Ubiquitous:
Hi Dave
A question on PSN or product labels are they required at all times when transporting under ADR?
Hi Ubiquitous,
Is the question you’re asking the same as this one??
Or have I misunderstood?
Hi Dave
Thanks for your response, the question this time is when an ISO Tank is transporting goods on the ACL under ADR markings is a PSN or product label required? My previous question was regarding IMDG markings. I transported an ISO Tank the other day labeled under ADR but without product labels and it caused a point for discussion with another driver.
Ubiquitous:
Hi Dave
Thanks for your response, the question this time is when an ISO Tank is transporting goods on the ACL under ADR markings is a PSN or product label required? My previous question was regarding IMDG markings. I transported an ISO Tank the other day labeled under ADR but without product labels and it caused a point for discussion with another driver.
Sorry, it must be me…
I can’t work out whether the whole journey from consignor to consignee is national or international, so I’m not sure what you’re looking for?
It’s an IMDG (only) requirement to have the PSN written on two sides. That rule applies to all tanks regardless of whether it’s a tank-vehicle or a tank-container.
What do you mean by “ACL” please?
Hi Dave
Sorry haven’t replied sooner been away. Approved Carriage List (ACL) Thanks for your response
Ubiquitous:
Hi Dave
Sorry haven’t replied sooner been away. Approved Carriage List (ACL) Thanks for your response
Hi Ubiquitous,
I thought I kinda recognised those letters from somewhere, but I had to be sure… the ACL was done away with (IIRC) in 2003 and has been replaced with the Dangerous Goods Emergency Action Code List. (Known as the EAC List for short.)
I hope I’ve answered your question. 
Hi Dave
Thanks for your reply. I know it can be dangerous using out of date publications that’s why I also consult the Oracle. My apologise taking so long to reply only got home this morning.
Once again Many Thanks
Ubiquitous:
Hi Dave
Thanks for your reply. I know it can be dangerous using out of date publications that’s why I also consult the Oracle. My apologise taking so long to reply only got home this morning.
Once again Many Thanks
Hi Ubiquitous,
Not only has the ACL list changed out of all recognition, but the people issuing it have also been changed twice since the time of the ACL too!!
I’m here if you need me.
I am a freelance ADR instructor and Dangerous Goods Safety Advisor (DGSA)
That means that I’m not tied to any particular training provider.
A DGSA is a person, who has passed further ADR related exams, where full legal references are required for the exam answers, and is effectively a consultant in the transporting of dangerous goods.
Having read the above, I’m sure you can appreciate that I need to earn a living. My work takes me all over the country; therefore I’m not always at home every evening, and so don’t always have internet access. Please don’t think me ignorant if you don’t get an immediate answer. As some of you will already know, most ADR courses take place over a 5-day period. It might be that you don’t get an answer for several days. I DO NOT SIT AT MY COMPUTER 24/7
When you ask a question, please do your best to include as much relevant detail as possible. Things like: the UN number, the name of the stuff, its UN class number and its packing group or ADR transport category. Whether it’s in packages or a tanker, and whether it’s a UK or international journey. Also please be prepared that I might need to ask you a question or two, before I can give you an accurate answer. ANSWERS ARE ONLY STRAIGHTFORWARD WHEN YOU’VE ASKED A GOOD QUESTION.
Please post questions through the forum, rather than by PM. Hopefully, this will save me answering the same questions more than once, because other people will be able to see the questions and answers. You don’t have to pay for the advice you receive, nor do I get paid for giving it. I freely give my advice to hopefully save you from getting nicked- please remember that. MUTUAL RESPECT PLEASE.
Hi Dave I’m seeking clarification on a couple of points.
I drive for a plant hire firm where we hire diggers out either operated or self drive. When they are operated sometimes we are responsible for supplying fuel (red diesel) this is usually in the shape of a couple of 45 gallon drums which travel with the machines.
The larger machines 13t / 20t obviously use more fuel and have 1000l bunded flasks, occasionally these get run out to a machine if it has been moved from a site where there is fuel to one where there isn’t.
Now I seem to recall it’s OK to transport a limited quanity of fuel with the machine, but how do we stand in this instance.
The other day I was doing a transport job moving someone elses machines, when I got to site the digger driver was doing his nut because his yard hadn’t sent a tank with me. The tank in question was a 3000l job, would I be right in saying that would be a definate no no without ADR.
Are orange boards and extinguishers a requirement when moving limited quantities.
Appreciate any help for future ref.
