ADR Limited quantities/small load exemption question

[iy67]

Hello,

In it’s endeavour to do the right thing/increase ISO rating etc. your company decides to offer you some basic adr awareness training. It’s stuff you’ve never really given much thought about before as you’ve been carrying mixed items containing the odd box or ten of hazardous goods (solvents, lubricants, adhesives, aerosols, cylinders etc.) for as long as you can remember. So you sit through a brief 1hr lesson about limited quantities and small load exemptions and toddle out the door clutching an a4 summary of said lesson. Not long after (next day ), it’s all a bit of a blur again. Soon after, new procedures come into force by way of a DG manifest issued at the start of your shift which contains information relating to the 20, 333, 1000 limits for the transport categories (TC) like this-

branch quantity     weight  category    total    under threshold
   1        4          25       3         100           YES
   1        1          25       2          25           YES        
   2        1          25       2          25           YES

The quantities are normally as small as shown and you set off from base with your trusty 2kg fire extinguisher in order to make your deliveries and pick up returns to/from satellite branches all around the country. Now these returns might also contain DGs but there is no manifest for these. You have no idea about the UN numbers and what TC they would fall into anyway and couldn’t work out the totals even if you wanted to. So you might drop off 2 DG items at drop 1, 1 at drop 2 then collect 3 DG items at drop 2. And so on. As far as I’m aware these collections are also meant to be documented beforehand but never are so the totals are pretty much meaningless after the first delivery. As stated, considering you have no idea about the TC should any DGs remain at the collection points unless already sanctioned for collection with the proper calculations shown on your manifest?

Example

You don’t even have any DGs this particular day and arrive at your delivery point, offload the goods and are about to collect the returns when you notice a 25l drum of UN 1993 N.O.S. which contains phosphate & ethanol (I think that’s what it contains, I can’t see the words properly) and has Class 3 flammable liquid and marine pollutant markings. As you have no idea about the TC should it be prudently left behind to allow you to seek advice and clarification? If it should be left behind what would be the consequences of collecting it a) knowingly and b) accidentally (eg. hidden in a cage so you couldn’t see it) then getting pulled on route and busted for carrying too much of a particular category? Could somebody also explain N.O.S. (not otherwise specified)?

Finally, could somebody explain in simple terms the difference between limited quantities (LQ) and small load exemption (SLE). Is a LQ always a SLE and vice versa, a SLE always a LQ?

Thanks.

[ben_blakemore]

Any and all dg freight should be properly documented in your notes. If you are not handed and dg paperwork don’t take the freight.

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[dieseldave]

ben.blakemore:
Any and all dg freight should be properly documented in your notes. If you are not handed and dg paperwork don’t take the freight.

Hi Ben,

Sorry mate, but that’s not quite correct in the way that you’ve written it.

For transport within the UK, there is a derogation from the normal ADR transport document requirements that covers the carriage of small loads.

For instance, a non-ADR trained driver can take a 300L of petrol in drums from Manchester to London without the need of an ‘official’ ADR transport document. A simple P.O.D. type delivery note contrived by the transport company would suffice for that job.

[ben_blakemore]

Very true I was thinking multimodal

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[dieseldave]

ben.blakemore:
Very true I was thinking multimodal

Sent from my iPhone using Tapatalk

Yes Ben, you’re correct with that one.

Multi-modal work needs a proper multi-modal DGN.

[dieseldave]

iy67:
Hello,

In it’s endeavour to do the right thing/increase ISO rating etc. your company decides to offer you some basic adr awareness training. It’s stuff you’ve never really given much thought about before as you’ve been carrying mixed items containing the odd box or ten of hazardous goods (solvents, lubricants, adhesives, aerosols, cylinders etc.) for as long as you can remember. So you sit through a brief 1hr lesson about limited quantities and small load exemptions and toddle out the door clutching an a4 summary of said lesson. Not long after (next day ), it’s all a bit of a blur again. Soon after, new procedures come into force by way of a DG manifest issued at the start of your shift which contains information relating to the 20, 333, 1000 limits for the transport categories (TC) like this-

branch quantity     weight  category    total    under threshold

1 4 25 3 100 YES
1 1 25 2 25 YES
2 1 25 2 25 YES

Hi iy67,

Firstly, I’ll start by telling you that a 1hr lesson to cover what you’ve said is IMHO woefully inadequate, so it’s no wonder that you’re left in a bit of a spin (other descriptions are available ) and therefore the company have got what they paid for, which is a great deal of confusion on your part.

