ADR - Environmental Label

Hi All, just looking for a bit of advice. I did my ADR course awhile back. The instructor told us that a new environmental hazard label has to be used from January 2011. I have seen a lot of tankers and tank containers already with the markings being used. Our company moves fuels (petrol, diesel, heating oil etc) under the regulations. No one seems to know if we will have to display the new label as well as the other markings from January. Can anyone advise? Also is there list anywhere of which products will require this environmental label. Milk is an environmental hazard if spilt into water, will this require the label as well.

Many thanks for taking the time to read this first post.

. :smiley: :smiley: :smiley: Welcome tommook2001 :smiley: :smiley: :smiley: .
Enviromental FISH LABEL for ADR

the info in the above link came from our resident ADR person…

tommook2001:
Hi All, just looking for a bit of advice. I did my ADR course awhile back. The instructor told us that a new environmental hazard label has to be used from January 2011. I have seen a lot of tankers and tank containers already with the markings being used. Our company moves fuels (petrol, diesel, heating oil etc) under the regulations. No one seems to know if we will have to display the new label as well as the other markings from January. Can anyone advise? Also is there list anywhere of which products will require this environmental label. Milk is an environmental hazard if spilt into water, will this require the label as well.

Many thanks for taking the time to read this first post.

Hi tommook2001,

Your ADR instructor is correct in what he told you.

Full compliance with the ‘fish and tree’ rules (including labels and placards) isn’t mandatory until the end of this year, but the ‘fish and tree’ sign may be used before then, such as on the tankers and tank containers that you saw.

Your question is well outside the scope of a driver’s responsibility, because it is a responsibility of the consignor of the dangerous goods to classify the dangerous goods in question. To do that, the consignor must have the ‘stuff’ tested in a lab to see whether the ‘stuff’ meets ADR’s definition of a pollutant. I imagine that your company’s DGSA might contact the fuel company and ask them the question.

Fish and Tree label/placard

I don’t think you have much to worry about - we have been given this placard for ages so it’s well in the system already - as posted its the sender thats supposed to give you the placards
However for groupage loads its a grey area and we have some real fights getting customers to even fill in a DGN and supply the placards because they recon the last person loading the trailer should do all that - a point that needs sorting by the powers that be ASAP
mind you if you refuse to take it without the right information they soon get it for you lol
cheers
Steve

gm:
I don’t think you have much to worry about - we have been given this placard for ages so it’s well in the system already - as posted its the sender thats supposed to give you the placards

Hi gm,
That’s true mate, the ‘fish and tree’ label/placard came out (for ADR) on 01/01/09, with full compliance required by 01/01/11

gm:
However for groupage loads its a grey area and we have some real fights getting customers to even fill in a DGN and supply the placards because they recon the last person loading the trailer should do all that - a point that needs sorting by the powers that be ASAP
mind you if you refuse to take it without the right information they soon get it for you lol
cheers
Steve

There is no grey area mate, but there are some conning folks around. (Some firms choose to ignore a perfectly clear requirement.)

ADR deals with this as follows:

Definition of Consignor:

ADR 1.2.1
“Consignor” means the enterprise which consigns dangerous goods either on its own behalf
or for a third party. If the transport operation is carried out under a contract for carriage,
consignor means the consignor according to the contract for carriage;

I don’t see a grey area. :smiley:

So now we know just who the consignor is, let’s see what their responsibilities are:

ADR 1.4.2.1 Consignor
1.4.2.1.1 The consignor of dangerous goods is required to hand over for carriage only consignments
which conform to the requirements of ADR. In the context of 1.4.1, [1.4.1 is general safety measures] he shall in particular:
(a) Ascertain that the dangerous goods are classified and authorized for carriage in
accordance with ADR;
(b) Furnish the carrier with information and data and, if necessary, the required transport
documents and accompanying documents (authorizations, approvals, notifications,
certificates, etc.), taking into account in particular the requirements of Chapter 5.4 and
of the tables in Part 3; []

Just to help them out a bit:
Chapter 5.4 of ADR is all about documentation. (ADR Transport documents and multi-modal DGNs etc etc.)
The tables in Part 3 of ADR make it perfectly clear how carriage is to be performed, including whether any Special Provisions (SPs) or other conditions, derogations, relaxations etc etc apply.

I can see why the OP asked the question.
If you look at (b) just above, you’ll see that the consignor must tell the carrier (the owner of the vehicle) certain information.
Without going into lots of quotes, there is also some responsibility on the carrier in this regard.