8wheels:
Hi Dave I’m seeking clarification on a couple of points.I drive for a plant hire firm where we hire diggers out either operated or self drive. When they are operated sometimes we are responsible for supplying fuel (red diesel) this is usually in the shape of a couple of 45 gallon drums which travel with the machines.
Hi 8wheels
I’m answering all your points on the basis of trying to keep you out of the Regs by utilising exemptions. I’m guessing here that you don’t hold an ADR licence, so please tell me whether my guess is right, and whether I’m taking the right approach.[/i]
We have to talk metric I’m afraid (I don’t like it either 
)
You can carry red Diesel in 200 litre drums without fully obeying all of the Regs. You would (generally) need to obey the following though…
1. Any one drum cannot be more than 450 litres capacity. (So, you’re ok so far by carrying it in 200 litre drums.)
2. For 200 litre drums containing red Diesel, there is a limit per vehicle of 1,000 litres without you needing an ADR licence. (So you can carry up to 5 X 200 litre drums at a time.) [Any empties that you might collect are not counted anyway, so there’s no limit on those. ]
3. As an acceptable alternative to 2 above, you could instead carry 1 X 1,000 litre IBC of red Diesel using the same exemption.( IBC = [usually] a pallet sized plastic “tank” surrounded by a metal cage, although there are other types.)
4. You do not need a correctly made out “transport document.”
5. You’d need 1 X 2Kg dry-powder fire extinguisher of an approved type (British Standard kitemark and/or CE mark) fitted with a seal and pin and and a label showing the next due date of inspection. (TIP: keep this handy in your cab.)
6. The drums (or IBC) are of an approved type and are correctly labelled and marked. (That’s a matter for your boss.)
7. Also for your boss: You, and any other drivers who do the same as you, plus your boss and/or any office staff involved, would need ADR “awareness” training. This training must be tailored to the company’s activities, and records must also be kept. ( Please PM me for futher advice on this.)
8. The fuel contained in the fuel tanks of the diggers doesn’t count towards the 1,000 litre limit as long as any fuel taps (if fitted) have been turned to the “off” position and there are precautions to prevent leakage.
If you fully comply with the above then from ADR’s point of view, you don’t need:
Orange boards, an ADR licence, Instructions In Writing (IIW) sometimes known as a Tremcard, chock(s) torch, warning signs and hi viz, or some other things that people might mention. (I’m still trying to keep you exempt. )
> 8wheels:
> Now I seem to recall it’s OK to transport a limited quanity of fuel with the machine, but how do we stand in this instance.
Good recollection (answered above I hope 
)
> 8wheels:
> The larger machines 13t / 20t obviously use more fuel and have 1000l bunded flasks
(Now showing my ignorance of plant hire.) I’m guessing that “bunded flask” is a term used in the plant-hire industry.
In practice, the “bunded flask” is either going to be counted as a “package” or some sort of “tank” and the rules are a bit different for these. ADR will have a definition for this, so I’ll need a good description of the size and appearance of one of these, before I can give you a good answer. (There’s another possible exemption that I have in mind. and I might then need to edit this post.)
> 8wheels:
> The other day I was doing a transport job moving someone elses machines, when I got to site the digger driver was doing his nut because his yard hadn’t sent a tank with me. The tank in question was a 3000l job, would I be right in saying that would be a definate no no without ADR.
Almost certainly, without an ADR licence, you’re pretty well stuck with a 1,000 litre limit for red Diesel.
> 8wheels:
> Are orange boards and extinguishers a requirement when moving limited quantities.
Covered above, I hope.
“Limited Quantities” (LQs) is a commonly misunderstood concept. (That statement includes many bosses and ADR trained drivers.) LQs relate to the size of an inner receptacle packed inside some other form of package. The LQ sizes for red Diesel are 5 litres for the inner receptacle and 30 litres for the whole package. If you comply with this, there is NO LIMIT to the amount on the vehicle. The LQ exemptions are usually used for movements of dangerous goods packaged ready for retail sale to the public.
The exemption I’m using for you isn’t LQs, but exemption based on amount carried per vehicle at one time.
As a footnote, VOSA often issue a PG9 when breaches of dangerous goods Regs are involved. Your boss should be aware of the possible consequences. Also for your boss, he/she might need to appoint a DGSA, or at least take advice from a DGSA on the “office” side of the exemptions.
BTW, Great question and great pics in the PDF.
OK DieselDave, great help mostly confirming what I was fairly sure about. You are correct in that I am non ADR. This used to rear it’s ugly head last year with a former employer and they took the head in the sand approach to it. This employer is different and genuinely does want to do things correctly. Well at least he says he wants to.
