Dangerous goods advice- UK regs and ADR

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

dieseldave:
Up to now, you’re fine as regards most of ADR, but now you do need an ADR compliant minimum 2kg dry powder fire-extinguisher, and some documented ADR ‘awareness’ training, but not a full ADR licence.

That’s great news, Dave, I presume it is the employer’s responsibility to give me the ADR awareness training? I haven’t been provided with any, is it something that there is an official course for or is it entirely up to the employer as to the content of this training? Also what would be the consequences of being stopped by VOSA and not having the documented training? (not that i don’t want to be trained you understand, I just want to have some ammunition to take back to the company to tell them I need some training).

Hi okeedokee,
The ‘awareness’ training isn’t necessarily a formal course, it could just be your boss explaining the hazards/risks involved in the carriage of Diesel fuel and making you aware of company procedures in the event of a spillage or other accident/incident.

If they really want to cover themselves, they could send you to (for instance) an ADR training school at the time they’re teaching UN Class 3.
UN Class 3 is usually taught for 1.5hrs on most ADR courses.
That way, somebody qualified and independent of your company would be conducting the training, so the training could be said to be more valid than your boss simply sticking a note in your personnel file to say that he’d explained a few things to you.

Just as a little note, “documented” doesn’t mean that you have to carry it with you, it just means that some training has taken place and that fact is written down and preferably recorded. It’s quite an easy matter for the company to get sorted, but it’s one that’s frequently missed because the boss is busy.

402

That’s just the info I needed. Very well explained. Thanks :slight_smile:

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Hi Dave
Another quick question, we carry a lot of oil and water (in tankers) which is classed as low hazard for road transport and does not come under adr,but we have been told that as of 1st dec we must display the new environmental hazard placards when carrying it.
When i was on my adr course the instructor showed us the new placards and said they are used mainly in conjuction with un 3082 and class 9 placards, does this mean that these loads now come under adr on that un number or are these placards to be displayed on the own or with low hazard boards?
I have asked the office and they said they will get in touch with our dgsa, but that was 2 weeks ago and as of yet no definite answer.
I would very much appreciate it if you could shed some light on this for me.
thanks in advance
Rob

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wood73:
Hi Dave
Another quick question, we carry a lot of oil and water (in tankers) which is classed as low hazard for road transport and does not come under adr,but we have been told that as of 1st dec we must display the new environmental hazard placards when carrying it.

Hi wood73,
Somebody might have got themselves a little bit mixed-up…
TBF, the goalposts in ADR for the ‘environmental mark’ have recently been moved somewhat, but it still remains the responsibility of the consignor (sender) of the goods to correctly classify a substance to be carried.
Can I assume that “we have been told” means that the consignor has told your company to use the environmental mark?
Also, could I ask where the date of “1st dec” came from please?

In order for a substance to need the environmental mark, it would need to have been subjected to the excruciatingly detailed scientific analysis detailed in appox 12 (yes, twelve :open_mouth: ) pages of ADR. (ADR 2011 2.2.9.1.10.1-6 inc) If the substance meets these criteria, it needs to be carried as:

UN 3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., (Contains xxxx) 9, PGIII

Given that you drive a tanker, the relevant markings on your 3 hazard warning panels should be:
(With the environmental mark showing as a secondary hazard next to the primary hazard.)

UN 3082_small.jpg

wood73:
When i was on my adr course the instructor showed us the new placards and said they are used mainly in conjuction with un 3082 and class 9 placards, does this mean that these loads now come under adr on that un number or are these placards to be displayed on the own or with low hazard boards?

Your ADR instructor has it spot-on mate. :smiley:
If the substance meets the classification criteria for inclusion in UN Class 9, then it becomes a dangerous substance regulated by ADR.
Again, I’ll say that it’s up to the consignor to tell your boss whether the substance they’re asking you to carry is subject to ADR, so if the consignor has spent a large sum of money to get the substance properly tested and the results say that it meets ADR’s criteria, then it counts as dangerous goods and should be carried subject to ADR requirements.

wood73:
I have asked the office and they said they will get in touch with our dgsa, but that was 2 weeks ago and as of yet no definite answer.
I would very much appreciate it if you could shed some light on this for me.
thanks in advance
Rob

No probs mate, this is an area that seems to be confusing a lot of people at the moment, but for ADR purposes, the answer turns on whether the substance has been properly tested. I’ve not given any thought to the Waste Regs as that’s outside my remit, so my answer is only from an ADR perspective.

I hope it helps, but please don’t worry about this because it’s really not part of your responsibilities as a driver.
As a driver, you cannot be held responsible for classifying your load. :smiley:

405

does that mean then the placards only need be displayed if the load is subject to adr i.e. un 3082?

406

wood73:
does that mean then the placards only need be displayed if the load is subject to adr i.e. un 3082?

Hi wood73,

Yes mate, If the substance meets the classification criteria for inclusion in UN Class 9, then it becomes a dangerous substance regulated by ADR.
Only then does it need the environmental mark.

Has the consignor told you that the substance needs the environmental mark? Has the substance been tested?

Who told you “1st dec” that you wrote in your question please? Was it your boss or the consignor?

407

the tm gave us all the new placards and said they were to be used with oil and water loads from 1st dec.
we carry different types of oil water waste from various companies.
I think maybe he has his wires crossed, as i said i have asked him to check, but still waiting to hear back from him.

