Dangerous goods advice- UK regs and ADR

Hi Dave,

Could I please have some advice on carrying UN1170 alcohol-based hand cleaning gel, packed in cardboard boxes of 12 x 240 ml containers - ADR required or not?

TIA…

MrFlibble:
Hi Dave,

Could I please have some advice on carrying UN1170 alcohol-based hand cleaning gel, packed in cardboard boxes of 12 x 240 ml containers - ADR required or not?

TIA…

Hi Mr Flibble,

I think I know the answer, but could I ask what the paperwork says, and what markings are on the boxes please?
To cover all bases, could I also ask how many boxes do you propose to load on a vehicle please?

There are a couple of entries in the dangerous goods list for UN 1170 ETHANOL SOLUTION, which could make a difference depending on which one you mean.

dieseldave:
I think I know the answer, but could I ask what the paperwork says, and what markings are on the boxes please?
To cover all bases, could I also ask how many boxes do you propose to load on a vehicle please?

There are a couple of entries in the dangerous goods list for UN 1170 ETHANOL SOLUTION, which could make a difference depending on which one you mean.

What sort of markings do you mean? There’s the usual diamond with the UN number inside; it’s ethanol-based hand cleaning gel. If you could give me a hint what I’m looking for, I might be able to work out what you want :wink:

Unfortunately, it didn’t come with any paperwork (free donation). As for number of boxes, I’m not in the warehouse to count them, but I don’t think it’d be more than two layers of boxes on a pallet - max. maybe about 30 boxes - it’s currently on two pallets, mixed in with other items.

MrFlibble:
There’s the usual diamond with the UN number inside; it’s ethanol-based hand cleaning gel.

Hi Mr Flibble,

The diamond with a UN number in it means it’s Limited Quantities, but just to be sure…

Does the diamond look like this please?

LQ 1170.jpg

If I’m correct, then you can load the whole lot on one truck and no ADR needed.
If you’re going by sea, then you’ll need a DGN cos IMDG has different rules to ADR.

dieseldave:
The diamond with a UN number in it means it’s Limited Quantities, but just to be sure…

Does the diamond look like this please?

Yes, that’s it.

Does a diamond like that always mean LQ? Or is it just for particular types/classes? And if it does always mean LQ, is there ever a limit on the total amount of LQ-labelled stuff that can be on a single vehicle?

Sorry for the long questions, but if the answers go the way I hope, it’ll mean that I’ll be able to avoid asking about different stuff in future, because I’ll just be able to see the diamond and know that it’s OK (for road at least). :wink:

dieseldave:
If I’m correct, then you can load the whole lot on one truck and no ADR needed.
If you’re going by sea, then you’ll need a DGN cos IMDG has different rules to ADR.

I think this stuff’s going through the tunnel. If it does go Dover-Calais, what’s the procedure for getting the DGN?

MrFlibble:

dieseldave:
The diamond with a UN number in it means it’s Limited Quantities, but just to be sure…

Does the diamond look like this please?

Yes, that’s it.

Does a diamond like that always mean LQ?

Hi Mr Flibble,

Yes mate, that’s a Limited Quantity label.

MrFlibble:
Or is it just for particular types/classes?

Yes, that’s just about the way it works.
The stuff that’s allowed to go as LQs is set out in ADR, so if it’s got that label, then the consignor must have checked it out.
However, some of the responsibility for this also rests with the carrier.

As a very rough guideline, the LQ exemptions usually relate to the kinds/types of dangerous goods that the general public can buy in a retail shop. The one you’re carrying is an excellent example of this.
In ADR, the really dangerous stuff isn’t allowed to be packaged and transported by use of the LQ exemption.

MrFlibble:
And if it does always mean LQ, is there ever a limit on the total amount of LQ-labelled stuff that can be on a single vehicle?

For the carriage of LQs, there is no limit in ADR to the amount that can be carried on board a vehicle.

The rules for LQs are in the process of being changed, but from what you’ve described, you’re using the old system.
Please have no fear about this, the old LQ system doesn’t get scrapped until 30/06/2015.
Under the current system, there is a requirement in ADR to mark vehicles whilst travelling on the road, but you’re nowhere near triggering it.

Sorry for the long questions, but if the answers go the way I hope, it’ll mean that I’ll be able to avoid asking about different stuff in future, because I’ll just be able to see the diamond and know that it’s OK (for road at least). :wink:

MrFlibble:
If you’re going by sea, then you’ll need a DGN because it’s then a multi-modal journey and IMDG has some different rules to ADR.