As for placards, the OP wrote about tankers. I’m guessing from your post (groupage) that you’re talking about packages.
Leaving out UN Classes 1 & 7… the only time that placards are need by road is when a container is conveyed by a road vehicle.
Otherwise than that, placards are required under IMDG when any dangerous goods are conveyed in a road vehicle that is itself a piece of freight on a ferry/ship. In the case of groupage (packages in a road vehicle going on a ferry) there is no requirement for placards to be displayed on the vehicle until the vehicle is to be loaded on a ferry.

Hi yes all my work is road work but its does end up on the ferry every time - i put the placards on before i leave so i don’t forget - lol
I have heard that the limited qty placard is coming into force for road transport soon as well

The grey area is the DGN - it states about the last person loading the goods should sign - and this is where the problem is =-
some of the stuff we carry doesn’t come under ADR but it is under IMDG - i tell you it gets confusing sometimes working out what it is you need -
VOSA have no idea at all about IMDG - and when you get stopped for a check and you have the eviro placards on and no ORANGE PLATE - they get right arsy about it

thanks for the heads up
cheers
Steve

gm:
Hi yes all my work is road work but its does end up on the ferry every time - i put the placards on before i leave so i don’t forget - lol
I have heard that the limited qty placard is coming into force for road transport soon as well

Hi gm,
It is true that the Limited Quantity mark for packages will change soon (01/01/11) for ADR and that some vehicles will need to be marked when carrying dangerous goods in LQs.

New LQ mark:

The new LQ mark will be a label of 100mm X 100mm which will be placed on packages like any other label.
The new LQ placard 250mm X 250mm will be required to be displayed one on the front and one on the rear on some vehicles when carrying dangerous goods packed in LQs.

The vehicles which will be affected are:
A vehicle or container of more than 12t GVW, but this would only apply when more that 8t of LQs are carried by such a vehicle/container.
When this vehicle marking requirement applies, an alternative is the use of normal ADR orange plates. (400mm X 300 mm one on the front and one on the rear.)

gm:
The grey area is the DGN - it states about the last person loading the goods should sign - and this is where the problem is =-
some of the stuff we carry doesn’t come under ADR but it is under IMDG - i tell you it gets confusing sometimes working out what it is you need -

IMDG deals with this in the following way:

Definitions of consignor and consignment:

IMDG 1.2.1
consignor means any person, organisation or Government which prepares a consignment for transport.
consignment means any package or packages, or load of dangerous goods, presented by a consignor for transport.

As you can see, there is no grey area up to now. IMHO, IMDG is pretty clear about this. :smiley:

Now lets see what the key responsibilities of the consignor are with regard to documentation, especially DGNs…

IMDG 5.4.1.1
Except as otherwise provided, the consignor who offers dangerous goods for transport shall describe the dangerous goods on a transport document and provide additional information and documentation as specified in this Code*.
[*Code = The International Maritime Dangerous Goods Code. (Shortened to IMDG)]

Then we get to the interesting part…

IMDG 5.4.1.6
The dangerous goods transport document shall include a certification or declaration that the consignment is acceptable for transport and that the goods are properly packaged, marked and labelled, and in proper condition for transport in accordance with the applicable regulations. The text for this certification is:

“I hereby declare that the contents of this consignment are fully and accurately described above by the Proper Shipping Name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable international and national government regulations.”

From the above, it seems pretty clear to me that each consignor (in the case of multiple consignors) has to get their part correct.
IMHO, I still can’t see any grey areas. :wink:

gm:
VOSA have no idea at all about IMDG - and when you get stopped for a check and you have the eviro placards on and no ORANGE PLATE - they get right arsy about it

thanks for the heads up
cheers
Steve

This is why I always mention to drivers that there’s really no need for them to worry about full compliance, because as you can see above, there is no overlap of responsibility between a consignor and a driver. :grimacing:
The way that dangerous goods law is written leaves no doubt about responsibilities. VOSA are responsible for some areas of dangerous goods compliance, but IMHO and with all due respect to them, VOSA as an organisation really should have identifed a training requirement for their officers a long time ago and got it sorted, but that’s up to them and their political masters. :wink:
Legislation exists for the enforcement bodies to pursue consignors, and I really wish they’d avail themselves of it more often. :unamused:

An example of a multi-modal DGN:

My last tip is that a driver should NEVER, EVER sign the declaration, because if something goes wrong, the person signing the declaration becomes responsible. :open_mouth:

Hi,
Thanks everyone for your timely and helpful responses. I think the company have asked our DGSA but as yet havent recieved an answer regarding the label but reading through your posts looks to me that we will have to display it.

