ADR advice please

[dieseldave]

oldhippyandy:
Thats grand thank you, as a further question regarding something that may arise, I assume I cannot carry two IBCs if the combined contents exceed 1000 litres, if I have more than one collection , but it is ok if the combined contents is under 1000 litres

Hi oldhippyandy,

ADR doesn’t set a limit to the number of IBCs that you can carry, but you’re correct to say that the combined total of contents cannot exceed 1,000 litres unless you hold an ADR licence and you have the necessary equipment and other documentation.

oldhippyandy:
Also, what then is a tank, and what rules apply if I carry diesel in a container that has wheels,( it would be carried not towed).

The fact that a container has wheels generally makes no difference.
Whether you tow or carry it might make a difference.

Can I guess that you’re talking of something like this?

If my guess is correct, then depending on its construction, it could be either a package or a tank. As an example, the pic above counts as a package, but there are others that look similar that count as a tank.
IF it counts as a tank, then the rules are different.

Could I ask you again please… could you have a look at the thing you’re speaking about and see whether there is an info plate on it and tell me what it says please?
A picture of it would also help me to give you an accurate answer.

Once I know what we’re speaking about, I reckon I can help.

[oldhippyandy]

Cheers for the info, I have no pictures as all this is theoretical at present, I really just wanted to know for future reference. What you’ve said is really useful and if it’s ok I’ll get back to you if I have any more questions.

[dieseldave]

oldhippyandy:
Cheers for the info, I have no pictures as all this is theoretical at present, I really just wanted to know for future reference. What you’ve said is really useful and if it’s ok I’ll get back to you if I have any more questions.

Hi oldhippyandy,

When you get back to me, please include some info from the plate cos I’ll only ask for it if you don’t.

[oldhippyandy]

Can anyone clarify this for me please.I drive a hiab vehicle and although I mainly carry cabins I am also called upon to do other types of work. As non ADR with a non ADR truck my understanding of the law is that I can carry up to 999 litres of diesel in a bunded tank which holds up to 999 litres. If the containers capacity exceeds 999 litres irrespective of the amount of diesel it has inside (i.e. under 999 litres) I am not able to carry it. I went to pick up a bunded tank from a site this week which had a capacity of 3000 litres and I was told was about a quarter full, although I could not verify this as I was unable to see the gauge, I have no reason to disbelieve this was the case. On my understanding of the law I refused to move it, the customer informed me that the FTA had said it was legal for me to do so, but when I contacted the RHA they told me it was not. I therefore would not carry it . Anyone know the correct answer ? Thanks in advance.

[dieseldave]

oldhippyandy:
Can anyone clarify this for me please.I drive a hiab vehicle and although I mainly carry cabins I am also called upon to do other types of work. As non ADR with a non ADR truck my understanding of the law is that I can carry up to 999 litres of diesel in a bunded tank which holds up to 999 litres. If the containers capacity exceeds 999 litres irrespective of the amount of diesel it has inside (i.e. under 999 litres) I am not able to carry it. I went to pick up a bunded tank from a site this week which had a capacity of 3000 litres and I was told was about a quarter full, although I could not verify this as I was unable to see the gauge, I have no reason to disbelieve this was the case. On my understanding of the law I refused to move it, the customer informed me that the FTA had said it was legal for me to do so, but when I contacted the RHA they told me it was not. I therefore would not carry it . Anyone know the correct answer ? Thanks in advance.

Hi oldhippyandy,

I’m afraid to say that you’ve been a little misinformed by people who should know better.

As a non-ADR trained driver you can carry a maximum of 1,000 litres of Diesel in a package without being subject to ADR.
For the carriage of Diesel in package(s), the vehicle does not need any special features to comply with ADR.

I imagine that you’ve been asked to carry something like this 3,000 litre IBC:

People commonly make the mistake of calling this thing a “tank,” then it all goes wrong after that because it ISN’T any kind of tank.

The thing in the picure is a kind of package called an Intermediate Bulk Container (IBC,) the 1,000 litre exemption from ADR relates to packages, NOT tanks. There is NO exemption for tanks, even if they’re empty but uncleaned.

If you look at the thing that you’re being asked to transport, please see whether you can find something like this information plate:

When used in this way, the letters “UN” in the circle mean that it’s a package.
The “31A” means that it’s an IBC (= package) made of steel.
The rest of the code is irrelevant to your question.

If the person asking you to transport it says that there’s 1,000 liters (or less) in it, then ask him for a delivery note (signed by him) that says so. It’s then irrelevant that you can’t see the gauge.

It is the consignor’s (= sender) legal responsibility to comply with the parts of ADR that apply to him (like consigning it correctly,) whilst yours is simply to have 1 X 2kg ADR compliant dry powder fire extinguisher on board when you carry the package, then you’re good to go.

For liquids, ADR uses the phrase “nominal capacity” for the actual amount placed on a vehicle, which in your case is 1,000 litres, but it doesn’t set a limit on the size of the package containing the 1,000 litres for the purpose of load limits.

I hope this helps.

[oldhippyandy]

Thats grand thank you, as a further question regarding something that may arise, I assume I cannot carry two IBCs if the combined contents exceed 1000 litres, if I have more than one collection , but it is ok if the combined contents is under 1000 litres

Also, what then is a tank, and what rules apply if I carry diesel in a container that has wheels,( it would be carried not towed).