My company has recently taken on a new contract and on the manifests there is the Limited Quantity label
MY question is, do we as drivers need to have completed any formal training before carrying goods under these conditions?
Many thanks
Nez
Personally I would give hazardous awareness training but there is no legal requirement to do so
stringy:
Personally I would give hazardous awareness training but there is no legal requirement to do so
Hi stringy,
I’ll differ only slightly from what you’ve said.
The awareness training is not only a good idea, but my opinion is that ADR 3.4.1(a) makes it also a legal requirement.
Here’s my thinking:
ADR 3.4.1 This Chapter provides the provisions applicable to the carriage of dangerous goods of certain
classes packed in limited quantities.
Limited quantities of dangerous goods , meeting the provisions of this Chapter are not subject to any other provisions of ADR except the relevant provisions of:(a) Part 1, Chapters 1.1, 1.2, 1.3, 1.4, 1.5, 1.6, 1.8, 1.9;
(b)
(c)
(d)
(e)
(f)
(g)
(h)
Here’s what ADR Chapter 1.3 has to say about training in the OP’s case:
CHAPTER 1.3
TRAINING OF PERSONS INVOLVED IN THE CARRIAGE OF DANGEROUS GOODS1.3.1 Scope and applicability
Persons employed by the participants referred to in Chapter 1.4, whose duties concern the carriage of dangerous goods, shall be trained in the requirements governing the carriage of such goods appropriate to their responsibilities and duties.
Employees shall be trained in accordance with 1.3.2 before assuming responsibilities …1.3.2 Nature of the training
The training shall take the following form, appropriate to the responsibility and duties of the individual concerned.1.3.2.1 General awareness training
Personnel shall be familiar with the general requirements of the provisions for the carriage of dangerous goods.1.3.2.2 Function-specific training
Personnel shall be trained, commensurate directly with their duties and responsibilities in the requirements of the regulations concerning the carriage of dangerous goods. Where the carriage of dangerous goods involves a multimodal transport operation, the personnel shall be aware of the requirements concerning other transport modes.1.3.2.3 Safety training
Commensurate with the degree of risk of injury or exposure arising from an incident involving the carriage of dangerous goods, including loading and unloading, personnel shall be trained in the hazards and dangers presented by dangerous goods. The training provided shall aim to make personnel aware of the safe handling and emergency
response procedures.1.3.2.4 The training shall be periodically supplemented with refresher training to take account of changes in regulations.
1.3.3 Documentation
Records of training received according to this Chapter shall be kept by the employer and made available to the employee or competent authority,
Quite how the OP’s company chooses to adapt the above to take account of their situation regarding the carriage of LQs is left entirely up to them (as long as a record is kept), but I do agree that there’s no formal course to attend, no matter what quantity is carried.
Thanks for the replies.
So, from a drivers point of view, if we transport the goods with this label displayed (it is also displayed on the shrink wrap around the pallets), are we or the company committing an offence if we’ve had no form of training or hazard awareness training?
Cheers, Nez
Nezza:
Thanks for the replies. So, from a drivers point of view, if we transport the goods with this label displayed (it is also displayed on the shrink wrap around the pallets), are we or the company committing an offence if we’ve had no form of training or hazard awareness training?Cheers, Nez
stobrats do it for mcbrides out of Middleton! 
wouldn’t put them on myself 
couldn’t be arsed getting a tug! 
I often wondered about temporary hazardous goods transport.
Often found amongst my multidrops, the odd pallet of Parrafin (1 litre bottles or 1 gallon bottles) for domestic delivery.
I did query it with the transport manager, and he said [zb]ed if I know. The paperwork doesn’t highlight it, the customer doesn’t point it out to us. Collecting depots don’t tell us. So I wouldn’t worry about it.’
Depot manager said something about the quantities being small and infrequent.
We had a similar situation , suppying small gas bottels for Roofers torches…H&S said , two bottles max at a time only…as long it was not a "bulk “sale for hire or reward, and motors to get " hazzard plates” on Monday, there is extra paperwork also.
I left our H&S Exe, in a great mood last thing friday , when i asked if the gas cans for nail guns would fall under the new regime .
.llBassstwards ,did’nt think 
whole ■■■■■■■ lot of that paperwork needs ammended now, i heard, over him banging doors.