Again many thanks to you all

dieseldave:

gm:
I don’t think you have much to worry about - we have been given this placard for ages so it’s well in the system already - as posted its the sender thats supposed to give you the placards

Hi gm,
That’s true mate, the ‘fish and tree’ label/placard came out (for ADR) on 01/01/09, with full compliance required by 01/01/11

gm:
However for groupage loads its a grey area and we have some real fights getting customers to even fill in a DGN and supply the placards because they recon the last person loading the trailer should do all that - a point that needs sorting by the powers that be ASAP
mind you if you refuse to take it without the right information they soon get it for you lol
cheers
Steve

There is no grey area mate, but there are some conning folks around. (Some firms choose to ignore a perfectly clear requirement.)

ADR deals with this as follows:

Definition of Consignor:

ADR 1.2.1
“Consignor” means the enterprise which consigns dangerous goods either on its own behalf
or for a third party. If the transport operation is carried out under a contract for carriage,
consignor means the consignor according to the contract for carriage;

I don’t see a grey area. :smiley:

So now we know just who the consignor is, let’s see what their responsibilities are:

ADR 1.4.2.1 Consignor
1.4.2.1.1 The consignor of dangerous goods is required to hand over for carriage only consignments
which conform to the requirements of ADR. In the context of 1.4.1, [1.4.1 is general safety measures] he shall in particular:
(a) Ascertain that the dangerous goods are classified and authorized for carriage in
accordance with ADR;
(b) Furnish the carrier with information and data and, if necessary, the required transport
documents and accompanying documents (authorizations, approvals, notifications,
certificates, etc.), taking into account in particular the requirements of Chapter 5.4 and
of the tables in Part 3; []

Just to help them out a bit:
Chapter 5.4 of ADR is all about documentation. (ADR Transport documents and multi-modal DGNs etc etc.)
The tables in Part 3 of ADR make it perfectly clear how carriage is to be performed, including whether any Special Provisions (SPs) or other conditions, derogations, relaxations etc etc apply.

I can see why the OP asked the question.
If you look at (b) just above, you’ll see that the consignor must tell the carrier (the owner of the vehicle) certain information.
Without going into lots of quotes, there is also some responsibility on the carrier in this regard.

As for placards, the OP wrote about tankers. I’m guessing from your post (groupage) that you’re talking about packages.
Leaving out UN Classes 1 & 7… the only time that placards are need by road is when a container is conveyed by a road vehicle.
Otherwise than that, placards are required under IMDG when any dangerous goods are conveyed in a road vehicle that is itself a piece of freight on a ferry/ship. In the case of groupage (packages in a road vehicle going on a ferry) there is no requirement for placards to be displayed on the vehicle until the vehicle is to be loaded on a ferry.

Good day

I advise on transport of dangerous goods by road. I too was very interested in the ADR Environmental Label and that fuel tankers incorporated these as from January 1st. 2011. Looking at ADR 2011, there is no reference in Chapter 3.2, Table A; Dangerous Goods List. There is no environmental labels in Column (5), 5.2.2!1 I take it if it is a marine pollutant, this must come IMDG??

Am I correct that IMDG dictates this?

PJ Enviro

PJ Enviro:
Good day

I advise on transport of dangerous goods by road. I too was very interested in the ADR Environmental Label and that fuel tankers incorporated these as from January 1st. 2011. Looking at ADR 2011, there is no reference in Chapter 3.2, Table A; Dangerous Goods List. There is no environmental labels in Column (5), 5.2.2!1 I take it if it is a marine pollutant, this must come IMDG??

Am I correct that IMDG dictates this?

PJ Enviro

Hi PJ Enviro,

Firstly, let me apologise for the delay in answering your post. :blush:

You’re spot-on that IMDG dictates what is or isn’t a Marine Pollutant.
This is usually done by reference to the IMDG index, or column 4 of the IMDG DG List, but sometimes reference to SOLAS and MARPOL is needed.

However, we seem to be discussing what IMDG calls the “Marine Pollutant mark” but IMDG also uses the phrase “fish and tree sign,” both at IMDG 5.2.1.6.3. Some confusion may arise between ADR Regs and IMDG because of different terminology.
BTW, the old triangular Marine Pollutant mark has disappeared from IMDG.

ADR also has the same “fish and tree” label as IMDG, but calls it the “environmentally hazardous mark” both at ADR 5.2.1.8.3.
ADR also uses the phrase “Pollutants to the aquatic environment” as a heading to 2.2.9.1.10
(The old “Environmentally hazardous substances” at ADR 2.2.9.1.9 is deleted.)

You’re also spot-on about ADR not using 3.2.1 Table “A” or 5.2.2.1 to signify mandatory use of the “fish and tree” label. (“Fish and tree” placarding is dealt with elsewhere.)

After having read your post and not wishing to make any assumption about your knowledge, I’ll confess that I might not quite understand your question.

Could I please ask you… Are you asking how ADR classifies which substances need to be labelled with the “fish and tree” sign please?