular dangerous substance or article being carried. The tunnel code must be given in brackets at the end of the entry.

The subject of dangerous goods passing through the European road tunnels has been the subject of much discussion amongst the (currently) 44 ADR member countries. The ADR countries have agreed a classification system for road tunnels on the Trans European Road Network (TERN.) The new rules will only affect tunnels of more than 500m in length. Under the new tunnel classification system, each tunnel will be allocated a letter in the range A - E and from that, we will know which dangerous goods are allowed to transit any particular tunnel.
The finer details aren’t absolutely finalised yet, so I shall post the details in a separate post as soon as I have more info.
There will also be some new road signs appearing, which relate to dangerous goods in tunnels.
ADR’s dangerous goods list already has the tunnel codes allocated to each substance, but there are differences for the same substance depending upon whether it is being carried in packages or a tanker, and there are also limits as to quantity in some cases.
If the dangerous goods on board your vehicle aren’t allowed through a particular tunnel, at least you’ll know in advance, and you’ll be able to select an appropriate alternative route before attracting the attention of enforcement officials.

ADR driver training courses
Still awaiting final details in writing from SQA…
Due in July…

[r_d]

hi dave,long time no speak.if you remember i popped on here quite a while ago with ADR queries and you helped me out
since then things have improved at work and things are done by the book and if i have any probs theyre usually sorted asap.ive got a couple of small queries you should be able to help me with,if youd be so kind we`ve started moving a lot of hazardous waste lately from depot to depot for a waste management company who no longer have their own vehicles.so,they arrange the jobs,paperwork etc and we do the transport.question 1) on the hazardous waste consignment note,where you have to put the hauliers details,apart from my name and registration,the waste management company is stated as the haulier.is this correct and legal,or should i change it to my companies details? question 2) i recently did a trailer swap with one of our drivers.it was a hazardous waste load.what do i do with the the details on the consignment note? as the other driver picked it up,its got his name and registration on it! i changed it to my details this week,is this correct? im just asking cus if there was an incident my copy wouldnt match the one at the collection point where it originated oh,the waste is in drums or IBCs and is a flammable solid class 4.1 un3175 pg2

[dieseldave]

R.D:
hi dave,long time no speak.if you remember i popped on here quite a while ago with ADR queries and you helped me out
since then things have improved at work and things are done by the book and if i have any probs theyre usually sorted asap.ive got a couple of small queries you should be able to help me with,if youd be so kind we`ve started moving a lot of hazardous waste lately from depot to depot for a waste management company who no longer have their own vehicles.so,they arrange the jobs,paperwork etc and we do the transport.question 1) on the hazardous waste consignment note,where you have to put the hauliers details,apart from my name and registration,the waste management company is stated as the haulier.is this correct and legal,or should i change it to my companies details? question 2) i recently did a trailer swap with one of our drivers.it was a hazardous waste load.what do i do with the the details on the consignment note? as the other driver picked it up,its got his name and registration on it! i changed it to my details this week,is this correct? im just asking cus if there was an incident my copy wouldnt match the one at the collection point where it originated oh,the waste is in drums or IBCs and is a flammable solid class 4.1 un3175 pg2

Hi R.D, I can give you a good answer to your questions if you could please tell me which type of waste consignment note you’re using?

I think I already know the answers to your questions, but I’d like to make sure that I’m giving you good info.

[r_d]

thanks for the quick reply,dave how do i know what type of note im using? i wasnt aware there were different types,i dont take much notice to be honest it was printed on A4 sized paper,had 5 or so sections (part A to E),and there were 2 copies.part A was conignor,part B hazard?? part C haulier part D consignee…i think…

[dieseldave]

R.D:
hi dave,long time no speak.if you remember i popped on here quite a while ago with ADR queries and you helped me out

Hi R.D,
ADR is one thing, and that’s relatively straightforward for me to answer, but your questions relate to a completely different set of Regs.

Thanks for your answer to what the collection note looks like.

R.D:
we`ve started moving a lot of hazardous waste lately from depot to depot for a waste management company who no longer have their own vehicles.so,they arrange the jobs,paperwork etc and we do the transport.question 1) on the hazardous waste consignment note,where you have to put the hauliers details,apart from my name and registration,the waste management company is stated as the haulier.is this correct and legal,or should i change it to my companies details?

I’m feeling my way along with your questions a little bit, but here goes…
This seems to me to be a question of definitions and the responsibilities of the various parties to the movement of hazardous waste, so here are the relevant definitions:
(This is from The Hazardous Waste (England and Wales)Regulations 2005.)

“carrier” in relation to a consignment of hazardous waste,
means a person who takes one or more of the following actions,
that is to say, collects the consignment from the premises at
which it was produced or premises at which it is being held,
delivers it to the consignee, or transports it in the course of its
transfer from those premises to the consignee;

I would take this to mean you and your boss.

“consignor”, in relation to a consignment of hazardous waste,
means the person who causes that waste to be removed from
the premises at which it was produced or is being held;

I would take this to mean the person or organisation that asks your company to move the waste.

“holder” means the producer of the waste or the person who is
in possession of it;

Having regard to the definitions of “holder” and “consignor,” it seems that the company who used to have their own transport might now have different responsibilities than they previously had. Reading your question the way it’s written makes me wonder whether your boss should ask them about this?