From the info you’ve given in the table above, it is correct to say that the load is less than threshold.

iy67:
The quantities are normally as small as shown and you set off from base with your trusty 2kg fire extinguisher in order to make your deliveries and pick up returns to/from satellite branches all around the country. Now these returns might also contain DGs but there is no manifest for these. You have no idea about the UN numbers and what TC they would fall into anyway and couldn’t work out the totals even if you wanted to. So you might drop off 2 DG items at drop 1, 1 at drop 2 then collect 3 DG items at drop 2. And so on. As far as I’m aware these collections are also meant to be documented beforehand but never are so the totals are pretty much meaningless after the first delivery. As stated, considering you have no idea about the TC should any DGs remain at the collection points unless already sanctioned for collection with the proper calculations shown on your manifest?

You can rest easy now mate, because this isn’t your job if you are an employed driver.
This is very firmly the responsibility of the Carrier ( = the vehicle owner.)

They can delegate this to an employed driver, but it would need quite a shift in the way that they do things for that situation to have any chance of success. You’ve given a perfect example of what I mean, because there are collections to be done during your route. You are completely correct to say that the original plan therefore goes out of the window after the first collection.

iy67:
Example

You don’t even have any DGs this particular day and arrive at your delivery point, offload the goods and are about to collect the returns when you notice a 25l drum of UN 1993 N.O.S. which contains phosphate & ethanol (I think that’s what it contains, I can’t see the words properly) and has Class 3 flammable liquid and marine pollutant markings. As you have no idea about the TC should it be prudently left behind to allow you to seek advice and clarification? If it should be left behind what would be the consequences of collecting it a) knowingly and b) accidentally (eg. hidden in a cage so you couldn’t see it) then getting pulled on route and busted for carrying too much of a particular category?

As an employed driver… if your boss has told you that you can carry the stuff legally, then you’re good to go.

As a carrier, your boss has a legally inescapable duty to employ a properly qualified DGSA.
The company’s DGSA has a responsibility to monitor and advise the company. As a DGSA, my (free) advice to you/your boss is that the system at your company needs to be changed and there is a need for a review of staff training to take account of duties in connection with the carriage of dangerous goods.

What they’re doing is fine, but IMHO it’s the way that they’re doing it that needs changing. Otherwise, they will fall foul of what you fear if you get pulled. The outcome for you as an employed driver is that you will be issued with a prohibition, which is simply a minor inconvenience to you, but which can have a negative outcome on your boss’ ‘O’ licence at review and maybe his ISO.

iy67:
Could somebody also explain N.O.S. (not otherwise specified)?

Not Otherwise Specified (NOS) is a legal way of saying that the ‘stuff’ doesn’t have one of the legally required names in ADR’s dangerous goods list, or is a mixture of chemicals. As you’ve observed, the name(s) of one (or more) of the ingredients are shown as part of the Proper Shipping Name. (PSN.)

In many cases involving NOS, there are three versions of ‘stuff’ according to the level of danger EG: PGI, or PGII or PGIII.
Therefore, the ‘stuff’ could end up being in any of the five ADR Transport Categories, and there is the reason that an employed driver wouldn’t be able to know what’s what with it when it comes to whether it’s ‘in scope’ or not.

UN 1993 (the one you mentioned) is a great example, because there are three PGs for that one!!

iy67:
Finally, could somebody explain in simple terms the difference between limited quantities (LQ) and small load exemption (SLE). Is a LQ always a SLE and vice versa, a SLE always a LQ?