The bunded flasks are steel tanks that look like this
As I recall they say something like 1100l bunded fuel flask on them, but am I right in saying that i bund has to hold 110% of the tank? This would give a 1000 capacity and therefore squeeze under the ADR limit. Does the amount of 1000l cover the actual fuel in the tank or the size of it. For example, could I move a 3000l tank with 1000l in it.
What sort of labelling must be applied to the tanks and drums?
How do I stand if coming back through the Dartford Tunnel with fuel on board? Do I have to join the DG queue for ■■■■■■ with the tankers, If so is there a cost involved with this?
Last year when I used to go to the Isle of Wight, they would spot an oil drum a mile off and I’d have to go and get a DG form and then travel under DG regs. It was a right pain because they would only load a certain amount of DG and sometimes I’d have to miss a couple before they could load me.
8wheels:
This employer is different and genuinely does want to do things correctly. Well at least he says he wants to.
Please let him know, because keeping you/the firm out of full ADR isn’t too difficult/costly. As I said, there are some areas they/you must still obey. Keeping you/the firm out of the full requirements doesn’t mean that you’re “out of Regs” and escape entirely. It appears that there may be several areas of potential concern. We must realise that red Diesel is “dangerous goods,” so, some of the UK carriage Regs/ADR will apply to you moving it about by truck on a road. I can’t comment further on this point without specific info on exactly what your firm does and the red Diesel itself. I’m now between a rock and a hard place, because ADR has such precise definitions. It’s simply not fair on your boss to put such info on a forum, so I’d advise that he needs to have a conversation/meeting with a DGSA to clarify his exact responsibilities. It might be that he doesn’t need to actually appoint a DGSA on an ongoing basis, but your boss won’t have a clue unless he makes himself aware. A DGSA could probably deal with all of this in a single visit, plus some informal training. There are limits for actually having to appoint a DGSA. The following must now only be viewed as general info:
8wheels:
As I recall they say something like 1100l bunded fuel flask on them, but am I right in saying that i bund has to hold 110% of the tank?
The bund isn’t to do with ADR, so I’m a bit off my patch on that subject. I’d guess that the bund is to do with storage and/or environmental Regs. I do seem to remember something about 110% being the size for bunds though. (A visit to the Environment Agency’s website might clarify.)
The yellow item of equipment in your photo (thanks for that BTW) could be counted as: a “package,” or an “IBC,” or a “bowser” or even a “bowser counting as an IBC.” UN approval generally applies to all of those items, but there are some UK exemptions based on size (capacity) and date of manufacture. Under this exemption, some non-approved types are actually allowed for UK use until May 2019. I’d need the date of manufacture and knowledge of any other markings before commenting further on that. For now, I would hesitate to use the word “tank” to describe it. If you’re an employed driver, this is your boss’ responsibility.
8wheels:
This would give a 1000 capacity and therefore squeeze under the ADR limit. Does the amount of 1000l cover the actual fuel in the tank or the size of it.
To clarify for you, the limit is on the nominal capacity eg 1,000 litres. There has to be an allowance of extra space in tanks and packages called “ullage” to allow the contents to expand SAFELY, for instance during hot weather. That “extra” space above the liquid doesn’t count as “capacity,” but MUST always be there. If you comply with this, it’s only one point. There are still other issues to consider, which are mentioned in my first reply.
8wheels:
For example, could I move a 3000l tank with 1000l in it.
Using the words “tank” or “package” the answer is: 'fraid not. It’s decided by the nominal capacity, rather than the amount actually in it. It’s academic in your case, but the maximum allowed size for an IBC is 3,000 litres. Without an ADR licence, you’ll still be caught by the 1,000 litre limit per vehicle though, because an IBC is counted as a package.
8wheels:
What sort of labelling must be applied to the tanks and drums?
This question is miles outside of the scope of a driver’s responsibilities, even if ADR trained. This is a matter for your boss (the “carrier”) or the sender (“consignor”) of the goods. These two words have specific definitions in ADR. It’s possible that your boss might meet both definitions, if so, he has two sets of responsibilities. (Please refer to first paragraph.)
