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Dangerous goods advice- UK regs and ADR.

PostPosted: Sun May 13, 2007 12:44 am
by dieseldave
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.

PostPosted: Fri Jun 08, 2007 11:33 pm
by 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.

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.

PostPosted: Sun Jun 10, 2007 6:04 pm
by dieseldave
8wheels wrote: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.

We have to talk metric I'm afraid (I don't like it either :wink: )
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. :wink: ]
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. :wink: )

8wheels wrote: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 :wink: (answered above I hope :!: )

8wheels wrote: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. :wink: and I might then need to edit this post.)

8wheels wrote: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 wrote: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.

PostPosted: Sun Jun 10, 2007 9:06 pm
by 8wheels
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

Image

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 escort 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.

PostPosted: Tue Jun 12, 2007 2:26 am
by dieseldave
8wheels wrote: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 wrote: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 wrote: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 wrote: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 wrote: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 wrote:How do I stand if coming back through the Dartford Tunnel with fuel on board? Do I have to join the DG queue for escort 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 :wink: ) Their advice was that you should stop for checking, but you'd probably get a wave through without escort, 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. :shock: We did clarify that 5X200 litre drums don't need an escort, 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.. :shock: . 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. :wink:

8wheels wrote: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. :shock:

PostPosted: Tue Jun 12, 2007 10:59 pm
by 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.

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.

PostPosted: Thu Jun 14, 2007 12:46 am
by dieseldave
8wheels wrote: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. :wink: )

8wheels wrote: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 wrote: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 wrote: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.

PostPosted: Fri Jun 15, 2007 10:07 pm
by 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.

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.

PostPosted: Fri Jun 15, 2007 11:47 pm
by dieseldave
8wheels wrote: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 wrote: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 :shock: 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.

PostPosted: Sat Aug 11, 2007 9:10 am
by JON LAD
Hi , Just an enquiry with reference to carrying Vehicle Batteries Palletised with thick shrinkwrap around the pallets.
The UN Number is UN2794 .
I believe these goods would fall under Transport Cat 3.

Could you confirm the maximum weight of these goods that can be carried per Transport Unit. ( I am an ADR Licence holder and think it is 1000 kg per transport unit ??? )

I collect from a battery stockholder, in groupage i.e 5+ pallets back to hub where pallets are then trans shipped around the UK. I am an ADR licence holder, yet no ADR plates/extinguisher Etc are supplied on the said collecting vehicle.

Your confirmation of the above movements of goods would be appreciated.
With Thanks. Jon

PostPosted: Sat Aug 11, 2007 12:43 pm
by dieseldave
JON LAD wrote:Hi , Just an enquiry with reference to carrying Vehicle Batteries Palletised with thick shrinkwrap around the pallets.
The UN Number is UN2794 .
I believe these goods would fall under Transport Cat 3.

These goods (UN 2794) are most probably totally exempt from ADR.
UN 2794 has a "special provision" called SP598, which if the consignor fulfills, would trigger the exemption. Now the strange bit: I can see how you got to 1,000kgs by thinking that batteries were goods of UN Class 8, PGIII, but in fact UN 2794 doesn't have a packing group assigned. :shock:

JON LAD wrote:Could you confirm the maximum weight of these goods that can be carried per Transport Unit. ( I am an ADR Licence holder and think it is 1000 kg per transport unit ??? )
If SP598 applies, then there is no limit per transport unit on the basis that the goods are ADR exempt.

If yopur groupage load includes other ADR stuff, then the batteries can be ignored when deciding whether the ADR threshold limits are exceeded.

JON LAD wrote:I collect from a battery stockholder, in groupage i.e 5+ pallets back to hub where pallets are then trans shipped around the UK. I am an ADR licence holder, yet no ADR plates/extinguisher Etc are supplied on the said collecting vehicle.
If SP598 applies, there would be no requirement for orange boards, or extinguishers or even an ADR certificated driver.

JON LAD wrote:Your confirmation of the above movements of goods would be appreciated.
With Thanks. Jon


No probs, JON LAD, it's a pleasure.

Please note that it is the consignor, who has to palletise and label-up etc, and the carrier who decides whether the Regs apply, selects a suitable vehicle, and assigns an ADR trained driver, if the regs require it.

If you have any further doubts, I could post SP598, so that you can check whether the consignor is compliant. Please just ask. (It's not very big or complicated.)

