My boss tells me, its law, I must carry both parts of my driving licence when carrying hazardous goods?
I can’t see why - but there you go.
thedeerhunter270:
My boss tells me, its law, I must carry both parts of my driving licence when carrying hazardous goods?I can’t see why - but there you go.
Hi the deerhunter270, the regulations for carrying dangerous goods come in several ‘layers,’ depending on the method of packaging and/or the total amount carried.
If you’re carrying Limited Quantities, Excepted Quantities, or a load that’s below the relevant ADR transport category threshold for the goods, then you’ll not need an ADR certificate.
If the load you’re carrying is in excess of the relevant ADR threshold for the transport category of the goods, you need the extinguishers, orange boards, documentation, ADR licence etc.
What I think your boss might mean is that when you’re carrying a load that’s in excess of the ADR threshold, you need a form of photographic ID ALSO. BTW, this has been the case since 2005 in the UK. I imagine that your boss thinks it’s easier for him to require you to carry your photocard driving licence in order to meet that requirement.
To answer your original question as you wrote it, there’s no requirement as such to carry both parts of your driving licence when carrying dangerous goods. 
Cheers for that Dave. I’ve only just started doing ADR work, which is why some of this is a bit new to me.
The transport category for the goods I carry is 0, so I’m going to be under ADR all the time when loaded.
I understand having to carry my ADR licence, but I couldn’t see why I’d need both parts of my driving licence. But I wasn’t sure, so I didn’t argue with him. It’s just a pain to carry the paper bit if I don’t need to. I always carry the photocard part of my licence, but not the paper counterpart. (until now that is)
Yep, I use the orange board back and rear - which when I’m empty I fold away. In the cab I have a Tremcard, or the Instructions in Writing that they use now.
I take a spill kit and fire extinguisher; basically they are always in the cabs of all the vehicles. He also told me I have to check the seal of the spill kit bag every trip, just in case it’s been tampered with? I guess that is usual procedure?
The daft thing about the photocard style driving licence is that in order for it to be a valid form of ID for the authorities you always need both parts to be present, so there’s little value really in carrying just the photocard around as if the police or VOSA stop you it’s of no use to them unless you also have the counterpart. It kind of makes the whole thing pointless IMO, why not just have all the information on a paper licence like we used to if you’re going to have to carry it anyway?
Also, another reason not to carry your photo card round in your wallet is that as it has your DOB, photograph and address on it, anyone who manages to get hold of you wallet (should it be lost or stolen) has a really good instant identity theft kit. For that reason alone I would recommend against it.
Personally I carry both parts of mine in a plastic wallet thing in my work bag. That way I have it if it is needed but it’s not in my wallet where combined with my bank cards etc. it could easily be used to do me out of money if it were lost.
Paul
In this techno age, I cannot see why we have to have a bit of paper.
Put all the info into the strip on the rear and secure it with a pin number as we have for other cards.
Computers could then have hardware readers for that info but only if pin number put in by card holder.
Second different pin number held by DVLA and both pins needed to change info.
I’m not a techno wizz but there must be a way…
From 2013 all EU countries are to start issuing only the photocard licence, which will include a chip to keep ‘other’ information on (endorsements I guess).
However they will be phased in over a period. The completion date for all licences will be 2030 - something to do with the older Germans not wanting to give up their original licences - and probably cost!
Smart Mart:
From 2013 all EU countries are to start issuing only the photocard licence, which will include a chip to keep ‘other’ information on (endorsements I guess).
That sounds like a good idea, as long as there’s some way for hauliers to read the endorsment information off the licence. I suppose as ROG suggested some kind of reader (perhaps the same one as for the digi cards) and PIN so when you go to your employer and tell them you have no points they can stick the card into their machine and check you’re not telling porkies.
Paul
Smart Mart:
From 2013 all EU countries are to start issuing only the photocard licence, which will include a chip to keep ‘other’ information on (endorsements I guess).
repton:
That sounds like a good idea, as long as there’s some way for hauliers to read the endorsment information off the licence. I suppose as ROG suggested some kind of reader (perhaps the same one as for the digi cards) and PIN so when you go to your employer and tell them you have no points they can stick the card into their machine and check you’re not telling porkies.Paul
All that info that is on the front of the present photocard driving licence could also be moved to the security strip which would then go some way to address the issue of identity fraud.
thedeerhunter270:
Cheers for that Dave. I’ve only just started doing ADR work, which is why some of this is a bit new to me.
Hi thedeerhunter270, No probs mate, cos giving ADR advice is what I do.
thedeerhunter270:
The transport category for the goods I carry is 0, so I’m going to be under ADR all the time when loaded.
Blimey, Cat 0 is the most dangerous of dangerous goods.
For a guy who’s new to ADR, you certainly don’t hang about.
You’re spot-on about being fully ADR regulated when carrying any amount of the ‘stuff’ you carry, even if the cargo is the size of a single grain of sand. The Regs for Cat 0 are very strict indeed, and for obvious reasons, but did you know that even empty packages having contained substances in Cat 0 are still fully regulated if carried on a return journey for re-filling??
Empty packages having contained ‘stuff’ in other transport categories drop into TC4, where there’s no threshold limit, but any empties having contained Cat 0 ‘stuff’ don’t.
thedeerhunter270:
I take a spill kit and fire extinguisher; basically they are always in the cabs of all the vehicles. He also told me I have to check the seal of the spill kit bag every trip, just in case it’s been tampered with? I guess that is usual procedure?
There’s no legal requirement for a seal on a spill-kit, but your boss can make that a company policy if he wishes. I can’t see any benefit to the firm in that TBH, but it’s his money he’s spending…
Any seal used should be of a type that can be easily removed without the need for any kind of tool, since the equipment in the bag wouldn’t then comply with the requirement that it’s readily accessible. Your boss would also have to accept the fact that VOSA/Police have the right to inspect the equipment on board your vehicle if you’re stop-checked. In that circumstance, I doubt that they’d accept the seal as evidence that the bag has the correct contents.
It’s probably not as bad as that packing group makes it look. Basically I’m transporting used operation theatre equipment for sterilisation. It comes under 6.2 infectious substances I think.
I have no idea what is in the stainless steel trolleys I pick up, apart from the contents having been used in a very recent operation (and they’re bloody heavy). One drop of liquid off that dirty equipment on my skin and I could be infected with any sort of nasty.
Nope, I didn’t know that about Cat 0 empties on the return — due to the nature of the job I do, the clean equipment is so sterilised, they class it as non hazardous.
thedeerhunter270:
It’s probably not as bad as that packing group makes it look. Basically I’m transporting used operation theatre equipment for sterilisation. It comes under 6.2 infectious substances I think.
It looks like you’ve got your packing groups mixed up with your transport categories mate.
Now you’ve said what it actually is that you’re carrying, my guess is that it’s:
UN 3291 which is in TC 2 with a 333kg threshold limit.
If the UN number is either 2814 or 2900, then it’s TC 0. 
thedeerhunter270:
I have no idea what is in the stainless steel trolleys I pick up, apart from the contents having been used in a very recent operation (and they’re bloody heavy). One drop of liquid off that dirty equipment on my skin and I could be infected with any sort of nasty.
I’m guessing that the UN number is 3291.
If I’m correct, you don’t have much to fear.
If you remember your ADR lesson on class 6, you might remember that class 6.2 doesn’t have packing groups, but instead has Cat “A” and Cat “B.”
Class 6.2 Cat “A” are the real nasties, which are moved under tightly controlled conditions.
Class 6.2 Cat “B” is ‘routine stuff’ like normal surgical instruments going to/from sterilisation or normal clinical waste.
Now for 
I think you might be moving these ‘Large Packagings:’ (These don’t count as IBCs.)
How am I doing so far?
Let’s just check to see whether they’re UN approved packages:
OK so far, so let’s see what they put inside:
These need to be UN approved too, so let’s check:
The Large Package counts as your ‘outer’ and the blue boxes count as your ‘inner,’ so now the packaging requirements for combination packages are met. The last piece of the puzzle is the trays that hold the surgical instruments:
These are normally carried in blue boxes, which in turn are carried inside the steel ‘Large Packaging.’
thedeerhunter270:
Nope, I didn’t know that about Cat 0 empties on the return — due to the nature of the job I do, the clean equipment is so sterilised, they class it as non hazardous.
That’s spot-on mate, but I still reckon you might not carrying TC 0 stuff.
It’s all decided by the UN number mate, so if your UN number is UN 3291, please don’t have nightmares, cos it isn’t TC 0 and you’ve probably already had all the jabs you need.
Am I correct with the UN number and my guess as to the appearance of the steel trolley??
Dave,
That was a fantastic post, thank you. Just reading through it now. You have the UN number right, and the pictures of the steel trolleys are spot on.
Yeah I did get my packing groups and transport categories mixed up. By the time we’d done the entire core subject in my ADR, by section 6 I’d drifted off a little, so it is nice to go through some of this again. My excuse, as I feel I need to — I’m studying part-time at college in Mechanical Engineering, so add an ADR course and there is only so much a brain can absorb.
I was sure someone said we’d be carrying TC0, but I must admit your post does seriously make that seem incorrect. Maybe someone at work has got it wrong, it wouldn’t surprise me. Still, something to check once I get to work later today.
I got my ADR training book out and now I see 2814 or 2900. So under UN3291, with a TC2, am I right in thinking I can carry 333kg without needing ADR? At work, they are giving the trolleys a nominal weight of 70kg for the transport paperwork, does that seem ok?
Yes, had a couple of hepatitis B jabs.
I checked at work this evening - Dave, you were correct.
UN3291 PGII
I tell you something Dave. When I did my multiple ADR over the years, they used to frighten us with tales of Phenol and Oleum to keep our attention 
These 6.2 infectious substances are like chemical warfare
Wheel Nut:
I tell you something Dave. When I did my multiple ADR over the years, they used to frighten us with tales of Phenol and Oleum to keep our attention
That’s true Malc, I’ve heard some of the tales.
One of the courses (consortium) has a rather graphic picture of the oleum victim, and the phenol tale is the stuff of legends.
Wheel Nut:
These 6.2 infectious substances are like chemical warfare
Things have changed in the way that 6.2s are classified.
You’ll probably remember that there were four ‘risk groups’ (RGs,) but although that idea was OK, it was rather unwieldy and rather confusing for my poor victims… err, I mean students.
Nowadays, 6.2s are simply known as Cat “A” and Cat “B.” (ADR 2.2.62.1)
Category A: An infectious substance which is carried in a form that, when exposure to it occurs, is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals.
UN 2814 INFECTIOUS SUBSTANCE, AFFECTING HUMANS and
UN 2900 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only
Category B: An infectious substance which does not meet the criteria for inclusion in Category A. Infectious substances in Category B shall be assigned to UN No. 3373.
UN 3291 CLINICAL WASTE, UNSPECIFIED, N.O.S. or
UN 3291 (BIO) MEDICAL WASTE, N.O.S. or
UN 3291 REGULATED MEDICAL WASTE, N.O.S.
and UN 3373 BIOLOGICAL SUBSTANCE, CATEGORY B
So, Class 6.2 only has four possible UN numbers.
So what happens if we eat the animal that was infected by UN 2900?
Wheel Nut:
So what happens if we eat the animal that was infected by UN 2900?
I’d guess that it wouldn’t taste very nice.