408

wood73:
the tm gave us all the new placards and said they were to be used with oil and water loads from 1st dec.
we carry different types of oil water waste from various companies.
I think maybe he has his wires crossed, as i said i have asked him to check, but still waiting to hear back from him.

Hi wood73,

As I explained above, it’s not just a case of “we’ll stick these placards on just to be on the safe side” because the substance is either dangerous goods, or it isn’t. The only way to know is to have the substance tested.

I’d still like to know where they got this “1st dec” idea, so have they said why it’s the “1st dec” and what Regs that’s from yet please??

409

dont know the date came from and I havent been back to the yard at all this week so havent had chance to speak with him, but will try and find out when I get back in.

410

Dave bit of a query for you

was asked last week to collect 3 full 3000 litre bunded derv tanks and 2 cages of gas bottles, 1 was oxygen, the other propane, now in my eyes thats a mixed load .I told the gaffer I wasnt taking it all, id do the tanks, or the gas but not both togther,now our DGSA reckoned i could take all of them in the same load

i ended up doing 2 trips just to cover my back who was right?

411

Andydisco:
Dave bit of a query for you

was asked last week to collect 3 full 3000 litre bunded derv tanks and 2 cages of gas bottles, 1 was oxygen, the other propane, now in my eyes thats a mixed load .I told the gaffer I wasnt taking it all, id do the tanks, or the gas but not both togther,now our DGSA reckoned i could take all of them in the same load

Hi Andy,
OK mate, you’re correct that it was a mixed load, so what we have here is a question of whether UN Classes 2.1, 2.2(5.1) and 3 can be carried on the same vehicle at the same time.
The answer is “yes” those classes can be carried together on the same vehicle at the same time.

Andydisco:
i ended up doing 2 trips just to cover my back who was right?

Your DGSA was right, but I’m not quite sure what you mean by “cover my back.”
The carrier (your boss,) or you had asked a DGSA, and you’d been told that it’s legal to carry that load .
Between them, the sender of the goods and your boss know exactly what they want you to carry, and it’s their responsibility to observe the mixed loading rules in ADR. As an employed driver, you can rely on that being their responsibility, not yours. :wink:

I’m guessing that you remembered the subject of segregating incompatible loads from when you did your ADR course, but what the instructor probably didn’t have time to explain fully is that the segregation rules mostly apply in respect to dangerous goods Vs. foodstuffs for humans and animals when being carried on the same vehicle at the same time.

412

Hi Dave (or any non-Dave’s that can help)

I’ve searched the forum and can’t find the answer so sorry if my question has been already asked:

Is it a legal requirement to drive with sidelights or dipped headlights switched on all the time when under ADR rules? Someone told me it is but I don’t remember that from when I did my ADR. I notice fuel tankers usually have their lights on but other trucks displaying orange plates don’t.

Thanks

Another Dave

413

dave75:
Hi Dave (or any non-Dave’s that can help)

I’ve searched the forum and can’t find the answer so sorry if my question has been already asked:

Is it a legal requirement to drive with sidelights or dipped headlights switched on all the time when under ADR rules? Someone told me it is but I don’t remember that from when I did my ADR. I notice fuel tankers usually have their lights on but other trucks displaying orange plates don’t.

Thanks

Another Dave

That is a safety feature on ADR vehicles, but normally petroleum regulation fuel tankers. An ADR approved vehicle has an isolator switch and must be turned off whilst loading flammable liquids.

A pet reg truck has double pole wiring which is intrinsically safe in an explosive atmosphere. You will see a lot of them that have cab marker lights lit when they are parked up, although the newer types may have just a green light by the isolator switch.

The tachograph is also intrinsically safe, so is not a danger in that explosive atmosphere. See Simon, I was listening :laughing:

414

dave75:
Hi Dave (or any non-Dave’s that can help)

I’ve searched the forum and can’t find the answer so sorry if my question has been already asked:

Is it a legal requirement to drive with sidelights or dipped headlights switched on all the time when under ADR rules? Someone told me it is but I don’t remember that from when I did my ADR. I notice fuel tankers usually have their lights on but other trucks displaying orange plates don’t.

Thanks

Another Dave

Hi Dave,

There’s no general requirement in ADR that requires vehicle lights to be switched on when a vehicle is ‘in scope’ of ADR Regs.

If there is a requirement for lights to be switched on, it’ll either be what Malc said, or some other rule not mentioned in ADR, such as a national road-traffic type rule in a particular country.

415

That is a safety feature on ADR vehicles, but normally petroleum regulation fuel tankers. An ADR approved vehicle has an isolator switch and must be turned off whilst loading flammable liquids.

Thanks wheelnut. The truck I drive has an isolator switch and carries DG’s all the time but not in liquid form. I have to switch the lights on rather than them staying on themselves as a safety feature. Am I breaking the law by driving without my lights on? (In daylight that is!) I was told by a petroleum tanker driver that I was but I’m thinking it’s a company specific rule rather than one I could get points for.

416

And thanks dieseldave too, you must have posted that while I was typing my reply to wheelnut but I don’t know how to remove the post!

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dave75:
And thanks dieseldave too, you must have posted that while I was typing my reply to wheelnut but I don’t know how to remove the post!

Hi Dave,

There’s nothing wrong with your post mate, so there’s no need to delete it. :smiley:

BTW, you could only delete the contents, but not the actual post itself.
Mods/Admins can delete posts, but we really try to avoid this if at all possible because it makes a topic disjointed and difficult for readers to follow.