Nezza:
Thanks for the replies.So, from a drivers point of view, if we transport the goods with this label displayed (it is also displayed on the shrink wrap around the pallets), are we or the company committing an offence if we’ve had no form of training or hazard awareness training?
Cheers, Nez
Hi Nezza,
It’s the employer (your boss) who has to provide any training that’s necessary in connection with a job that he asks you to do for him.
Given that this training isn’t part of a formal course, the training can be provided in-house or by an external provider as long as it’s somebody who delivers the required subject areas and a record is kept by the employer.
Clunk:
I often wondered about temporary hazardous goods transport.
Often found amongst my multidrops, the odd pallet of Parrafin (1 litre bottles or 1 gallon bottles) for domestic delivery.
I did query it with the transport manager, and he said [zb]ed if I know. The paperwork doesn’t highlight it, the customer doesn’t point it out to us. Collecting depots don’t tell us. So I wouldn’t worry about it.’
Depot manager said something about the quantities being small and infrequent.
Hi Clunk,
From the info you’ve given, this looks like it’s possibly covered by a different exemption (not LQs.)
If my guess is correct, the fact that the paperwork doesn’t mention it is OK.
Nedbear:
We had a similar situation , suppying small gas bottels for Roofers torches…H&S said , two bottles max at a time only…as long it was not a "bulk “sale for hire or reward, and motors to get " hazzard plates” on Monday, there is extra paperwork also.
I left our H&S Exe, in a great mood last thing friday , when i asked if the gas cans for nail guns would fall under the new regime .
.llBassstwards ,did’nt think
Hi Nedbear,
This sounds like somebody is making it up as they go along.
How big (in liters or milliliters) are these “small gas bottels for Roofers torches” please?
What’s in them… is it Butane?
BTW, there’s NO WAY that this is anything to do with either “bulk” or “hire or reward.”
How big (in liters or milliliters) are the “gas cans for nail guns” please?
What’s in them… is it compressed air?
How much/many do you carry at any one time?
If you can answer my couple of questions, it might save your boss from banging the doors, producing extra paperwork or maybe even buying unnecessary orange plates.
For limited quantities then no, but them placards will have to be placed to the front and rear of the vehicle for road transport after 2014 as compulsory.
Fatboy slimslow:
stobrats do it for mcbrides out of Middleton!
You will have to put them on front and back of the vehicle soon, if you don’t and you are stopped then you will be in a spot of bother
dieseldave:
How big (in liters or milliliters) are these “small gas bottels for Roofers torches” please?
What’s in them… is it Butane?BTW, there’s NO WAY that this is anything to do with either “bulk” or “hire or reward.”
How big (in liters or milliliters) are the “gas cans for nail guns” please?
What’s in them… is it compressed air?How much/many do you carry at any one time?
If you can answer my couple of questions, it might save your boss from banging the doors, producing extra paperwork or maybe even buying unnecessary orange plates.
Limited quantities is anything at all that is hazardous. Say half litre of flammable liquid that is not big enough to come under ADR regs. An example of this would be hair spray’s
Kerbdog:
Fatboy slimslow:
stobrats do it for mcbrides out of Middleton!You will have to put them on front and back of the vehicle soon, if you don’t and you are stopped then you will be in a spot of bother
Hi Kerbdog,
You’re spot-on with that mate. 
Since 2011, there has been a requirement to mark a vehicle carrying LQs as follows:
If the vehicle has a maximum mass of more that 12t and it’s carrying more than 8t of goods packaged in LQs, then the vehicle needs to be marked.
The makings can be either:
Two orange plates, one at the front and one at the rear.
OR
Two LQ placards (250mm X 250mm) as in the pic in the OP, one at the front and one at the rear.
This applies only to vehicles.
The driver still does NOT need an ADR licence nor any special ADR kit or equipment, no matter how much/many goods packaged in LQs are carried on board the vehicle.
To be honest DieselDave, I thought it was the packaging only that had to be labelled up from 2011 but as far as I was aware the vehicles for road transport only have to be marked (front and back) from sometime either this year or 2014. When I done my ADR is August 2011 the guy was saying it was just coming in on the packaging but he definately said that the vehicle regs were coming in at a later date, and as yet you never seem to see any vehicle with the ltd qty placards on the front at all. I say the front as you do see trailers marked up usually that have come off the boat unaccompanied.
