ADR is mentioned in the June '08 Nat. CPC case study.....

The quoted extract below is from the June 2008 pre-release case study (unit 4) for National CPC

In the case study is:
BACKGROUND
Current Operation John Johnson, an owner driver aged 45, carries out work for a single customer, which mainly involves multiple drop work in and around Huntingdon. He has done this for the last 18 months after being made redundant from his previous job as a dairy herdsman. John has no qualifications other than a driving licence covering categories A, B & C1.

The work for his customer currently averages 30 deliveries and 20 collections per day and John covers an average distance of 120km per day.
John currently owns a 7500kg GVW rigid box bodied vehicle with a sleeper cab, purchased new from his customer. This vehicle is not fitted with a working tachograph. He operates on his customer’s operator’s licence. The customer charges John for this service and for providing a CPC holder and a DGSA. John takes his vehicle home in the evening parking it on the roadside, and uses it most weekends to help out a friend by moving furniture between furnished properties which she owns.

The number of working days with his vehicle for this customer is 250 per annum.

Dangerous Goods
John currently carries dangerous goods on three days a week. The following goods are carried: UN 1790 Hydrofluoric Acid of Packing Group 1 with a Transport Category 1 and a Limited Quantity 0.
John has tried to contact the DGSA, but only gets an answer machine message. His customer has told John that there is nothing to worry about as the consignments are packed in one litre plastic bottles and as he never carries more than 100 at a time, they are exempt from dangerous goods regulations. The customer also informed John that it is a remote service and the DGSA never visits.

This seems to me to be looking at whether you understand the various definitions and threshold limits for ADR, and possibly your knowledge of a DGSA’s duties.

Three useful definitions:
A ‘carrier’ is a person or company that performs the transport operation, so John is a ‘carrier.’ The Regs require John to appoint a DGSA.
A ‘consignor’ is a person or company who consigns (sends) dangerous goods, either for themselves or on behalf of a third party.
In the scenario, the ‘customer’ is the consignor. The Regs require a consignor to appoint a DGSA.
A dangerous goods safety advisor (DGSA) is a person who holds the relevant DGSA qualification. (In the UK, this is an SQA qualification.)

A DGSA’s duties include:

  1. monitoring compliance with the requirements governing the carriage of dangerous goods;
  2. advising on the carriage of dangerous goods;
  3. preparing an annual report to the management on their activities in the carriage of dangerous goods.
    (Management MUST retain these reports for 5 years AND produce them to the Police, VOSA or the HSE if requested.)
  4. verification of proper procedures for identifying dangerous goods.
  5. verification that persons have had training appropriate to their duties
  6. preparing reports of serious incidents or infringements for forwarding to the DfT.
  7. verification that a company has appropriate equipment for the carriage of dangerous goods.
  8. verification of proper emergency procedures in case of an incident involving dangerous goods.
    (As if these weren’t enough, there are some others too. :open_mouth: )

:open_mouth: John’s current dangerous goods arrangements are somewhat dodgy I’m afraid. :frowning:

Johns’ DGSA is falling down in that he/she isn’t available to give advice to John.
The consignor’s DGSA has neglected to ensure that persons at the customer’s premises have had appropriate training, since one of them WRONGLY says it’s OK for John to carry the stated amount of UN 1790.

John EITHER needs to undertake an ADR course covering ‘core’, ‘packages’ and Class 8, if he wishes to continue to carry UN 1790 in the stated amounts, OR carry NO MORE THAN 20ltrs of UN 1790 at any one time.

Here is a UN class 8 label:

The “Limited Quantity of 0” means that there ISN’T an option to escape the Regs by carrying this substance in little packages.
Therefore, any amount carried will count towards the relevant ADR limit, in this case, 20ltrs.
We know this because the Transport Category is given as “1” in the scenario.
It follows that the customer is talking utter ZB by telling John that he’s OK to carry 100 ltrs of this stuff in little bottles because he doesn’t carry more than 100 ltrs at a time.
In this case, the threshold that triggers the requirement for an ADR licence is 20 ltrs.
John CAN carry UP TO (and including) 20 ltrs, but if he were to carry more than that, he’d need an ADR certificate valid for at least Class 8 in packages.
The scenario tells us that John doesn’t have any other qualifications. :wink:
In this case, if John carries up to 20ltrs, he would need a proper 2kg dry powder fire extinguisher like this:
or this

If John were to be stop-checked on the road, he must be able to tell the authorities the identity of his DGSA, and there is a part of the form used by VOSA where this info must be written, if dangerous goods above ADR thresholds are being carried.
John must also have annual reports on his dangerous goods compliance from his DGSA.
Additionally, the DGSA would have to be able to show how he/she meets the requirement of ‘advising’ John about dangerous goods.
:open_mouth: The fact that the DGSAs service is “remote” isn’t a problem, nor is there anything wrong with the fact that the DGSA never visits- strange, but true. :open_mouth:

I hope I’ve guessed the content of the likely questions correctly, and given you enough clarity to be of help. :smiley:

:open_mouth: Mind you, the above is possibly the least of John’s worries, because he’s running on somebody else’s ‘O’ licence and he seems to work rather more than he should… :wink:
:open_mouth: …and he possibly needs to get his tacho repaired.:grimacing:

Good luck with the rest of the case study.:grimacing:

Thanks for taking the time to do that Dave, it sounds like it will be very useful to anyone taking the exam this time round. I, for one, am glad I’m not one of them!