MrFlibble:
I think this stuff’s going through the tunnel.

LQs can be carried through the tunnel, so no problem there… but in order to avoid delays please make sure your paperwork is correct.

MrFlibble:
If it does go Dover-Calais, what’s the procedure for getting the DGN?

I’d suggest that you check with whichever shipping line you’ll use for the crossing, but you will need a DGN if your LQs are to travel by ferry.

Good Evening Diesel Dave

Could you please clarify the markings required on a tank container on an ADR journey. I thought that the tank required placards on all four sides plus two kemler boards left and right. The vehicle will also show orange boards front and rear. To-day my Operations Manager stated that the tank must have a kemler board on all four sides? Who is right?

Ubiquitous:
Good Evening Diesel Dave

Could you please clarify the markings required on a tank container on an ADR journey.

I thought that the tank required placards on all four sides plus two kemler boards left and right.

Hi Ubiquitous,
You’re correct mate. :smiley:

Ubiquitous:
The vehicle will also show orange boards front and rear.

Also correct, but I’d add the word “plain” to show that there are no numbers/writing on the orange boards.

Ubiquitous:
To-day my Operations Manager stated that the tank must have a kemler board on all four sides? Who is right?

I think it’s possible that your OM might have got the requirements for placards confused with the requirements for the orange (Kemler) plates in ADR.

dieseldave:

Ubiquitous:
Good Evening Diesel Dave

Could you please clarify the markings required on a tank container on an ADR journey.

I thought that the tank required placards on all four sides plus two kemler boards left and right.

Hi Ubiquitous,
You’re correct mate. :smiley:

Ubiquitous:
The vehicle will also show orange boards front and rear.

Also correct, but I’d add the word “plain” to show that there are no numbers/writing on the orange boards.

Ubiquitous:
To-day my Operations Manager stated that the tank must have a kemler board on all four sides? Who is right?

I think it’s possible that your OM might have got the requirements for placards confused with the requirements for the orange (Kemler) plates in ADR.

I also think he is confusing his IMDG with his ADR

IMDG would require 4 hazard diamonds and the UN number on 4 sides. It would also require the PSN on two sides. The tank container marked up as IMDG is legal to travel on the roads but when marked up correctly for ADR, it would probably miss the ship.

Obviously the unit and trailer will still need the plain orange boards and the IIW

The UN number can be written either within the placards or printed on a separate panel.


  1. x 4 You can write a legible UN number in the white space and use with 3.


  2. 4x To be used in conjunction with 3 & 4.


  3. Proper Shipping Name x 2


  4. UN number x 4 as an alternative to placard 1 when used with 2 & 3.

Hi Dave & Wheelnut

Thanks for the reply and the info it is gratefully received. I thought that the Regulations had changed and the Company had not informed the people who need to know.
The saying knowledge and power sprung to mind.
Once again many thanks

Ubiquitous:
Hi Dave & Wheelnut

Thanks for the reply and the info it is gratefully received. I thought that the Regulations had changed and the Company had not informed the people who need to know.
The saying knowledge and power sprung to mind.
Once again many thanks

The Proper Shipping Name does not have to be orange like my example, it can be a simple sticky label or even painted on the side of a dedicated tank.

I am sure Dave will be along with chapter and verse, but he does ADR, the shipping line will normally supply extra labels and placards, at a great cost to the haulier or shipper.

Wheel Nut:
… I am sure Dave will be along with chapter and verse, but he does ADR, the shipping line will normally supply extra labels and placards, at a great cost to the haulier or shipper.

Hi Malc,

I’m always happy to oblige… :grimacing:

IMDG 5.3.2.0.1.
The Proper Shipping Name of the contents shall be durably marked on at least both sides of:

.1 tank transport units containing dangerous goods; [My edit: = Tank vehicles and tank containers are treated the same.]
.2 Not relevant
.3 Not relevant

IMDG 5.3.2.0.2
The Proper Shipping Name for the goods shall be displayed in characters not less than 65 mm high.
The Proper Shipping Name shall be of contrasting colour with the background.

:open_mouth: Oh yes Malc, the cost shall indeed be great. :wink:

Hi Dave this week I have been moving waterstofperoxide 70% in tank containers. The DGN supplied listed the product as UN 2015 class 5.1 with a secondary hazard of class 8.
The tank had on all four sides a kemler plate showing 559 plus a class 5 and a class 8 placard.
My query is with the kemler plate showing 559, the class 8 placard is incorrect and it should be a class 9 placard?
Your help and assistance in this matter would be appreciated.

