Dangerous goods advice- UK regs and ADR

8wheels:
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:
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:
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:
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:
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:
How do I stand if coming back through the Dartford Tunnel with fuel on board? Do I have to join the DG queue for ■■■■■■ 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 ■■■■■■, 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. :open_mouth: We did clarify that 5X200 litre drums don’t need an ■■■■■■, and that 1X1,000 litre IBC does. We also found out that they don’t charge for escorting, so I learned something as well! :slight_smile:

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… :open_mouth: . 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:
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. :open_mouth: