Maybe one here again for Diesel Dave but…anyone know the maximum percentage of sulphamic acid in trigger spray bottles (750ml) constitutes domestic/non ADR classification? The previous load we pulled out of Calais was only 5% but just been emailed next weeks work and theres another load with our names on it apparently for industrial use at 20%. Does this also count as non ADR/LQ?
EDIT- in total 40,000 bottles- rust remover.
AndrewG:
Maybe one here again for Diesel Dave but…anyone know the maximum percentage of sulphamic acid in trigger spray bottles (750ml) constitutes domestic/non ADR classification? The previous load we pulled out of Calais was only 5% but just been emailed next weeks work and theres another load with our names on it apparently for industrial use at 20%. Does this also count as non ADR/LQ?
EDIT- in total 40,000 bottles- rust remover.
Hi AndrewG,
I think somebody (not sure who, but it doesn’t matter) is trying to interpret something without knowing where the goalposts are.
I wouldn’t be thinking in terms of % allowance just yet, but I do need the exact:
- UN Number
- Proper Shipping Name (PSN)
- Class
- Packing Group
The inner packaging size (750ml) is also important when considering whether we can say that the job is an LQ job, but you’ve given that piece of info already.
Note:
A phrase like ‘rust remover’ or ‘descaler’ or even ‘drain cleaner’ are NOT a correct PSN.
Sometimes, the % concentration might make a difference when considering some substances, but it’s like trying to catch fog in a net until I have the correct info to the four bullet points above from the consignor.
Thanks yet again Dave, further info sent by pm… 
AndrewG:
Thanks yet again Dave, further info sent by pm…
Ahh!!, thanks for that Andrew… now it’s easy. 
We now know it is:
UN 2967 SULPHAMIC ACID, 8, PGIII
From this, we now know it’s an LQ job, so the details are the same as I gave you last time.
In this case, the % makes no difference, but fair play for mentioning it. 
Your PM will need to be replied to, so please keep an eye on your inbox…
Huge thanks again Dave for that. As you know my co. are known for being evasive with info and are expert at relocating goalposts as and when it suits but actually looks like this time at least were not really at fault, more likely the shippers instead.
Cheers- Andrew
AndrewG:
Huge thanks again Dave for that. As you know my co. are known for being evasive with info and are expert at relocating goalposts as and when it suits but actually looks like this time at least were not really at fault, more likely the shippers instead.
Cheers- Andrew
Yes indeed Andrew, and I’d go as far as to say that it’s fairly clear that it’s the ‘error’ lies with the shipper.
dieseldave:
AndrewG:
Yes indeed Andrew, and I’d go as far as to say that it’s fairly clear that it’s the ‘error’ lies with the shipper.
As mentioned Dave we will now try to book onto an ADR ‘awareness’ course to cover ourselves. Thought i’d post this on the thread as it may also help other drivers carrying LQ hazardous chemicals without having to do full ADR…
AndrewG:
dieseldave:
AndrewG:
Yes indeed Andrew, and I’d go as far as to say that it’s fairly clear that it’s the ‘error’ lies with the shipper.As mentioned Dave we will now try to book onto an ADR ‘awareness’ course to cover ourselves. Thought i’d post this on the thread as it may also help other drivers carrying LQ hazardous chemicals without having to do full ADR…
That’s a very fair point Andrew.
We’ve got the LQ side of things all boxed off now, and so just to make it clear…
A driver who carries LQs falls into this requirement:
ADR 8.2.3
Persons whose duties concern the carriage of dangerous goods by road shall have received training in the requirements governing the carriage of such goods appropriate to their responsibilities and duties according to Chapter 1.3. This requirement shall apply to individuals such as personnel who are employed by the road vehicle operator or the consignor, personnel who load or unload dangerous goods, personnel in freight forwarding or shipping agencies and drivers of vehicles other than drivers holding a certificate in accordance with 8.2.1, involved in the carriage of dangerous goods by road.
Notes to hopefully aid understanding:
“such goods” in this case means LQs.
“Chapter 1.3” is where the content of the training is specified in detail and includes this at ADR 1.3.3
Records of training received according to this Chapter shall be kept by the employer and made available to the employee or competent authority, upon request.