From my experience, SP598 is a very common (and perfectly legal) way of transporting UN 2794 by road.
(It would be a very different matter by sea or air though :wink: )

PostPosted: Wed Oct 03, 2007 12:29 pm
by Peter K
dieseldave wrote:
8wheels wrote: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.

Dave

I always understood this to be the case i.e. capacity not contents but I couldn't find that rule recently in the ADR books. You haven't got a reference have you?

Pete.

PostPosted: Thu Oct 04, 2007 2:05 am
by dieseldave
dieseldave wrote:
8wheels wrote: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.


Peter K wrote: Dave

I always understood this to be the case i.e. capacity not contents but I couldn't find that rule recently in the ADR books. You haven't got a reference have you?

Pete.
Hi Pete,
Sorry mate, but I can't quite tell which quote you're asking for, or which "ADR books" you are using.
In any case, your question doesn't relate to any part of a driver's duties, unless the driver also owns the truck, since it's for the "carrier" and the "consignor" to decide whether the Regs apply. BTW, both the "carrier" and the "consignor" must have a properly qualified (by examination) DGSA, unless they're exempt from that requirement.
:oops: It's possible that I haven't correctly understood your question, due to a large number of variables. :oops:

The eventual answer to your question will depend upon whether you're asking about a liquid, a solid or a gas (you'd need to do this by quoting the "proper shipping name") and which type of receptacle/package/tank is to be used. I'm afraid it isn't as straightforward as "nominal capacity" in all cases. That's the reason that you couldn't find the rule that you're looking for. I'm also afraid that the UK doesn't blindly follow ADR at all times, especially on a particularly "British" question, like a "UK journey." In cases when we don't follow ADR, we have a set of Regs called "The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007. (We shorten this to CDG 2007.) Sometimes, we have further exemptions granted by the DfT.

I do apologise if I appear vague, but 8-wheels' question was about a specific substance in a specific type of package being carried in the UK. Not all of my answers to his questions can be found by looking in ADR :wink: If you're using ADR on its own for UK journeys, you're possibly commiting one or more offences.

I'm steering away from quotes at the moment, until I know exactly which books you're using and I'm happy that I've understood your question correctly. Believe me, if I start with quotes and you're not using the full set of current law-books, the quotes won't mean anything to you. :wink:

I hope this helps :? (I have a feeling that this one might go to PMs :wink: )

PostPosted: Thu Oct 04, 2007 9:00 am
by Peter K
Hi Dave,

I'll try and explain what I mean, but of course if you would prefer me to go to PM I will. I'm going on from 8wheels question, if he was to carry UN1202 diesel in say drums with 200 ltr capacity but with only 100 ltrs in each drum, then for the purposes of the load size thresholds would the amount to be used for the calculation be the capacity or the contents? In the past it was definitely the capacity but I can't see that anywhere in the regulations now. I have access to ADR 2007 so if you had a reference I could find it.

Thanks
Pete.

PostPosted: Thu Oct 04, 2007 11:58 pm
by dieseldave
Peter K wrote:Hi Dave,

I'll try and explain what I mean, but of course if you would prefer me to go to PM I will. I'm going on from 8wheels question, if he was to carry UN1202 diesel in say drums with 200 ltr capacity but with only 100 ltrs in each drum, then for the purposes of the load size thresholds would the amount to be used for the calculation be the capacity or the contents? In the past it was definitely the capacity but I can't see that anywhere in the regulations now. I have access to ADR 2007 so if you had a reference I could find it.

Thanks
Pete.
Hi Pete.
Now I understand the question- thanks for the clarification. :wink:

The reference you need is ADR 2007 1.1.3.6.3

If the drum(s) had been normally drained of dangerous goods, (ADR calls this "nominally empty.") there would of course be some residue of dangerous goods remaining inside. In that case, the drum(s) would be in TC4 and could be carried by an untrained driver in any quantity and without orange boards etc... (Please see the entry for TC4 in the table at 1.1.3.6.3 and note that the load threshold for TC4 is "unlimited.")