When I’m on Mcburney’s they do backloads with ltd qty’s, The trailers are running around all the time for miles on end with the placards still showing as nobody bothers to turn them around. The bit that confuses me is that they give you 4 (one for each side) which is daft as IMDG regs say that ANY quantity of hazardous must be declared via class placards on all sides of the container / vehicle. Now I have only done 1 load of ADR in nearly 2 years and my memory maybe somewhat forgetful of what I was taught !! So if I have got it wrong that is why. What’s your interpretation of it ? Thanks.
Kerbdog:
To be honest DieselDave, I thought it was the packaging only that had to be labelled up from 2011 but as far as I was aware the vehicles for road transport only have to be marked (front and back) from sometime either this year or 2014. When I done my ADR is August 2011 the guy was saying it was just coming in on the packaging but he definately said that the vehicle regs were coming in at a later date, and as yet you never seem to see any vehicle with the ltd qty placards on the front at all. I say the front as you do see trailers marked up usually that have come off the boat unaccompanied.When I’m on Mcburney’s they do backloads with ltd qty’s, The trailers are running around all the time for miles on end with the placards still showing as nobody bothers to turn them around. The bit that confuses me is that they give you 4 (one for each side) which is daft as IMDG regs say that ANY quantity of hazardous must be declared via class placards on all sides of the container / vehicle. Now I have only done 1 load of ADR in nearly 2 years and my memory maybe somewhat forgetful of what I was taught !! So if I have got it wrong that is why. What’s your interpretation of it ? Thanks.
Hi Kerbdog,
There are two LQ package labelling systems in use at the present time.
I’ll deal with the ‘old’ system first:
Old LQ package labelling system
The first two ‘old’ LQ package labels (100mm X 100mm) above each have the applicable (single) UN number to represent the dangerous goods in a package.
In case the consignor wishes to package multiple UN numbered dangerous goods in the same overall package, they can use a package label with several UN numbers on it, or a package label (100mm X 100mm) with just the letters “LQ” on it:
A disadvantage of the ‘old’ labelling system is that it relies on the consignor maintaining adequate stocks of the correct labels for each UN number that they wish to send.
The ‘old’ LQ package labelling system can be used until 30/06/2015.
New LQ package labelling system
From 01/01/2011, a ‘new’ labelling system for dangerous goods packaged in LQs came into force and can be used.
From 30/06/2015, the new package labelling system ALONE will be mandatory.
An advantage of the ‘new’ system is that the labelling of LQ packages is now very much simplified.
The ‘new’ LQ label (100mm X 100mm) does NOT need to show the UN number for the dangerous goods and can be used for any/all dangerous goods authorised to be packaged as LQs:
Marking of vehicles carrying packaged LQs for a road journey:
No matter which of the above package labelling systems is used, there is a requirement to mark vehicles carrying LQs in the following circumstances:
If the vehicle is more than 12t authorised mass AND is carrying more than 8t of dangerous goods packaged as LQs, THEN it must be marked on the front and rear with an orange plate (= 2) of 40mm X 30mm size.
OR marked on the front and rear with an LQ Placard (= 2) of 250mm X 250mm size.
Marking of a container for a road journey:
If a container containing more than 8t of dangerous goods packed in LQs is carried on a vehicle that has an authorised mass of more that 12t, the container must be marked on all four sides with LQ placards (= 4) of 250mm X 250mm size.
For sea transport of LQs under IMDG:
A complete vehicle (rigid or artic) needs an LQ placard (250mm X 250mm) on both sides and the rear (= 3) regardless of the quantity of LQs carried.
An unaccompanied trailer needs an LQ placard (250mm X 250mm) on all four sides (= 4) regardless of the quantity of LQs carried.
A container needs an LQ placard (250mm X 250mm) on all four sides (= 4) regardless of the quantity of LQs carried.
Forget about orange coloured plates here… IMDG doesn’t recognise them, but allows them to remain displayed.
==========================================
Drivers seem to get themselves all confused about marking requirements when they collect/deliver ferry trailers from/to the docks…
The answer to markings questions can best be found by remembering that IMDG DOESN’T apply to the road leg of a journey, so in that case please just ignore the blue writing above.