LQs are best thought of as the kind of dangerous goods that can be bought in a retail shop such as B&Q or a garden centre and packaged for retail sale over-the-counter. LQs are completely separate from any ‘small load’ considerations and can be carried without limit.

The small load exemption is completely separate from the LQ exemption, because that only applies when the dangerous goods are NOT packaged as LQs. As a rough guideline… anything bigger than 5L or 6Kg, or anything that doesn’t come as receptacles in a box (max 30Kg per box) or on small stretch wrapped trays (max 20Kg per tray) is NOT an LQ.

Anything that has this label does NOT count towards load calculation:

For me to give you any advice other than the very general advice above, I would need an extensive knowledge of what you’re expected to carry (how/where/when) and the way that the paperwork and returns are done.

I hope this helps, but I fear it might be insufficient.

[iy67]

Thanks for your input Ben and to Dave for his comprehensive answer, much appreciated

dieseldave:
Hi iy67,

Firstly, I’ll start by telling you that a 1hr lesson to cover what you’ve said is IMHO woefully inadequate, so it’s no wonder that you’re left in a bit of a spin (other descriptions are available ) and therefore the company have got what they paid for, which is a great deal of confusion on your part.

Hi Dave, they didn’t pay anything, the gaffer did it He did some kind of awareness course himself which gave him accreditation to teach us?

dieseldave:
You can rest easy now mate, because this isn’t your job if you are an employed driver.

Great, that’s a relief so can I just clarify that without documentation or the say so of my employer to confirm its legality then the aforementioned 25l drum should stop where it is? Note: you are told not to bring back adr items that you shouldn’t but therein lies the problem. It’s knowing what you can/can’t bring and unfortunately many items are hidden amongst other goods so you can’t see them. Hence even though it can be transported normally, without knowing various factors you are not being deliberately difficult leaving the drum where it is? Apologies for the 20 questions

dieseldave:
This is very firmly the responsibility of the Carrier ( = the vehicle owner.)

They can delegate this to an employed driver, but it would need quite a shift in the way that they do things for that situation to have any chance of success. You’ve given a perfect example of what I mean, because there are collections to be done during your route. You are completely correct to say that the original plan therefore goes out of the window after the first collection.

As an employed driver… if your boss has told you that you can carry the stuff legally, then you’re good to go.

I’m not saying my boss is unscrupulous, far from it but by “told” do you mean in writing or would the powers that be side with the driver on a “Me: Boss told me. Boss: No I didn’t” oral scenario?

dieseldave:
As a carrier, your boss has a legally inescapable duty to employ a properly qualified DGSA.
The company’s DGSA has a responsibility to monitor and advise the company. As a DGSA, my (free) advice to you/your boss is that the system at your company needs to be changed and there is a need for a review of staff training to take account of duties in connection with the carriage of dangerous goods.

What they’re doing is fine, but IMHO it’s the way that they’re doing it that needs changing. Otherwise, they will fall foul of what you fear if you get pulled. The outcome for you as an employed driver is that you will be issued with a prohibition, which is simply a minor inconvenience to you, but which can have a negative outcome on your boss’ ‘O’ licence at review and maybe his ISO.

It’s a large company so there should be one. I’d raise the concerns to my boss who would then liase with the DGSA officer and report back I guess as I don’t know who it is and have never seen them. One thing I forgot to mention is that delivering across the UK sees you passing through most tunnels available to LGVs yet I would be surprised if the DGSA was aware which routes passed through which tunnel!

dieseldave:
Not Otherwise Specified (NOS) is a legal way of saying that the ‘stuff’ doesn’t have one of the legally required names in ADR’s dangerous goods list, or is a mixture of chemicals. As you’ve observed, the name(s) of one (or more) of the ingredients are shown as part of the Proper Shipping Name. (PSN.)

