Hazardous products

[ste_j]

My son works as a van driver, driving a 3.5t transit for a company that distributes goods to pubs, clubs etc.
Quite frequently he loads up with large amounts of chemicals in 5 litre plastic containers, sometimes from bulkhead to rear doors, to replenish stocks at the warehouse. These consist of cleaning chemicals such as bleach in various strengths, some of which are very strong, beer line cleaning agents, and polish. A large proportion of which are clearly marked with hazardous warning labels.

Does this mean that the van should be labelled with hazardous warning stickers?

And if so should my son then have to have the relevant Haz-pak or Haz-chem training to enable him to drive the van?

[simon]

Depending on the quantities of the chemicals involved and the scientific strength of them, they might come under ADR regulations.
Provided the containers are under a certain size, then they are classified as “Limited Quantities” and don’t come under the ADR Regs.
Unfortunately I can’t tell you what size of container is the max, because it’s different for each ADR class and I’m now out of date with exactly what the regulations say.

If the containers are over those sizes, then the van will have to have hazard labels on it and your son will need to have the appropriate ADR training.
His employer is responsible for ensuring that his load doesn’t come under ADR regs and if it does, that your son has had the correct training.

ADR is the most recent version of Haz-Pak Haz-Chem and is a European wide qualification. The old one was the UK qualification.

[ste_j]

cheers simon

[dieseldave]

ste.j:
My son works as a van driver, driving a 3.5t transit for a company that distributes goods to pubs, clubs etc.
Quite frequently he loads up with large amounts of chemicals in 5 litre plastic containers, sometimes from bulkhead to rear doors, to replenish stocks at the warehouse. These consist of cleaning chemicals such as bleach in various strengths, some of which are very strong, beer line cleaning agents, and polish. A large proportion of which are clearly marked with hazardous warning labels.

Does this mean that the van should be labelled with hazardous warning stickers?

And if so should my son then have to have the relevant Haz-pak or Haz-chem training to enable him to drive the van?

Your son might need an ADR certificate to carry the loads you mentioned.
It used to be that the type of vehicle your son drives was exempt from ADR on the basis of it being <3,500 Kgs G.V.W. However, that exemption ended on 1/1/07.

The next subject to consider is/are the substance(s) that he carries. Dangerous goods are listed in ADR’s Dangerous goods list. For EACH substance there are exemptions based on the size of the package. However, some substances are so dangerous that NO exemption is permitted. I think it likely that the substances your son carries would possibly have some exemption under the “limited quantity” (LQ) provisions. If the dangerous goods are individually loaded in the way you describe, then the LQ exemptions would NOT apply.

Given that the LQ exemptions don’t apply, the next thing to consider is the degree of danger (transport category) and the total amount loaded. It may be that your son wouldn’t need an ADR certificate, because he carries less than the allowance given before the ADR regulations apply in full.

ADR has definitions for “carrier” (the owner of the vehicle) and “consignor” (the person or company offering the dangerous goods for transport) BOTH of whom must appoint a Dangerous Goods Safety Advisor (DGSA) to advise on the legality of the transport operation from a dangerous goods point of view. DGSAs also have other duties. The person who actually hands over the load must also have had some " ADR awareness" training.

So the answer to your question isn’t straightforward, I’m afraid. It would depend on how dangerous the goods are, how they are packaged and how much of them he has on board at any one time.

Your next point related to “vehicle labels.” For dangerous goods in packages, there must be orange coloured plates on the vehicle (front and rear) if the ADR allowances (load limits) are exceeded. The diamond shaped “stickers” you mentioned are only required on road vehicles carrying explosives or radioactives.

Given that the LQ exemptions do not appy, ADR also requires that dangerous goods are accompanied by the correct documentation. A competent DGSA would be able to tell from this how much, if any, of ADR applies.

As both a DGSA and ADR instructor, I strongly advise your son to ask his boss some questions.
dieseldave

[matchbox]

I agree with the above post, it is quite conplicated at times.

I myself have just successfully taken my ADR.

I’ll try and condense it further, not all the drivers where I work have their ADRs and I load all the vehicles before I go out on my own run, so this is the rule of thumb that I apply.

Each substance has a Transport Category. (You’ll see it in the shape of a coloured diamond attached to the package.)

In short, if you see a ‘2’ and its any colour OTHER than GREEN then the maximum weight he can carry without his ADR is 333kg.

If you see a 3, 4, 5, 6, 8 or 9 then the maximum COMBINED weight of any of the previously mentioned categories is 1000kg.

Class 1 is EXPLOSIVES and the limit is 20kg.

Class 7 is RADIOACTIVES.

Again, if in doubt, consult a DGSM.

All vehicles that are concerned in the transportation of hazardous materials must have an ADR kit in the vehicle.

But don’t forget, ALL hazardous substances that are marked hazardous, MUST carry not only a ‘diamond’ but have a Transport Emergency Card with the documents. aka a ‘TREM’ card.

[wheel_nut]

matchbox:
But don’t forget, ALL hazardous substances that are marked hazardous, MUST carry not only a ‘diamond’ but have a Transport Emergency Card with the documents. aka a ‘TREM’ card.

Ooh, dont let the pedants see this piece Matchbox

You are not allowed Tremcards anymore. You must have Instructions in Writing

[matchbox]

Wheel Nut:

matchbox:
But don’t forget, ALL hazardous substances that are marked hazardous, MUST carry not only a ‘diamond’ but have a Transport Emergency Card with the documents. aka a ‘TREM’ card.

