Splendid, thanks Dave.
Hi Dave
If I load a gas tanker and leave it in the yard awaiting collection. Is it under the tanker regulations or only when it goes on the public highway.
Thanks in advance.
Jim.
jcc100165:
Hi DaveIf I load a gas tanker and leave it in the yard awaiting collection. Is it under the tanker regulations or only when it goes on the public highway.
Thanks in advance.
Jim.
Hi Jim,
Could you clarify what you mean by “tanker regulations” please?
Sorry Dave
The Carridge of dangerous goods and use of transportable etc, we only do uk work from our depot.
It was a question which cropped up in a recent adr exam, now has caused a debate in the messroom.
Thanks
Jim
jcc100165:
Sorry Dave
The Carridge of dangerous goods and use of transportable etc, we only do uk work from our depot.
It was a question which cropped up in a recent adr exam, now has caused a debate in the messroom.Thanks
Jim
Hi Jim,
UK Regs [GDG 2009 (as amended)] are to be used for national (UK domestic) journeys.
CDG is based heavily on ADR, but with a few things done in a particularly ‘British’ way if the journey starts and finishes in the UK.
If your question is about tanker markings(?) this is one of the areas in which UK law differs quite a lot from ADR.
If you tell me what kind of gas was in the tanker and the exact subject of the debate, I can help you by giving a detailed answer.
Sorry Jim, but I need a good question before I can give you a good answer. 
Sorry Dave
A tanker loaded with Class 2.2 Liquid Nitrogen marked correctly for the road and road legal.
Left in our yard for the next shift, is it under any regulations sitting in our yard loaded, or only when it is on the public highway.
Thanks for your time
Jim.
jcc100165:
Sorry Dave
A tanker loaded with Class 2.2 Liquid Nitrogen marked correctly for the road and road legal.
Left in our yard for the next shift, is it under any regulations sitting in our yard loaded, or only when it is on the public highway.
Thanks for your timeJim.
Hi Jim,
As long as the tanker is marked correctly and road legal as you’ve said, then it’s as compliant as it needs to be and there’s nothing extra to do.
You’ve mentioned “public highway,” so I’ll explain that dangerous goods Regs don’t normally apply when the vehicle is not on a public highway.
To try to give you a better answer, a road is defined in England and Wales as: “any highway and any other road to which the public has access.” My own take on this is that IMHO the vehicle is parked off the road in a place that the public don’t have access to, so dangerous goods Regs don’t apply.
However, your yard is a place of work (a workplace) so all the other normal workplace Acts and Regs will still apply.
Sorry for being a bit slow on the uptake, but I hope I’ve answered your question?
Hi Dave
You have answered fully, I appriciate your help, and thanks for your patience.
Jim.
jcc100165:
Hi Dave
You have answered fully, I appriciate your help, and thanks for your patience.Jim.
Hi Jim,
No problem mate, it was probably my fault for over-thinking and guessing at the reason for your question.
Not all questions get asked in the straightforward way that yours came, so I sometimes have to ask a question to find out what the question actually is. I hope that makes sense.
dieseldave:
jcc100165:
Hi Dave
You have answered fully, I appriciate your help, and thanks for your patience.Jim.
Hi Jim,
No problem mate, it was probably my fault for over-thinking and guessing at the reason for your question.
Not all questions get asked in the straightforward way that yours came, so I sometimes have to ask a question to find out what the question actually is. I hope that makes sense.
I understand Dave
Thanks again
Jim.
Good Morning Dave
Just a quick question, is a PSN / product label required by ADR on a tank container?
Ubiquitous:
Good Morning DaveJust a quick question, is a PSN / product label required by ADR on a tank container?
Hi Ubiqitous,
I’m not quite sure what you mean by “product label,” but ADR doesn’t require the PSN to be displayed on a tank container for a road journey.
However…
Since tank containers are multi-modal, you’ll commonly see PSNs on the sides of tank containers because that is a requirement contained in IMDG for when the tank container is carried on a ship.
The IMDG requirement for PSNs applies equally to tank vehicles AND tank containers.
To comply with IMDG 5.3.2, tank vehicles and tank containers must display the PSN on at least both sides.
The lettering must be at least 65mm height and be written on a contrasting background.
Good Afternoon Dave
I was aware of the requirement under IMDG, However; it was ADR I wanted to clarify. I didn’t place a product label on an ISO Tank and was
questioned as to why. When I said it didn’t need one the proverbial hit the fan. I should have stuck to my guns, but as always it makes sense to check with the oracle.
Many Thanks.
Ubiquitous:
Good Afternoon DaveI was aware of the requirement under IMDG, However; it was ADR I wanted to clarify. I didn’t place a product label on an ISO Tank and was
questioned as to why. When I said it didn’t need one the proverbial hit the fan. I should have stuck to my guns, but as always it makes sense to check with the oracle.Many Thanks.
Hi Ubiquitous,
For a road journey, you were absolutely right!!
I’ve no idea why somebody would question why you hadn’t put something on that’s not needed.
Both the consignor AND the carrier need to have a properly qualified DGSA, so I’m thinking that two organisations had some doubts based on the fact that PSNs are normally seen on tank containers because they’re normally multi modal.
Given that it was a purely road journey, was it a domestic journey within the UK from start to finish?
If so, did you use the UK marking system and EACs?
I’ve asked that because the UK Hazard Warning Panel marking system looks a bit odd on a tank container too!!