Ubiquitous:
Hi Dave this week I have been moving waterstofperoxide 70% in tank containers. The DGN supplied listed the product as UN 2015 class 5.1 with a secondary hazard of class 8.
The tank had on all four sides a kemler plate showing 559 plus a class 5 and a class 8 placard.
My query is with the kemler plate showing 559, the class 8 placard is incorrect and it should be a class 9 placard?
Your help and assistance in this matter would be appreciated.

Hi Ubiquitous,

My guess is that its Wasserstoffperoxyd, which is German for Hydrogen Peroxide.

You’re correct that it’s UN 2015, and you’re also correct that its Class 5.1 with a secondary corrosive hazard.

The HIN of 559 is also correct for that substance, so the Kemler board should look like this:

Image1.jpg
The significance of the top row of numbers is:

The figure ‘55’ denotes that the substance is a very strong oxidiser, whilst the additional ‘9’ indicates that it has a danger of spontaneous violent reaction.

There is only the possibility of showing three numbers in the top part of a Kemler board, so it’s been decided that 559 is a better description of the danger of UN 2015 than 558 would be.

I’ve checked for you and I can tell you that the DGN, the Kemler boards and the placards are all spot-on. :smiley:

Thanks a lot Dave; it was just confusing seeing 559 with a class 8 placard.

Ubiquitous:
Thanks a lot Dave; it was just confusing seeing 559 with a class 8 placard.

Hi Ubiquitous,

The ‘9’ has two meanings in the Kemler system in the upper half of the orange plate.

If a 9 is the first number (on the far left) it means it’s a Class 9 product.

Eg: you’d see ‘90’ as the HIN for a general Class 9 product such as ‘Environmentally Hazardous Liquid N.O.S.’

If a 9 is anywhere other than the first position in the upper half of the orange plate, it means there’s a danger of sponateous violent reaction.

Eg: 99 is a Class 9 product carried “HOT” (Eg BITUMEN) or has a danger of violent reaction.

So it’s also possible to see 239, 39, 59, 339, 539, 69, 669, 89, 839, 889 etc.

:bulb: The Kemler system is based on the UN Class numbers, but it doesn’t follow them rigidly.

Hey Dave, after some help.

Passed my ADR a few years ago now and I’ve never used it due to delays with lessons and test, now I’ve done everything and ready to drive but all the ADR info has gone. Can you remind me of all the paperwork I need to carry with me please.

I’m gonna be carrying Diesel, Nitrogen in both liquid and gas form, Helium in gas form as well as a class 9 liquid which is like washing up liquid but cant remember what it’s called.

please help…

kwaka jack:
Hey Dave, after some help.

Passed my ADR a few years ago now and I’ve never used it due to delays with lessons and test, now I’ve done everything and ready to drive but all the ADR info has gone. Can you remind me of all the paperwork I need to carry with me please.

I’m gonna be carrying Diesel, Nitrogen in both liquid and gas form, Helium in gas form as well as a class 9 liquid which is like washing up liquid but cant remember what it’s called.

please help…

How many is a FEW?

Wheel Nut:

kwaka jack:
Hey Dave, after some help.

Passed my ADR a few years ago now and I’ve never used it due to delays with lessons and test, now I’ve done everything and ready to drive but all the ADR info has gone. Can you remind me of all the paperwork I need to carry with me please.

I’m gonna be carrying Diesel, Nitrogen in both liquid and gas form, Helium in gas form as well as a class 9 liquid which is like washing up liquid but cant remember what it’s called.

please help…

How many is a FEW?

2/3

kwaka jack:

Wheel Nut:

kwaka jack:
Hey Dave, after some help.

Passed my ADR a few years ago now and I’ve never used it due to delays with lessons and test, now I’ve done everything and ready to drive but all the ADR info has gone. Can you remind me of all the paperwork I need to carry with me please.

I’m gonna be carrying Diesel, Nitrogen in both liquid and gas form, Helium in gas form as well as a class 9 liquid which is like washing up liquid but cant remember what it’s called.

please help…

How many is a FEW?

2/3

The only paperwork the driver has to carry is his ADR certificate and “Instructions in Writing” .These replaced the seperate Tremcards for each product. Obviously you will need the transport documents for the load or a valid cleaning certificate if the tank has been purged free.

The onus is on the shipper or manufacturer to supply the transport document, but the instructions in writing must be supplied by the carrier or yourself if you are an owner driver.