Generally speaking, a drum must have: a UN approval mark (the letters"UN" in a circle) followed by a code designating the terms of its approval. For a “normal” steel drum with “bung” type closures, the first part of the code will probably be: 1A1, but other codes/construction materials are allowed for red Diesel. The UN approval mark and code are usually applied to a steel drum by stamping or embossing during manufacture. Next, the drum would require a “diamond” label of 100x100mm min size, with the following: background colour = red, a flame symbol in the top half and a figure “3” in the bottom half. The words “Flammable liquid” may also be on the label, but that’s not compulsory. The graphics may be black or white in this case. The UN number for the goods inside the drum should also be written or labelled on the drum with the letters “UN” written first. For Diesel, it would normally be UN1202. An IBC, being much bigger than a drum, requires UN approval like the drum, plus (sometimes) an information plate, and then needs the same labels/markings as a drum, but doubled and placed on two opposite sides. An IBC may need periodic re-testing. If it turns out that the yellow item is a steel IBC, then its code would probably start with 31A.
8wheels:
How do I stand if coming back through the Dartford Tunnel with fuel on board? Do I have to join the DG queue for ■■■■■■ with the tankers, If so is there a cost involved with this?
To answer this one, I’d need to know the flashpoint and manufacturing standard for the Diesel. The fuel supplier will have this info. Your boss could ask them for it. Whether you’re allowed straight through can also depend on the size(s) of the packages you have on board.The Dartford tunnel has different limits than ADR, because they’re looking at a slightly different question, using different rules and from their point of view. I spoke to them today about a “theoretical” case (uncannily similar to yours ) Their advice was that you should stop for checking, but you’d probably get a wave through without ■■■■■■, but it depends on the size of the individual package(s.) That much isn’t clear in their relevant book on the subject even though I have the current edition. 
We did clarify that 5X200 litre drums don’t need an ■■■■■■, and that 1X1,000 litre IBC does. We also found out that they don’t charge for escorting, so I learned something as well! 
Another interesting point was that they said they’d check your paperwork. That rang an alarm bell for me. Please refer your boss to my last reply to you and the mention of “transport document.” If VOSA/HSE/Police are hanging around the tunnel’s truck inspection area, you might come to their attention… . As I said in my first reply, they often issue a PG9 when DG offences are discovered. Prosecution and fines usually follow for both driver and company. The Traffic Commisioner gets to know, then quetions might be asked at the next “O” licence review. Stable doors and horses come to mind here.
8wheels:
Last year when I used to go to the Isle of Wight, they would spot an oil drum a mile off and I’d have to go and get a DG form and then travel under DG regs. It was a right pain because they would only load a certain amount of DG and sometimes I’d have to miss a couple before they could load me.
You’re spot-on there, that’s because you were being considered under the Regs for carrying dangerous goods by sea (IMDG.) Their limits are far stricter than ADR’s. If aeroplanes were involved (IATA DG Regs) their limits are usually even tighter again.
OK this is all great info, once I have got all my relevant facts together I will go and speak to the boss about it. As long as I know I’m right I will tell him the postion and state that I will not move fuel unless we comply with the above.
On the assuption that we get everything above sorted are we allowed to take an IBC or package (drum) from the yard to a site where the machine already is.
ie. can we transport the fuel, when we are not carrying the plant for which it is intended.
Lastly (phew) I assume that this is applicable to any vehicle involved in the task, LGV or LDV.
Thank you for your time and patience.
8wheels:
OK this is all great info, once I have got all my relevant facts together I will go and speak to the boss about it. As long as I know I’m right I will tell him the postion and state that I will not move fuel unless we comply with the above.On the assuption that we get everything above sorted are we allowed to take an IBC or package (drum) from the yard to a site where the machine already is.
Yes. The yellow “thingy” will probably count as an IBC for ADR’s purposes. BTW, are there any markings/serial numbers stamped/embossed on them?? A nice close-up pic would help. This is now the only unresolved part of your questions. the issue is that you called it an “1,100” litre bunded flask.
We must clarify that its “CAPACITY” isn’t more than 1,000 litres. If the bund takes it to the stated 1,100 litres total capacity, you’re OK to carry one of them at any one time. If it’s 1,100 litres plus the bund, you have a little problem in that you’re still stuck with the 1,000L limit. That’s definitely a question for your boss/the manufacturer, unless it’s clearly written on it somewhere.
When that “thingy” is on the ground, as in your pic, ADR isn’t interested in it. It’s then a bunded flask for environmental/storage Regs. ADR only takes an interest when you carry it on a truck. You can only carry: one of these at a time, if its capacity is 1,000 litres. Alternatively, you could carry up to 5X200 litre drums at any one time. (Remember, the fuel already in the digger’s tank DOESN’T count, so you can also fill that before you set off. )
8wheels:
ie. can we transport the fuel, when we are not carrying the plant for which it is intended.