In any case, the company on whose behalf you move the waste are clearly responsible for providing correct documentation to accompany the load, so from this point of view, you’re pretty much in the clear since it’s not your responsibility to provide the documentation.

R.D:
question 2) i recently did a trailer swap with one of our drivers.it was a hazardous waste load.what do i do with the the details on the consignment note? as the other driver picked it up,its got his name and registration on it! i changed it to my details this week,is this correct? im just asking cus if there was an incident my copy wouldnt match the one at the collection point where it originated oh,the waste is in drums or IBCs and is a flammable solid class 4.1 un3175 pg2

I’d say that it’s perfectly in order for you to put your details alongside the original driver’s details on the collection note. I’d suggest that you don’t cross anything out though.

Now we’re into some ADR stuff.
Here’s what you were carrying:
UN 3175 SOLIDS CONTAINING FLAMMABLE LIQUID, N.O.S., 4.1, PGII

I have one question for you:
Did you have more than 333kgs of this stuff in packages on board your vehicle?

[r_d]

thanks dave the load in question on that day was packaged in 88 45gallon drums…4 drums per pallet = 22pallets.the note didnt specify individual package weight,just the load as a whole.if i remember rightly the entire load was around 17000kgs.now,if my math is correct,the average weight per package was under 200kg.packing group 2 lets you have upto 333kg per package.so maybe it isnt ADR…is that what you`re getting at? the waste management company did inform my boss that an ADR truck and driver were neccesary that day

[dieseldave]

R.D:
thanks dave the load in question on that day was packaged in 88 45gallon drums…4 drums per pallet = 22pallets.the note didnt specify individual package weight,just the load as a whole.if i remember rightly the entire load was around 17000kgs.now,if my math is correct,the average weight per package was under 200kg.

Hi R.D You asked what I’m getting at, and that’s a very good question indeed.

I’m getting at the fact that BOTH the Waste Regs AND ADR applied to that job.
The waste firm were perfectly correct to require an ADR trained driver to carry that load, because you were carrying a load that was subject to the full weight of BOTH sets of Regs.

R.D:
packing group 2 lets you have upto 333kg per package.so maybe it isnt ADR…

You’re correct that the goods are in PGII, which in this case happens to be in Transport Category 2, but the limit of 333kgs is PER VEHICLE LOAD NOT PER PACKAGE.
(That means for the stuff you were carrying that ADR applied in full.)

I’m not sure where you got the notion that the 333kgs limit applies per package, but that’s absolutely wrong. The next point I’m getting at is that (if you’re an employed driver) under ADR it simply isn’t your job to decide such things, because ADR is very clear on the subject of Consignor and Carrier responsibililities.

The subject of Transport Categories and load limits is required teaching on an ADR course, but the instructor is also required to explain that the decision as to whether the Regs apply is for the Consignor and Carrier jointly. To be fair to you, it’s a very common mistake that many bosses make when they wrongly assume what’s on the ADR teaching syllabus.

I wish I had £1 for every time I’ve heard a boss say to a driver something like “you’ve been on the course, so you should know.” IMHO, when a boss says such things, he’s showing just how out of touch he is. The responsibility for deciding when and how much of ADR applied to a particular job passed from the driver to the Carrier at midnight on 09/05/2004. Whilst I’m on the point of responsibilities, a Carrier and a Consignor have both been required to have access to a properly qualified DGSA since 31/12/1999. The idea is that the DGSA sees to it that the relevant people within the firm have had the required training and awareness of dangerous goods that go with their responsibilities within the company.

In the event that you’re ever stop-checked by VOSA, there is a question on the VOSA officer’s check-sheet that you’ll be asked if you’re carrying dangerous goods subject to ADR. You’ll be asked for the contact details of your company’s DGSA. Don’t let this frighten you, because that’s not my intention. It isn’t an employed driver’s responsibility to appoint/retain a DGSA, I’m simply saying that you might be asked the question, so it’s pertinent for you to ask your boss who your firm’s DGSA is.

For now, I’m imagining that your firm has a DGSA, because there is a requirement on Consignors that they check the bona-fides of anybody they engage to carry out transport on their behalf. I can’t imagine a proper waste management company failing to do that, but you never know…
TBF though mate, I have met DGSAs that make me wonder how they ever managed to pass the DGSA exams.

In the event that your firm actually has a DGSA, it might be time for your boss to be asking that person some serious questions.

[r_d]

thanks dave i was having a blonde moment when i wrote that post yesterday i was getting confused with another issue i had at work involving a packing group 2 consignment a month ago.doh!! i remember the 333kg threshold from that,on that occasion i was right,yesterday i had my head up my ■■■ i know that its not my responsibility as a driver to know such things,but like you say,some people expect you to know because you did the course.i just take it upon myself to check everything as a good professional driver should i do it mainly to avoid situations with our friends at VOSA.mistakes are made occasionally in transport offices around the country,altho its hard to get them to admit it sometimes we do have an onsite DGSA whos kinda knowledgeable and my boss has recently appointed a new off site DGSA who we can call if need be.ive been assured hes top notch and much better than the last bloke who was a bit hit n miss!!hes the one whos knocked our company into shape lately.ive been fairly comfortable with how ive dealt with the recent afore mentioned issues, so ive refrained from calling him and decided to bug you instead when ive got 5 mins to spare