Ooh, dont let the pedants see this piece Matchbox

You are not allowed Tremcards anymore. You must have Instructions in Writing

Whoops!

I meant to say " Written Emergency Information"

[dieseldave]

matchbox:
I agree with the above post, it is quite conplicated at times.

I myself have just successfully taken my ADR.

I’ll try and condense it further, not all the drivers where I work have their ADRs and I load all the vehicles before I go out on my own run, so this is the rule of thumb that I apply.

Each substance has a Transport Category. (You’ll see it in the shape of a coloured diamond attached to the package.)

In short, if you see a ‘2’ and its any colour OTHER than GREEN then the maximum weight he can carry without his ADR is 333kg.

If you see a 3, 4, 5, 6, 8 or 9 then the maximum COMBINED weight of any of the previously mentioned categories is 1000kg.

Class 1 is EXPLOSIVES and the limit is 20kg.

Class 7 is RADIOACTIVES.

Again, if in doubt, consult a DGSM.

All vehicles that are concerned in the transportation of hazardous materials must have an ADR kit in the vehicle.

But don’t forget, ALL hazardous substances that are marked hazardous, MUST carry not only a ‘diamond’ but have a Transport Emergency Card with the documents. aka a ‘TREM’ card.

Congrats on passing your ADR.
I’m sorry, but what you’ve written isn’t quite right. You seem to have confused “UN class” and “Transport category.” (There is NO connection between the two.)
The UN class number tells us only the nature (type) of the hazard eg fire or poisoning etc, it tells us NOTHING about the degree of danger.

In all regs, IATA, IMDG, RID and ADR we use packing groups (Roman numerals I, or a II ,or a III) to express how dangerous the “stuff” is. ADR extends the idea of packing groups, which we call “transport categories” which gets us to our load limits. There is only ONE way to know for sure what the load limit is for a particular dangerous good; you must refer to the table in ADR 1.1.3.6.3

Tremcards are only required when the load exceeds the values given in 1.1.3.6.3; if the values are not exceeded, the only document you need is a transport document. You also wouldn’t need an ADR kit or the larger of the fire extinguishers

I’d stress that there is NO rule-of-thumb method for this.

You mentioned UN class 2. The load limits for these depend on whether the gas is “just” a gas, or whether it is a liquified gas, plus which subdivision it belongs to. Not easy!

As for explosives, sorry but you’re wrong. Some of them,1.4 S, can be carried in ANY amount, without orange boards etc.

As for UN classes 3,4,5,6,8&9 sorry but you’re wrong again. The limit for some of these is 0Kg/lit, for some others it is 20Kg/lit, for some it is 333Kg/lit and for others it is 1,000Kg/lit. Some are unlimited. I’d stress that there is NO rule-of-thumb method for this.

Under ADR, a driver isn’t required to know the above, it is for the owner of the vehicle to tell the driver whether he/she is subject to regs.

As you rightly said, consult a DGSA.
dieseldave

[matchbox]

Whoops!

Botty smacked!

I yeild to the greater knowledge.

Much to learn I still have!

[dieseldave]

matchbox:
Whoops!

Botty smacked!

I yeild to the greater knowledge.

Much to learn I still have!

Hey, what’s all this?
You’re absolutely spot on when you said instructions in writing!

As a DGSA we’re required to pass written exams on ADR, but even that’s not enough. We also have to say where we’re quoting from, otherwise we score a fat zero, even if the answer is correct.

I have to say that ADR doesn’t mention the word “Tremcard” anywhere in the two volumes of approx 1300 pages.

The word “Tremcard” comes from: TRansport EMergancy CARD, the capital letters put together spell TREMCARD. An organisation called CEFIC thought up a standardised form for the information. The word CEFIC comes from the French initials for “European Council of Chemical Manufacturers,” which in French is: CEFIC.

If CEFIC produces instructions in writing, it is a “Tremcard,” because CEFIC copyrighted the word “Tremcard.” If anybody else produced your instructions in writing, then it isn’t a tremcard. It’s as simple as that!

So, if you’re ever carrying a tremcard, it’s actually better than the minimum required by ADR- Happy days!

Botty not smacked, have a gold star instead!
dieseldave

[lovlyperson]

ste.j:
My son works as a van driver, driving a 3.5t transit for a company that distributes goods to pubs, clubs etc.
Quite frequently he loads up with large amounts of chemicals in 5 litre plastic containers, sometimes from bulkhead to rear doors, to replenish stocks at the warehouse. These consist of cleaning chemicals such as bleach in various strengths, some of which are very strong, beer line cleaning agents, and polish. A large proportion of which are clearly marked with hazardous warning labels.

Does this mean that the van should be labelled with hazardous warning stickers?

And if so should my son then have to have the relevant Haz-pak or Haz-chem training to enable him to drive the van?

makes no sense as he must be overloaded and dangerous on the Way if he is full loaded with 5 Liter Plastic containers.

[dieseldave]

Lovlyperson:
makes no sense as he must be overloaded and dangerous on the Way if he is full loaded with 5 Liter Plastic containers.

I understood that he meant a full legal load, not an overload. I took that as an ADR question rather than a “weights” question.
To give a good answer to the ADR part of this, I would need more info on the total amounts he carries, the method of packaging and exactly which UN numbers are involved.

This is an old question anyway Lovlyperson, and I didn’t see a reply to my first post from the original question, so maybe we will never know