Vac Tanker ADR

[lusk]

A tanker only has class placards down the sides and not the Kemler panels on the sides. Under UK regs, is this allowed?

[Henry024]

Hello. Are you available to chat

[lusk]

Yes what you thinking?

[Henry024]

Check your inbox

[lusk]

I cannot see anything?

[dieseldave]

Hi Lusk,

Sorry, I’ve only just seen your post.

I’m afraid that there isn’t enough info for me to give you a good answer, but from what you’ve said…

A tanker carrying dangeous goods must have UN Class placards on both sides and the rear.

You mentioned “Kemler” plates, but the use of those depends on whether the tanker is on an international journey.

For now, I’m guessing that we’re talking about a UK journey carrying a single dangerous substance, in which case we use the UK’s ‘big boards’ which consist of five sections each containing certain information. This type of board contains the UN Class placard in one of the sections and is displayed on both sides and the rear.

There is provision in UK law [CDG 2009 (as amended) Reg.6 and Schedule 1] which mandates the above. The same law also allows the ‘big board’ to be split up a bit, but the overriding rule is that all of the required markings must be displayed on both sides and the rear. This applies to a UK registered tanker on a UK journey.

If it’s an international journey carrying a single dangerous substance, the marking requirements in ADR changes the above to:
Placards on both sides and the rear the same as we do. (ADR 5.3.1.)
Orange ‘Kemler’ numbered plates (40cm X 30cm) to be displayed on the front and rear. (ADR 5.3.2.)

[lusk]

Thanks a lot for this Dave.

It all makes complete sense, and just to clarify, the vehicle would only ever be used on UK journeys.

At present on the sides of the vehicle, there a class specific placard holders spaced about a metre apart and no provision has been made for the Kemler (or as you put it big boards).

Can you just confirm (I think you have) that this is not permitted under UK regs?

[dieseldave]

@lusk

Thanks a lot for this Dave.

It all makes complete sense, and just to clarify, the vehicle would only ever be used on UK journeys.

At present on the sides of the vehicle, there a class specific placard holders spaced about a metre apart and no provision has been made for the Kemler (or as you put it big boards).

Can you just confirm (I think you have) that this is not permitted under UK regs?

Hi lusk,

Thanks for the clarification, it was most helpful.

With you saying that we are talking about a vac tank, is my guess correct that it’s a waste carrying tanker please?

If I’m correct and as with most tankers, there will most probably be holders (frames) to accomodate the required boards/placards already attached to the tanker.

The next thing to consider is that the tanker might not always be carrying waste that counts as “dangerous goods,” in which case… NO signage is required and the driver doesn’t need an ADR licence.

IF the tanker is carrying dangerous goods, including waste dangerous goods, then both ADR and the UK Waste Carriage Regs must be obeyed at the same time. Fortunately, the two sets of Regs do not clash, so compliance is quite easy.

Just to clarify the ADR/UK Regs question…

ADR is an international agreement covering international transport, which is defined as transport that crosses international frontiers.
.
UK law (known for short as CDG) requires full adherance to ADR including for UK journeys, except for tanker marking and signage (and a few other unrelated things) as I described in my last post.

I do have a small concern about this…
Your company is legally required (UK and ADR) to appoint a properly qualified Dangerous Goods Safety Advisor (DGSA) if they’re running a tanker(s?) that carries dangerous goods, rather than you needing to find out answers on a forum, not that I mind though.

DGSA options:

• Your boss can take the qualification him/herself
• Your boss can send one of his/her employees to take the qualification, OR
• Your boss can make use of a properly qualified external consultant, which from my experience (20+ years) most companies take this option.

There is NO equivalent qualification, and it doesn’t come under any other general H&S qualification that somebody may have because it’s a completely separate qualification and certificate. A person is either qualified and certificated as a DGSA, or they are not.

The good thing about this is that it is your boss’ responsibility to deal with the DGSA requirement, for which an employed driver bears ZERO responsibility.

[lusk]

Hi Dave,

Thanks a lot for this.

Regarding your first question, it is a tanker which is ADR approved.

There are placard holders down the side of the tanker which are only capable of holding the one class placard - there is no option to display the UN Number, EAC nor the emergency telephone number.

The tanker has come from a supplier as ready to go to work, and from what you have said, it is not because it does not comply with UK regs.

[dieseldave]

@lusk

Hi Dave,

Thanks a lot for this.

Regarding your first question, it is a tanker which is ADR approved.

There are placard holders down the side of the tanker which are only capable of holding the one class placard - there is no option to display the UN Number, EAC nor the emergency telephone number.

The tanker has come from a supplier as ready to go to work, and from what you have said, it is not because it does not comply with UK regs.

Hi Lusk,

From your description, the only thing I can say for sure is that the tanker does not comply with UK marking rules. (Quoted in my earlier post)

Your boss should be aware (or made aware) that he needs a DGSA.

Just a reminder for you… if you are an employed driver, you bear ZERO responsibility if the company doesn’t have a DGSA or if it chooses to operate an incorrectly marked tanker on the road.

If you are the boss… carry on keeping your head down and I hope both matters keep fine for you.