“competent authority” (in the UK) means the DfT, or anybody appointed by them such as DVSA/Police/HSE etc.
“… drivers holding a certificate in accordance with 8.2.1” means drivers who hold a valid ADR card after successfully completing an approved ADR course. (8.2.1 is where that is all specified in detail.)
In Spain, the main competent authority is:
Dangerous Goods Commission
Ministerio de Fomento
Paseo de la Castellana, 67
E - 28 071 MADRID
Dave’s ADR trivia:
The list of documents required to be carried on board the vehicle (at ADR 8.1.2) does NOT include the record that the training mentioned in ADR 1.3 took place.
All interesting stuff. Thanks all.
Putting two things together:
dieseldave:
Records of training received according to this Chapter shall be kept by the employer and made available to the employee or competent authority, upon request.
And
dieseldave:
The list of documents required to be carried on board the vehicle (at ADR 8.1.2) does NOT include the record that the training mentioned in ADR 1.3 took place.
If a vehicle carrying LQs is stopped for a control, at say midnight, and the authorities request sight of the records of ADR 1.3, then although no offence has occurred, the vehicle could be held until such time as the office opens? It would be prudent to carry a copy of this doc you`d agree? Or have I got that wrong?
Franglais:
All interesting stuff. Thanks all.Putting two things together:
dieseldave:
Records of training received according to this Chapter shall be kept by the employer and made available to the employee or competent authority, upon request.And
dieseldave:
The list of documents required to be carried on board the vehicle (at ADR 8.1.2) does NOT include the record that the training mentioned in ADR 1.3 took place.If a vehicle carrying LQs is stopped for a control, at say midnight, and the authorities request sight of the records of ADR 1.3, then although no offence has occurred, the vehicle could be held until such time as the office opens? It would be prudent to carry a copy of this doc you`d agree? Or have I got that wrong?
Hi Franglais,
The first quote contains requirements on the employer. I’d imagine that “kept by the employer” means kept at their office since there is no standardised requirement for how it’s set out etc, so might not be capable of being read in a foreign country. If a control does take place and the stopping officer has any doubts (as he may do) then I imagine it would be flagged up to the competent authority of the country concerned.
Contrast this with a ‘proper’ ADR card, which is in a form that’s standardised across 50 countries and is required to be carried when a load is fully subject to ADR.
The second quote is my own comment and I suggest to be read ‘as is,’ for the reason that the record cannot be asked for at the roadside since it is not on the listed documentary requirements in ADR 8.1.2 regardless of what language the ADR books are written in.
As for it being prudent to carry it, maybe it is, but I’d say that the written law clearly leaves it up to company policy.
dieseldave:
Franglais:
All interesting stuff. Thanks all.Putting two things together:
dieseldave:
Records of training received according to this Chapter shall be kept by the employer and made available to the employee or competent authority, upon request.And
dieseldave:
The list of documents required to be carried on board the vehicle (at ADR 8.1.2) does NOT include the record that the training mentioned in ADR 1.3 took place.If a vehicle carrying LQs is stopped for a control, at say midnight, and the authorities request sight of the records of ADR 1.3, then although no offence has occurred, the vehicle could be held until such time as the office opens? It would be prudent to carry a copy of this doc you`d agree? Or have I got that wrong?
Hi Franglais,
The first quote contains requirements on the employer. I’d imagine that “kept by the employer” means kept at their office since there is no standardised requirement for how it’s set out etc, so might not be capable of being read in a foreign country. If a control does take place and the stopping officer has any doubts (as he may do) then I imagine it would be flagged up to the competent authority of the country concerned.
Contrast this with a ‘proper’ ADR card, which is in a form that’s standardised across 50 countries and is required to be carried when a load is fully subject to ADR.
The second quote is my own comment and I suggest to be read ‘as is,’ for the reason that the record cannot be asked for at the roadside since it is not on the listed documentary requirements in ADR 8.1.2 regardless of what language the ADR books are written in.
As for it being prudent to carry it, maybe it is, but I’d say that the written law clearly leaves it up to company policy.
Very clear. Thanks.