In many cases involving NOS, there are three versions of ‘stuff’ according to the level of danger EG: PGI, or PGII or PGIII.
Therefore, the ‘stuff’ could end up being in any of the five ADR Transport Categories, and there is the reason that an employed driver wouldn’t be able to know what’s what with it when it comes to whether it’s ‘in scope’ or not.

UN 1993 (the one you mentioned) is a great example, because there are three PGs for that one!!

Ah yes, the PG is another thing we’d need to know? Thanks for reminding me. Told you it had become a bit of a blur again

dieseldave:
LQs are best thought of as the kind of dangerous goods that can be bought in a retail shop such as B&Q or a garden centre and packaged for retail sale over-the-counter. LQs are completely separate from any ‘small load’ considerations and can be carried without limit.

The small load exemption is completely separate from the LQ exemption, because that only applies when the dangerous goods are NOT packaged as LQs. As a rough guideline… anything bigger than 5L or 6Kg, or anything that doesn’t come as receptacles in a box (max 30Kg per box) or on small stretch wrapped trays (max 20Kg per tray) is NOT an LQ.

Anything that has this label does NOT count towards load calculation:
0

Thanks, this is starting to make sense. So a 25l drum of flammable liquid would normally be part of the small load exemption, right? If you think “screwfix” type company, you will have a better grasp of the goods being carried. So, there will be plenty of LQs on there amongst a mainly non adr load but nowhere near the 8000kg that would bring the load in scope. In amongst all that you have the small load exemption items as discussed too.

dieseldave:
For me to give you any advice other than the very general advice above, I would need an extensive knowledge of what you’re expected to carry (how/where/when) and the way that the paperwork and returns are done.

I hope this helps, but I fear it might be insufficient.

No it’s a big help thanks Dave, one thing the training has done is to make you more aware of the stuff you are carrying and flag up and query things that have previously been carried out in a “Well, that’s how it’s always been” fashion. Reading your last paragraph has just prompted another question with regards to the paperwork and discarding it so I’ll briefly explain the process of events relating to the adr items:-

1. Receive paperwork containing adr manifest as per table above which will always be under the threshold as they have checked it.
2. Proceed to delivery points and tip loaded cages (may or may not contain DG).
3. At the delivery points load any returns (may or may not contain DG).
4. Return to depot with same adr manifest as you set off with unaltered in any way. (you have now delivered the DG as per manifest but may or may not have more DGs on board than you set off with via the returns!). 
5. The adr manifest has no further use and is discarded. (I've been told that since the job is complete the paperwork is no longer required - is that correct?).

[dieseldave]

Hi iy67,

It is possible that a simple DG awareness can be ‘cascaded’ downwards, but the person delivering the cascaded info must first understand it himself.

The way of calculating a load consisting of differing ADR transport categories of stuff is somewhat complex, and defo needs more than an hour’s worth of training to absorb.

The next thing I’d suggest is that at least one member of staff from each of the branches needs to be shown how it works, and I’d suggest the implementation of a company-wide requirement that all DG returns need to be authorised in advance via HQ before they can be taken.
That way, the central planner is always aware of what’s going to be loaded on the vehicle as it goes around its route, then HE/SHE can say with certainty whether a load is ‘in scope’ at any given time.

I’ve no idea whether your company has a properly qualified DGSA.
Strictly speaking, if a company only ever transports DG that don’t come ‘in scope’ then they don’t need one, but that then leaves the question of how do they know what is/isn’t in scope??

You mentioned 8t of LQs… that only triggers a vehicle marking requirement, because LQs are never ‘in scope.’

As for tunnels, the thresholds for whether you’re allowed through certain tunnels are also somewhat complex and not easily explained here.

As I said in my last post, without knowing a lot more than I do about your operation… I can only speak in general terms.

I’m glad I’ve clarified at least some of it for you.

[iy67]

dieseldave:
I’m glad I’ve clarified at least some of it for you.

Thanks for your time Dave, most helpful