A 200 litre drum containing 100 litres could not be argued as being "nominally empty," so the load limit for diesel fuel would apply. Diesel fuel is in TC3, so the limit is 1,000 litres. You could therefore load five such drums, before ADR applies in full, since the "nominal capacity" of the drums is 200 litres. This is also in 1.1.3.6.3 just after the table. If you read that reference, you'll see why I mentioned about whether your question related to liquids, solids or gases. :wink: You'll also see that gases are treated differently, dependant upon whether they're liquified. :shock:

To clarify "nominal capacity," a drum is normally around 205 - 210 litres ACTUAL capacity, but the extra 5 or 10 litres of space is required for possible expansion of the liquid contents due to warm weather. (This extra space is called "ullage.") Even if the drum is 210 litres actual size, for ADR's purposes we'd only count 200 litres for the calculation of load thresholds in 1.1.3.6.3.

UN2984 - LQ Exemption?

PostPosted: Fri Oct 05, 2007 7:14 am
by MrFlibble
As I mentioned in my other thread - UN2984, Oxidising Agent, "1.5" in the bottom of the diamond, 25-litre barrels. What (if any) LQ exemptions are there?

TIA...

PostPosted: Fri Oct 05, 2007 9:07 am
by Peter K
Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn't spotted.

Pete.

PostPosted: Fri Oct 05, 2007 3:48 pm
by dieseldave
Peter K wrote:Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn't spotted.

Pete.
Hi Pete, no problem mate.
You do have to be careful when reading ADR :wink:
A complicating factor is that the rules for UK journeys are sometimes slightly different, so not all of ADR always applies in the UK.

Not all of the rules can be found by reading, some are "implied." That's one reason why the DGSA exams are so difficult to pass. It did get me wondering whether your company were using you as a DGSA. The strange thing is that DGSA isn't a job title that a boss can just hand out. It's a very specific qualification, which needs a vocational certificate issued by SQA on behalf of the DfT to prove you have passed the 3 necessary exams.

Re: UN2984 - LQ Exemption?

PostPosted: Fri Oct 05, 2007 6:06 pm
by dieseldave
MrFlibble wrote:As I mentioned in my other thread - UN2984, Oxidising Agent, "1.5" in the bottom of the diamond, 25-litre barrels. What (if any) LQ exemptions are there?

TIA...


Hi Mr Flibble,

This substance is called:
UN 2984 HYDROGEN PEROXIDE, AQUEOUS SOLUTION, 5.1, PGIII.

To take advantage of LQ exemtions, the consignor would have to pack this substance in 1 litre tubs/bottles and place several in a cardboard box. The consignee would also have to be happy to receive his consignment packaged in this way. What works for a retail shopkeeper wouldn't necessarily be acceptable to a person buying the same substance for industrial use. In this case, the cardboard box isn't allowed to weigh more than 30kgs. IF that's complied with, then there's no load limit per vehicle and the rest of ADR doesn't apply. (No orange boards, no ADR licence, no specific docs, you could carry a full load etc etc...)

The boxes would look something like this:
Image

For the substance in your question, the boxes would also need a white label (100x100mm) like this:
Image

-----------------------------------------------------------------------------------------------------------


Since you mentioned 25 litre drums, the question of LQs cannot arise. The maximum LQ size for any substance is 5 litres for liquids and 6kg for solids, but not all of them are allowed to be packed into receptacles of those sizes. For example, the LQ size for UN 2984 is 1 litre as above. There are approx 26 different combinations of inner Vs. outer package sizes for LQs, and the allowed sizes depend upon the particular substance in question. For the substance in your question, the code assigned is: LQ13.

However, there is another way that an untrained (in an ADR sense) driver could legally carry this stuff in packages. This doesn't rely on package sizes though, so the packages could be the 25 litre drums you mentioned for instance. If this were the case then the limit would be 1,000 litres per vehicle. 1,000 litres (or less) per vehicle would require a 2kg dry powder fire extinguisher to be carried on board the vehicle for a UK journey. If it were an international journey, then there would be an additional requirement for a transport document (Please see my reply to 8-wheeels above) In either case, the carriage of UN 2984 in drums requires special vented caps to be fitted to the drums.
This 1,000 litre exemption ISN'T called LQs :wink:

It would also be dangerous to assume that there's a blanket exemption of 1,000 litres for all substances. For some substances, the limit would be 20kg/ltr, for others the limit would be 333kg/ltr. For some others, there's NO exemption whatsoever, and for others, there's NO LIMIT whatsoever. These limits depend on the particular substance involved. If carriage by sea was involved, the goalposts would move still further :shock:

If the load of UN 2984 wasn't packaged in LQs, the packages would need correct labelling (see below.) Then if there were to be more than 1,000 litres going on the vehicle, the driver would need an ADR licence and the rest of ADR would apply, such as orange boards, documentation and PPE etc etc...