Yes. The fuel can be transported without the machine(s) as long as you don’t go above the 1,000 litre limit above. (Remember ANY number/combination of empty drums/IBCs can ALSO be carried at any time- they don’t count either)
8wheels:
Lastly (phew) I assume that this is applicable to any vehicle involved in the task, LGV or LDV.
Yes. There was an exemption for vehicles of less than 3,500Kgs GVW, but that ended on 1/1/07, so now even they will be affected by the same limits.
8wheels:
Thank you for your time and patience.
No probs 8wheels, thank you for yours also. I can’t always answer straight away, and sometimes there’s some research involved. Your questions about that yellow “thingy” and the Dartford Tunnel involved some research outside of both ADR and normal UK Regs. I do answer as quickly as possible, within limits, though. Excellent questions BTW.
OK, had a chance to look round the steel IBC’s in the yard today.
I’m not sure where I got the 1100l from there’s nothing on them except for a big label with the companies name and details etc. and 110% bunded fuel flask.
There is a little embossed serial number plate however and it gives the unladen weight as 500kg Laden at 1500Kg, assuming diesel weighs 1Kg per litre this would make it a 1000l IBC would it not?
The next task is to present my findings to the boss, might take a while as one of them has just gone away. I’m not too worried as it’s not something that has occured, just that it might.
8wheels:
OK, had a chance to look round the steel IBC’s in the yard today.I’m not sure where I got the 1100l from there’s nothing on them except for a big label with the companies name and details etc. and 110% bunded fuel flask.
I wouldn’t worry about that. You were going from memory, so that’s why I asked for more info.
8wheels:
There is a little embossed serial number plate however and it gives the unladen weight as 500kg Laden at 1500Kg, assuming diesel weighs 1Kg per litre this would make it a 1000l IBC would it not?
I’m a little surprised that there isn’t a proper “UN” marking as I described above, but there are many non-approved versions around. Depending on a few conditions as I mentioned above, it might be no problem whatsoever, because there’s a UK exemption in force until 2019. Before I can give you a good answer, I’m afraid we’re back to needing some info from your boss and/or the manufacturer.
Thanks for the 500 unladen… etc. Your assumption is generally correct, because we’d normally count 1 litre as weighing 1 KG, but that’s based on the weight of water. Interestingly, litre for litre, Diesel is actually a little lighter in weight than water. That’s why ADR works on literage for liquids, rather than Kgs. That’s another reason I mentioned the manufacturing standard when you asked about the Dartford Tunnel.
Spare a thought for somebody carrying sulphuric acid, because 1 litre of that weighs approx 1.8 Kgs there’s many a tanker driver been caught for overweight with that stuff.
We’re looking for an allowed capacity not exceeding 1,000 litres, plus the ullage space (not counted) plus the bund (also not counted.) ADR wouldn’t be interested in the gross weight for instance, but you’d have to count the weight for axle/GVW loading purposes under the Construction and Use Regs.
Hi Dave,
When collecting a trailer from a port and it has “airbag inflators or air bag modules , only by sea related goods” on the cmr. Do you need ADR to transport these goods from port to delivery point?
Thanks
Added a picture of what the cmr states
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PAULSIMO:
Hi Dave,When collecting a trailer from a port and it has “airbag inflators or air bag modules , only by sea related goods” on the cmr. Do you need ADR to transport these goods from port to delivery point?
Hi PAULSIMO,
The CMR isn’t quite correctly filled in, it should say:
UN 3268 SAFETY DEVICES, 9
These goods are in ADR Transport Category 4, so you can carry as much as you like without an ADR Card or orange plates etc.
dieseldave:
PAULSIMO:
Hi Dave,When collecting a trailer from a port and it has “airbag inflators or air bag modules , only by sea related goods” on the cmr. Do you need ADR to transport these goods from port to delivery point?
Hi PAULSIMO,
The CMR isn’t quite correctly filled in, it should say:
UN 3268 SAFETY DEVICES, 9
These goods are in ADR Transport Category 4, so you can carry as much as you like without an ADR Card or orange plates etc.
Thanks for the quick reply, appreciate it!
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Having had a time out break from H.G.V . driving class 2 only and only worked in delivering frozen food industry ive joined an agency and am currently working for and a local ish company my question is how much dangerous good can i transport on an 18 tonne 14 pallet wagon in layman terms please i.e how many 20 litre containers of oil or bleach
how many 50 litres drums of oil or chemicals
whats the limit on flammable items i can carry without an ADR
am i legal to carry a ibc container think theyre a 1000 litres, without an ADR ive tried looking online but its confusing , thank you for youre help