Hi Dave, quick question if I may.
I hold a current ADR but for tankers only. We actually don’t need this under for our business of carrying non hazardous classified waste in our tankers but the boss thought it wise to take it anyway.
Previously I drove a 3.5t van, so again was out of scope of ADR regs when carrying scrap car batteries, which on occasion we do.
Now we have a 7.5t van and on our last CPC module which covered ADR briefly I asked the trainer about ADR regs and scrap batteries. He completely deflected my question and started going on about taking one battery to the council tip.
So my question is this.
Do I need to fully comply with ADR when carrying scrap batteries in a 7.5t lorry? The amount will be nominal usually under 100 batteries, often much less. Also if they do fall under ADR, will I need to take the packages part to cover me?
Many thanks in advance for any clarification.
109LWB:
Hi Dave, quick question if I may.I hold a current ADR but for tankers only. We actually don’t need this under for our business of carrying non hazardous classified waste in our tankers but the boss thought it wise to take it anyway.
Previously I drove a 3.5t van, so again was out of scope of ADR regs when carrying scrap car batteries, which on occasion we do.
Hi 109LWB,
The bit about the 3.5t van was OK until 2005, but since then there’s no sub-3.5t exemption any more.
109LWB:
Now we have a 7.5t van and on our last CPC module which covered ADR briefly I asked the trainer about ADR regs and scrap batteries. He completely deflected my question and started going on about taking one battery to the council tip.So my question is this.
Do I need to fully comply with ADR when carrying scrap batteries in a 7.5t lorry? The amount will be nominal usually under 100 batteries, often much less. Also if they do fall under ADR, will I need to take the packages part to cover me?
Many thanks in advance for any clarification.
I’m assuming that the scrap batteries are vehicle batteries of the lead/acid type, am I correct please?
If I’m correct, then here’s how it goes…
Assuming that my assumption is correct, then they’re called:
UN 2794 BATTERIES, WET, FILLED WITH ACID, electric storage, Class 8
(UN 2794 does not have a Packing Group.)
ADR does not apply 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.
However, there are a few things that do need to be correct because you’re carrying the batteries by use of a Special Provision [SP598(b),] contained in ADR as follows:
Used storage batteries <are exempt from most of ADR> when
- their cases are undamaged;
- they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
- there are no dangerous traces of alkalis or acids on the outside of the articles;
- they are protected against short circuits.
Definition of used:
“Used storage batteries” means storage batteries carried for recycling at the end of their normal service life.
======================================================
Here are the marking rules:
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” must be written on the shrink wrap, (a warehouse marker pen will do) 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 (a warehouse marker pen will do).
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.
Yes they are lead acid car/lorry batteries.
Usually we use large plastic boxes, (ibc sized although not as tall), rather than pallets, so presumably as long as I put the information on the box the same will apply? Might actually be easier to use a pallet now I have more room in the back of the truck but that’s something I’ll need to investigate.
We pick them up from garages/workshops, so as you can well imagine, they are simply dumped out the back somewhere and I have to carry them one by one to the vehicle to be properly loaded. In the past, when we used to pick up a lot more, we would often have broken casings which would go in with the rest. Now judging by your info, any battery that’s broken or leaking will cause the entire load to fall fully under ADR, so its easier for me just to refuse to take it.
Thankfully its very rare we carry any now, we used to do about 8 tons a week, now they are worth money the ■■■■■■ take them and leave me with a lot less hassle. It’s just the odd handful here and there, think I did less than half a ton in the last 3 years combined.
Many thanks for the info, just got to get the boss to realise we can’t just do this sort of stuff anymore without taking the right steps. He’s still very much of the mind of “it doesn’t matter”, but it will ■■■■ well matter when I get stopped by VOSA and have my arse handed to me on a plate.
Also regarding the 3.5t exemption… We were told last year by the EA and by our previous CPC tutor that it was still exempt, hence why we continued to do it without any regard to proper labelling. Always nice when the so called experts give you duff advice that could land you in hot water. 
Hi Dave
I am going to sit my DGSA Road course next month. I was a DGSA until 2010 but it has lapsed and my employer now wants me to sit it.
So being a good student I thought i would download the test paper that SQA has on it’s website for some practice but it doesn’t come with any answers. I have even spoken to them and they don’t provided the answers. It does beg the question why post the test paper up but heyho.
Any ideas where i can get some practice papers or sheets (with answers) online?
Many thanks
sunoco69:
Hi DaveI am going to sit my DGSA Road course next month. I was a DGSA until 2010 but it has lapsed and my employer now wants me to sit it.
So being a good student I thought i would download the test paper that SQA has on it’s website for some practice but it doesn’t come with any answers. I have even spoken to them and they don’t provided the answers. It does beg the question why post the test paper up but heyho.
Any ideas where i can get some practice papers or sheets (with answers) online?
Many thanks
Hi sunoco69,
I think the DGSA paper on the SQA website is simply intended as an indicative sample of an exam paper.
However, if you look at the other available papers, you’ll also see how best to set out your answers and references.
All that info is here: Dangerous Goods Safety Adviser - Syllabus and examinations - DGSA
Here’s one to get you started:
http://www.sqa.org.uk/files_ccc/DGSA_Sample_Papers_Guidance_Notes.pdf
I hope this helps.
Thanks Dave
I found those already, what I was really looking for were some old papers but with answer sheets. Be good to know that I am doing them right.