I'm guessing that there's a typo at work here MrFlibble, [because class 1.5 is an explosive :shock: ] OR the UN number is wrong. My guess is that the label you saw looked like this:
(With OR without the words "OXIDISING AGENT.")
Image

Does this help??

PostPosted: Sun Oct 07, 2007 11:29 am
by Peter K
dieseldave wrote:
Peter K wrote:Hi Dave,

Your reply was very helpful, thanks very much. It was the note after the table that I hadn't spotted.

Pete.
Hi Pete, no problem mate.
You do have to be careful when reading ADR :wink:
A complicating factor is that the rules for UK journeys are sometimes slightly different, so not all of ADR always applies in the UK.

Not all of the rules can be found by reading, some are "implied." That's one reason why the DGSA exams are so difficult to pass. It did get me wondering whether your company were using you as a DGSA. The strange thing is that DGSA isn't a job title that a boss can just hand out. It's a very specific qualification, which needs a vocational certificate issued by SQA on behalf of the DfT to prove you have passed the 3 necessary exams.


Thanks again Dave, I was having a moment , where I couldn't remember where that note was and didn't have my books with me. I should have remembered given that I've passed my DGSA exams twice, run DGSA courses and act as DGSA to several companies! I also have an ADR centre and would be interested in talking to you about your freelance instruction - are you fully committed? Do you mind if I send you private mail?

Pete.

PostPosted: Sun Oct 07, 2007 1:03 pm
by dieseldave
Peter K wrote: Do you mind if I send you private mail?
Pete.
No Pete, I don't mind at all. In fact I've beaten you to it.
:wink: You have a PM

Re: UN2984 - LQ Exemption?

PostPosted: Sun Oct 14, 2007 1:42 pm
by MrFlibble
dieseldave wrote:Hi Mr Flibble,

This substance is called:
UN 2984 HYDROGEN PEROXIDE, AQUEOUS SOLUTION, 5.1, PGIII.

(snip useful stuff)


Thanks for all of that. It confirmed my suspicion that we should refuse to carry it.

dieseldave wrote:I'm guessing that there's a typo at work here MrFlibble, [because class 1.5 is an explosive :shock: ] OR the UN number is wrong. My guess is that the label you saw looked like this:
(With OR without the words "OXIDISING AGENT.")
Image


Not a typo - faulty memory :wink:

I'm pretty sure that the UN number is correct - H2O2 makes sense, as it's laundry bleach. I remembered the "5.1" incorrectly.

dieseldave wrote:Does this help??


Yes, lots thanks.

PostPosted: Thu Oct 25, 2007 10:04 pm
by GlesgaBill
I have a question-

Were there any changes to the CDG Regs in Jan 07?

A guy in my work says that since then, there are no "limited quantities" and that if you are carrying anything (even items under 333kg etc etc) that they must have full ADR, plates spill kits etc.

Basically he's saying that you're either ADR or not, with no exemptions.

Is he right? :?: :roll:

PostPosted: Fri Oct 26, 2007 12:40 am
by dieseldave
GlesgaBill wrote:I have a question-

Were there any changes to the CDG Regs in Jan 07?

A guy in my work says that since then, there are no "limited quantities" and that if you are carrying anything (even items under 333kg etc etc) that they must have full ADR, plates spill kits etc.

Basically he's saying that you're either ADR or not, with no exemptions.

Is he right? :?: :roll:
Hi GlesgaBill, I'm afraid your guy has got it all wrong.
Ask him for the source of his info, meanwhile I'll guarantee that it isn't CDG 2007. :wink:
CDG 2007 contains 95 Regulations and 9 Schedules, but not a great deal has actually changed for drivers.
Your company is required to inform you of any changes that affect their operations, and your DGSA is supposed to see to it that that happens.
The notion of Limited Quantities (LQs) is described above in my answer to MrFlibble (please read that) and the load limits per vehicle are described above in my answers to 8-wheels, MrFlibble and Jon Lad.

Just to clarify this even further, LQs require no action from the driver -- No orange plates, no spill kit, no ADR licence--- full load?? just load and go--- no question about it. The whole idea of LQs is that for SOME dangerous goods that actually present only a small danger, there is a way to carry them without being affected by the Regs. The best way to think of this idea is that it is a limited quantity per package. If that's complied with, then there's no load limit. If the LQ exemptions apply to the load you're carrying, the boxes will be marked as in the pictures above.

When the "stuff" ISN'T packed in LQs, there are limits of either 0kg/lit, or 20kg/lit, or 333kg/lit or 1,000kg/lit depending on how dangerous the "stuff" is. If you're loaded to below the appropriate limit for the "stuff" that you're carrying, then all you need is an "awarenes" of dangerous goods and a 2Kg dry powder fire extinguisher if it's a UK job. If your load exceeds these freebie limits, then ADR applies in full and everything you described would then be required plus some other requirements depending on which "stuff" you're carrying.

Just to clarify even further, there is NO connection between LQs and the idea of load limits before the Regs apply in full.

If the answer to your question isn't clear from carefully reading the above and looking at the pictures, please find out the UN number and name of the substance, the class and the packing group. The size and type of package(s) would also help. Then I'll be able to give you a good and full answer. Please let me know whether this answers your question??

PostPosted: Fri Oct 26, 2007 7:17 am
by GlesgaBill
Yes Dave....that about sums it up i reckon!

PostPosted: Fri Oct 26, 2007 1:37 pm
by dieseldave
GlesgaBill wrote:Yes Dave....that about sums it up i reckon!
Hi GlesgaBill, all that effort and you write me 9 words :roll: :lol:
Did it seem understandable that ADR doesn't heap loads of Regs on you right from the off, if what you're carrying isn't awfully dangerous??
IMHO, they've got the balance about right, because really dangerous "stuff" is heavily regulated pretty well straight away. Did you put your guy at work right on the principal of how it works??

PostPosted: Fri Oct 26, 2007 10:16 pm
by GlesgaBill
Hi Dave...i answered your thread putting on a shirt, eating boiled egg & toast and halfway out the door this morning....apologies! :D

What you replied in your thread was my understanding & might i add, that of my ADR instructor (i'm halfway through my course just now) so i reckoned the guy was a bit of a blowhard to start with.

I also told a guy who works in our office (with haz packages etc) about what he said his reply was "He's a balloon....he has his own set of rules in his head until we keep him right"

It has learned me not to listen to "the bloke in the yard" and taught me that finding out the info required from the proper channels is always the best & correct course of action-and in this instance, many thanks go to you Dave for providing the proper insight.

Having said all that, can i safely assume the following?-

1. Limited quantities are alive and well

2. The 1000kg, 333 Kg and 20 Kg load limit still apply (ps....does ppe, spill kits etc apply here?)

3. Anything above those limits require full ADR, VTC PPE Etc

Many thanks for sharing your knowledge! :)

GlesgaBill :)

pps....i never saw that blowhard guy today....i think he's probably too hard headed to listen to anything other than his interpretation.....

PostPosted: Sat Oct 27, 2007 12:35 am
by dieseldave
GlesgaBill wrote: Hi Dave...i answered your thread putting on a shirt, eating boiled egg & toast and halfway out the door this morning....apologies! :D
Cheers for that Bill. I thought it was something like that. I'd noticed the time of your post and thought "he's on his way to work." Not a bad guess 8)

GlesgaBill wrote: What you replied in your thread was my understanding & might i add, that of my ADR instructor (i'm halfway through my course just now) so i reckoned the guy was a bit of a blowhard to start with.
I think that proves that the guy in the yard either doesn't have ADR, or he didn't listen. (I can't think of a third option :wink: )

GlesgaBill wrote: I also told a guy who works in our office (with haz packages etc) about what he said his reply was "He's a balloon....he has his own set of rules in his head until we keep him right"
Now you can see why one works in the office and the other works in the yard. :wink:

GlesgaBill wrote: It has learned me not to listen to "the bloke in the yard" and taught me that finding out the info required from the proper channels is always the best & correct course of action-and in this instance, many thanks go to you Dave for providing the proper insight.
Hey, no probs Bill. That's what I do. Are you doing your ADR at Ritchies??

GlesgaBill wrote: Having said all that, can i safely assume the following?-

1. Limited quantities are alive and well
Yes, with a full description and pics above. (Your instructor probably won't have time to go into as much detail as I did above.) Please remember that LQs are nothing to do with the load limits for the transport categories. In fact, if you have a mixed load of LQs and other stuff, you can ignore the LQ stuff altogether, because it just doesn't count towards any load total.

GlesgaBill wrote: 2. The 1000kg, 333 Kg and 20 Kg load limit still apply (ps....does ppe, spill kits etc apply here?)
Yes, but there are five limits in total: 0, 20, 333, 1,000 and unlimited. Those are the five transport categories (TCs.) Once you're carrying more than the limit for the type of goods you're carrying, then ADR applies in full, so those are the limits for: orange boards, ADR licence, Instructions in writing, spill kit, 2 extinguishers, PPE, chock, torch, self-standing warning signs and Hi-viz etc.

All the Regs you heard about on Monday (IATA, IMDG ADR and RID) use Packing Groups (PGs) to express the danger presented by the goods. ADR (only) extends this idea into the 5 TCs I mentioned. That way, the most dangerous goods are fully regulated instantly, then there are bigger limits as the danger decreases. The law is very clear that it is your always your boss' responsibility to tell you when the Regs apply.

GlesgaBill wrote: 3. Anything above those limits require full ADR, VTC PPE Etc
Many thanks for sharing your knowledge! :)

That's it Bill, you've got it. :wink: Nice one mate.

GlesgaBill :)

GlesgaBill wrote: pps....i never saw that blowhard guy today....i think he's probably too hard headed to listen to anything other than his interpretation.....
I've got nothing against the "guy", but I'd suggest you ignore his opinions on ADR. I'm convinced that your own ideas will be nearer reality!! :wink: Let me know how you got on in the exams?? The way it's running, you'll know in about 3-4 weeks.

PostPosted: Mon Oct 29, 2007 11:28 pm
by GlesgaBill
Hi again, Dave :)

I think i've got the gist of this now...but i still have a nagging doubt (even after reading the CDG Document) :D:D:D

OK...here goes-

LQ's = No problem...i understand that...no additional stuff needed.

Load over the "small threshold limit" = Full ADR applies....Tremcard,Boards, Chock...PPE Extinguishers, etc etc etc I understand that.

"Small threshold limit" = This is where i'm unsure. If i have a load or item(s) under the threshold limit, what (if any) other items do i need to carry to stay legal?

Slightly puzzled,

GlesgaBill :)

PostPosted: Tue Oct 30, 2007 12:34 am
by dieseldave
GlesgaBill wrote: Hi again, Dave :)

I think i've got the gist of this now...but i still have a nagging doubt (even after reading the CDG Document) :D:D:D

OK...here goes-

LQ's = No problem...i understand that...no additional stuff needed.
Nothing needed on your part whatsoever.

GlesgaBill wrote: Load over the "small threshold limit" = Full ADR applies....Tremcard,Boards, Chock...PPE Extinguishers, etc etc etc I understand that.
Yes, we have a winner!! :wink:

GlesgaBill wrote: "Small threshold limit" = This is where i'm unsure. If i have a load or item(s) under the threshold limit, what (if any) other items do i need to carry to stay legal?
If you're on a UK journey, all you'd need is 1 X 2Kg dry powder fire extinguisher, with the date of the next examination/inspection marked, and it needs to be fitted with a seal and pin. If any of that is missing, you ass belongs to VOSA and you win a PG9 until it's sorted :wink: (You might also be prosecuted, because you were supposed to check that before you set-off, so the defence below wouldn't be available to you) Then it's like LQs, you don't need anything else.

If you're doing an international journey (that's when UK Regs don't apply) you need the extinguisher as above
+ a "transport document" containing at least:
the UN number, Proper Shipping Name, class and packing group; (Written in that order. :roll: )
the number size and type of packages;
the total Kgs/Lit of the load;
and the name(s) and address(es) of the consignor(s) and consignee(s)
The document doesn't have to be too fancy, but the required info must be on it.

GlesgaBill wrote:Slightly puzzled,

GlesgaBill :)
Be puzzled no longer mate :wink:

Here's two other tips for you:
1. It is always your boss' job to tell you which Regs apply, to what extent, and when.
(= if in doubt at a customer's premises, phone your boss before setting off.)
2. UK law (this one includes Scotland) provides you with a defence if you can show that the offence is somebody else's responsibility, ie, somebody lied to you, but there are several conditions to that.