Dangerous goods advice- UK regs and ADR

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 :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:
> 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 :exclamation: )
> 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. :wink: 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.