As a favour for a mate I’ve jumped in a truck for the day, gets me out for a few hours and gives me a few beer tokens for the weekend, his lad isn’t ADR so all I need to do is load a trailer for him and take it to the port at Immingham.
All went ok, load was ready, all paperwork and DGN’s in order, all I need to do is collect labels at the booking office on the port, it’s here where confusion begins.
The load I’m carrying is Marine Pollutant and LQ, at a total weight of 670kg it’s well beneath the threshold to have the boards up even if it wasn’t LQ, the booking clerk at the port asked where my labels were, I informed him I didn’t have them and to charge the company for them, to which he replied that I’d been running illegal and that’s it’s a requirement to display labels.
I’ve been ADR for 9 years and never heard of having to display labels ( apart from classes 1 and 7 ) and other than adr tankers who display the UN number I only ever placed labels on my trailer prior to boarding the ferry and removed them when I was about to get off the boat.
He told me the law has changed and the DVSA that patrol the port, regularly pull vehicles displaying the HAZ plate and not the class labels, and should a vehicle be leaving the port he should advise them.
Has the law changed and am I wrong for not displaying them, it’s not that I’ve been fined but more peace of mind.
road and sea regs are different - this causes confusion which I think is happening here . I’m sure an expert will clear this up for you soon .
I lost a bloody good job over all this stuff about 13 yrs ago. 
I went to pick up a P&O trailer off Immingham to deliver to N.East.
The trailer was covered in hazardous load stickers and I rang to refuse to take it, not having an ADR cert, but the guy on the phone was a bit arsey with me and told me it was for sea routes only but ok by road. By his arsey attitude I didn’t believe him, I thought he was b.s ing me, but it turned out he wasn’t.
P&O rang my firm told them they wouldn’t use me again. 
Ended up on Schnellecke for next 3 months which was a crap job in comparison, so I kinda crapped in my own nest as it turned out as the P&O job was getting me home most nights until the Euro work re.started, plus I was still getting paid 5 nts out a week while on it. 
beefy4605:
road and sea regs are different - this causes confusion which I think is happening here . I’m sure an expert will clear this up for you soon .
I think the confusion is the guy on the gate is stating marine regs, he’s right the trailer needs labels to go by sea ( but I needed him to give me them ) he’s incorrectly stating they also need to be on the vehicle while on the road.
Ive done ADR going over the water for years and I’ve never had a label on the trailer while driving, only had them on while on the boat.
But he was so adamant I was wrong I came away questioning myself, and wondered if there had been an amendment to ADR regs stating labels must be displayed.
Grumpy Dad:
Has the law changed and am I wrong for not displaying them, it’s not that I’ve been fined but more peace of mind.
Hi GD,
If it were an ISO container, you’d be needing Placards right from the word ‘go,’ but you said “trailer” so that makes it that what you did and the way you did it was OK.
Some of the ports require you to be marked correctly before entering the port.
From the info you gave, you didn’t need any signage at all for the road part of your journey.
There’s one aspect of this that I need to look at my IMDG books to make sure I get correct for you, but those books are presently in a classroom 40miles from where I am at the moment… so I’ll give you a good answer tomorrow.
Cheers Dave, I didn’t think I was wrong, but the bloke on the gate was insistent I’d put my licence at risk by not having the labels on while driving, even down to his “ I think you’ll find things have changed since you took your ADR”.
Its only as a favour for a mate and he’s asked if I’ll do the same run for him tomorrow
dieseldave:
Grumpy Dad:
Has the law changed and am I wrong for not displaying them, it’s not that I’ve been fined but more peace of mind.Hi GD,
If it were an ISO container, you’d be needing Placards right from the word ‘go,’ but you said “trailer” so that makes it that what you did and the way you did it was OK.
Some of the ports require you to be marked correctly before entering the port.
From the info you gave, you didn’t need any signage at all for the road part of your journey.
There’s one aspect of this that I need to look at my IMDG books to make sure I get correct for you, but those books are presently in a classroom 40miles from where I am at the moment… so I’ll give you a good answer tomorrow.
I bet I know exactly what you’re going to check Dave! And yes, it’s only if over 8 tonnes, so no markings were required.
khdgsa:
dieseldave:
Grumpy Dad:
Has the law changed and am I wrong for not displaying them, it’s not that I’ve been fined but more peace of mind.Hi GD,
If it were an ISO container, you’d be needing Placards right from the word ‘go,’ but you said “trailer” so that makes it that what you did and the way you did it was OK.
Some of the ports require you to be marked correctly before entering the port.
From the info you gave, you didn’t need any signage at all for the road part of your journey.
There’s one aspect of this that I need to look at my IMDG books to make sure I get correct for you, but those books are presently in a classroom 40miles from where I am at the moment… so I’ll give you a good answer tomorrow.
I bet I know exactly what you’re going to check Dave! And yes, it’s only if over 8 tonnes, so no markings were required.
I’ve now had chance to have a look at my IMDG… there’s no requirement to have done anything any differently to what GD did. 
It wasn’t the 8t bit though!! 
Thanks guys for the help, seems like I encountered the infamous know it all booking in clerk
Grumpy Dad:
Thanks guys for the help, seems like I encountered the infamous know it all booking in clerk
This ^^^ 