Paul

On behalf of myself and the others booked in for the exam

I hadn’t been sure where to start with the case study :open_mouth:

Many thanks Dave.

ADR is not one of my most favourite topics in the CPC syllabus but you have certainly made things a lot clearer. Broken down, it all makes a lot more sense where they could be heading and what steps should be taken to adhere to regulations.

I wish the OCR would write more realistic scenarios though as surely there can’t be people out there bucking the system and as as clueless as this - or is there? :open_mouth:

Oh well, just under 3 weeks to go!

Hi Guys, many thanks for the responses.:grimacing:

It’s really nice to know that my efforts are appreciated. :smiley:

G Griffin:
Many thanks Dave.

ADR is not one of my most favourite topics in the CPC syllabus but you have certainly made things a lot clearer. Broken down, it all makes a lot more sense where they could be heading and what steps should be taken to adhere to regulations.

I wish the OCR would write more realistic scenarios though as surely there can’t be people out there bucking the system and as as clueless as this - or is there? :open_mouth:

Oh well, just under 3 weeks to go!

Hi G Griffin, you’re right on the money with that comment IMHO.:grimacing:

The part I’ve quoted above is actually the nearest that OCR have come to a realistic scenario. :open_mouth:

:open_mouth: Yes, there really are people like John, and VOSA catch up with them fairly regularly. :wink:

DGSAs are no different to any other profession IMHO, there’s the good, the bad and the indifferent.

DIESEL DAVE, can you clarify the ‘Limited Quantity 0’ ?
Does this mean that even though UN1790 is Transport Cat 1 ,which has a threshold of up to 20, this particular substance is in fact ‘0’ meaning any amount falls in scope of full ADR regs ? (Regardless of its Transport Cat).
Or another way of asking would be: Does Limited Quantity ‘0’ mean the same as the max permissable before full ADR regs, in this case ‘0’ so John can’t even move any of it without full ADR compliance ?
Hope you understand the question.

It says ERF not RAF:
DIESEL DAVE, can you clarify the ‘Limited Quantity 0’ ?
Does this mean that even though UN1790 is Transport Cat 1 ,which has a threshold of up to 20, this particular substance is in fact ‘0’ meaning any amount falls in scope of full ADR regs ? (Regardless of its Transport Cat).

Hi It says ERF not RAF… I see where the problem lies. :smiley:

The system of Transport Categories is a completely separate idea to the notion of LQs, and there’s no ‘mix and match’ option because you’re either doing one or the other. :wink:

The LQ exemption is to do with the amount packaged in an individual package, whereas the limits in the transport categories is a total load limit per vehicle, which if exceeded, triggers the full weight of the Regs into action.

There are approx 3,200 substances and articles in the dangerous goods list. Each one of these is assigned an LQ code ranging from LQ0 - LQ28. The meaning of LQ0 is that there are no LQ exemptions allowed for that ‘stuff.’ Therefore a substance like UN1790 has NO possibility of being carried using an LQ exemption. Therefrore, any quantity of this ‘stuff’ will count towards the relevant load limit of 20ltr.

The meaning of the other LQ codes (LQ1 - LQ28) is a way of saying what sizes / weights the inner receptacle and outer box sizes can be in order to be exempt from the Regs regardless of the total amount carried. As a rule of thumb, ‘stuff’ that’s quite dangerous can’t be carried by the use of LQ exemptions.

The Transport Categories are for use when the ‘stuff’ isn’t being carried (for whatever reason) in Limited Quantities.

Please can I suggest that you read my replies to Mr Flibble near the bottom of pages 1 and 3 of THE ADR STICKY IN THE H&S FORUM

But please don’t hesitate to ask another question if it’s still not clear.:grimacing:

Was the info in the sticky helpful??

Hi Dave

To the best of my recolection the questions in your line of work were:-

  1. Give 6 x responsibilities of a DGSA
  2. I/D the markings John would need for his vehicle carrying DG and the two documents he would require to carry.
  3. Name 3 x items of equipment he needs to carry.

These were a scoosh :astonished:
Shame about some of the others :smiling_imp:

I think John has a lot more to worry about than his ADR. I recommend he gets one of these and rereads the question before he gets to “anything you say etc” :stuck_out_tongue:

Otherwise I think DD is doing a sterling job on the ADR advice :stuck_out_tongue: