ADR Markings Question

[matthewjohnston]

I deliver some packaged items so obviously flip down the orange plate, but I have noticed today that the vehicle I will be using on Monday (61 Plate) has the orange plate rivited to the front bumper. it looked a strange size and when i flipped it down it was like this:-

instead of looking like this

I know the ADR orange sign should be 300 down and 400 across, but this one is bolted on so it opens with 400 down and 300 across.

I know its illegal, but what fine/penalty would you get for this?, also if I kick up a stink about this on monday morning could get sack as this is a fixed plate and they dont have sticky ones laying about.

also, I just read online that the instructions in writing was changed again in Jan this year?, did not know that . even when i obtained the licence 7 months ago they never mentioned it and my book shows the 2009 version. I say that as every vehicle I been in has the 2009 one. So is it safe for me to download and print the 2011 amended version or must it be laminated?, at least one less thing to worry about on monday.

It says here that if old version is a written report and not a PN. whats a written report and whats a PN? I mean the difference, one i guess is a fine but what does report mean?
hse.gov.uk/cdg/manual/opstratenforce.htm

plus, another thing that confuses me, when I was taught for the ADR I was told if you carry any item that has a UN number then you must display an orange plate, yet some days |I get given delivery notes that have multiple UN numbers but traffic office insist its non-adr so no plates required. They say its not enough quantity to show as adr, but is a huge 25lt drum or a huge drum of flamable liquid like anti freeze that has UN number not classed as an adr?

[jwalker78]

The orange board should be mounted the other way,as you said in the UK you be very unlucky to get done they would advise to change it’s position ASAP.
The new style Trem card is a must and you would run the risk of large fine or GV9 depending on the officer, as long as they are in colour and in your native tongue they will no problem.

[dave75]

Not sure about you getting a fine but they’ll likely put a prohibition notice on the motor and you won’t be able to move it until the plate is displayed correctly. I got one for a plate that had faded with the sun and wasn’t the correct shade of orange. No fine but a prohibition notice was put on the trailer.

[dieseldave]

matthewjohnston:
I deliver some packaged items so obviously flip down the orange plate, …

Hi Matthew,
Sorry to chop your post up in the way that I have, but it’s made my answer to you a bit more logical.

I’m not sure of your use of the word “obviously” above, because whether you need to display the orange plates depends on the ADR Transport Category, the size and type of packages AND the amount of the dangerous goods that you’re carrying. However, this decision is NOT your responsibility.

matthewjohnston:
…plus, another thing that confuses me, when I was taught for the ADR I was told if you carry any item that has a UN number then you must display an orange plate, yet some days |I get given delivery notes that have multiple UN numbers but traffic office insist its non-adr so no plates required. They say its not enough quantity to show as adr, but is a huge 25lt drum or a huge drum of flamable liquid like anti freeze that has UN number not classed as an adr?

It sounds to me that your traffic office are probably correct.
It also sounds to me that you’ve either misunderstood your ADR instructor, or he didn’t cover the ADR Transport Category load limits as he should have done. (I can’t say which though, but something isn’t quite right here. )
If your ADR course was timetabled in the traditional way, you’d have covered the subject of ADR Transport Categories briefly on the Monday morning, and again in a little more depth during the packages module around lunchtime on the Tuesday.

matthewjohnston:
… I know the ADR orange sign should be 300 down and 400 across, but this one is bolted on so it opens with 400 down and 300 across.

I know its illegal, but what fine/penalty would you get for this?, also if I kick up a stink about this on monday morning could get sack as this is a fixed plate and they dont have sticky ones laying about.

Matthew, that’s not your problem mate, I’d advise you to point it out to the office bods as soon as you ‘notice’ it on Monday. I’d very much doubt that any reasonable employer would sack you for pointing this out, on the contrary, IMHO pointing this out shows that you’re conscientious in your daily checks.
The reason that it’s not your fault is that you didn’t attach the orange plate in the wrong orientation, since I’ve not seen many drivers who carry a rivet gun to work with them.
I’ve noticed that the border surrounding the orange plate in your pics looks like it’s blue in colour, but this might be a trick of lighting or camera angle. In any case, the border of an ADR orange plate must be black.

matthewjohnston:
So is it safe for me to download and print the 2011 amended version or must it be laminated?, at least one less thing to worry about on monday.

Yes mate, it’s perfectly OK for you to download and print the 2011 version of the Instructions In Writing (IIW.)
You must print it in colour and you must have 4 sides.
You can print it double sided on two pages if you wish, and there’s no requirement for it to be laminated.
Just so that you know, it is the carrier’s (vehicle operator) legal responsibility to provide you with the correct IIW.

I can tell you what the law on carrying dangerous goods says, or whose responsibility something is. However, I have no connection with enforcement, so I wouldn’t like to second guess an enforcement officer’s decision on what, if any, penalty is likely.

The letters “PN” stand for Prohibition Notice.
The PN below was issued because the carrier had failed to supply the driver with the correct equipment for the class of dangerous goods that he carried.

If you can tell me the UN number, Proper Shipping Name, Class and Packing Group plus the package size(s) and amounts of what you’re going to carry, I’ll have a shot at telling you whether you need to display orange plates for that particular load.

I hope this helps.

[matthewjohnston]

dieseldave:

matthewjohnston:
I deliver some packaged items so obviously flip down the orange plate, …

Hi Matthew,
Sorry to chop your post up in the way that I have, but it’s made my answer to you a bit more logical.

I’m not sure of your use of the word “obviously” above, because whether you need to display the orange plates depends on the ADR Transport Category, the size and type of packages AND the amount of the dangerous goods that you’re carrying. However, this decision is NOT your responsibility.

matthewjohnston:
…plus, another thing that confuses me, when I was taught for the ADR I was told if you carry any item that has a UN number then you must display an orange plate, yet some days |I get given delivery notes that have multiple UN numbers but traffic office insist its non-adr so no plates required. They say its not enough quantity to show as adr, but is a huge 25lt drum or a huge drum of flamable liquid like anti freeze that has UN number not classed as an adr?

It sounds to me that your traffic office are probably correct.
It also sounds to me that you’ve either misunderstood your ADR instructor, or he didn’t cover the ADR Transport Category load limits as he should have done. (I can’t say which though, but something isn’t quite right here. )
If your ADR course was timetabled in the traditional way, you’d have covered the subject of ADR Transport Categories briefly on the Monday morning, and again in a little more depth during the packages module around lunchtime on the Tuesday.

matthewjohnston:
… I know the ADR orange sign should be 300 down and 400 across, but this one is bolted on so it opens with 400 down and 300 across.

I know its illegal, but what fine/penalty would you get for this?, also if I kick up a stink about this on monday morning could get sack as this is a fixed plate and they dont have sticky ones laying about.

Matthew, that’s not your problem mate, I’d advise you to point it out to the office bods as soon as you ‘notice’ it on Monday. I’d very much doubt that any reasonable employer would sack you for pointing this out, on the contrary, IMHO pointing this out shows that you’re conscientious in your daily checks.
The reason that it’s not your fault is that you didn’t attach the orange plate in the wrong orientation, since I’ve not seen many drivers who carry a rivet gun to work with them.
I’ve noticed that the border surrounding the orange plate in your pics looks like it’s blue in colour, but this might be a trick of lighting or camera angle. In any case, the border of an ADR orange plate must be black.

matthewjohnston:
So is it safe for me to download and print the 2011 amended version or must it be laminated?, at least one less thing to worry about on monday.

Yes mate, it’s perfectly OK for you to download and print the 2011 version of the Instructions In Writing (IIW.)
You must print it in colour and you must have 4 sides.
You can print it double sided on two pages if you wish, and there’s no requirement for it to be laminated.
Just so that you know, it is the carrier’s (vehicle operator) legal responsibility to provide you with the correct IIW.

I can tell you what the law on carrying dangerous goods says, or whose responsibility something is. However, I have no connection with enforcement, so I wouldn’t like to second guess an enforcement officer’s decision on what, if any, penalty is likely.

The letters “PN” stand for Prohibition Notice.
The PN below was issued because the carrier had failed to supply the driver with the correct equipment for the class of dangerous goods that he carried.

0

If you can tell me the UN number, Proper Shipping Name, Class and Packing Group plus the package size(s) and amounts of what you’re going to carry, I’ll have a shot at telling you whether you need to display orange plates for that particular load.

I hope this helps.

thanks for the reply.

the images of the orange plate are just stock images from the web, it was just easier to take image from there to visually explain what the plate looked like. Do not have a camera phone so could not take pics, but basically the way its been rivited on is wong way so opens up with narrow part at top and folds down with long part facing down instead of other way round. I forgot to check the rear so not sure if its same, but will obviously check on monday.
As I am an agency driver although semi regular with the company dont want the company complaining I am an aqward driver and get less work or banned from site for complaining. I already complained about there being no spare digi tacho rolls in the cab and that did not go down well in transport office. Now I carry my own supply yet still no spares in cab, one vehicle I used did not even have a roll in the unit when i took it over.

the first part you highlighted, i only show orange plates if it says ADR on the loading sheet, basically the sheet with the delivery addresses and pallet amounts, it will either say ADR or Non-ADR at the top, so depending on what that says is what I show or dont show.

when I did the adr course it was all mixed up, the screen did not work so he showed videos from day 3 on day 1 and day 1 was done on day 2 ets… still did full course but not in the proper order. He did explain things but maybe was not thorough enough in some aspects. The instructor did specifically say (maybe he was wrong), if you carry any goods that have a UN number on it whether package or drums etc then its automatic orange plate no matter what quantity, if it shows a UN number then it means it comes under adr regulations.

All the cabs have a copy of the laminated INW in them as any can be used for ADR and all drivers trained in it. I did presume they were current but only by chance did I look at a website and thought that looks different than what I have. It seems they have not replaced any of them, you would think they would know its been updated. But as long as it does not have to be laminated I can print it off myself so at least its current and legal. But will still let them know but wether they listen is another matter, you say stuff to them and it goes in one ear and straight out other. I reported several minor faults with vehicles thats never been fixed, they nothing major but could cause problems in long term.

I will download this one
unece.org/fileadmin/DAM/tran … sh2011.pdf

one thing that niggles me too is that during the adr course they said that the documents if carrying adr must be signed by the supplier/sender. Basically the people i work ( cant say who they are incase one of them read this) for make and distribute the items themselves,

The delivery notes I get are as follows.
Company name at top.
Billing address left, delivery address to right
then list of items, eg quantity, description of item with proper names, un number, packing group, tunnel code etc… (like list shown below)
bottom of sheet place for person receiving goods to sign and date and very bottom my company address. I keep top copy and return to office customer gets bottom copy.

thats all the sheet has, nothing else.

I did quickly write down a basic list of one days work that I delivered, the quantity was all in cases eg:- not 12 units of 250ml, so was 12 cases with x amount inside each case. Basically pallet was cases of goods a meter high.

Consignment #1

12 x 250ml UN1263 3.0 II (D/E) LQ
6 x UN1993 - Flamable Liquid NOS, 3.0 III (D/E) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
1 x 25ltr Thinners UN1263 3.0 II (D/E) HZ
12 x 500ml UN1993 Flamable Liquids NOS 3.0 III (D/E) LQ
12 x 250ml UN3269 Polyester Resin 3.0 III (E) LQ
14 seperate items all UN1950 Aerosols (12x400ml) 2.1 (D) LQ

Consignment #2

UN2924 Flamable Liquid Corrosive NOS 3.0 (8) III (D/E) LQ
UN1950 Aerosols 12 x 500ml 2.1 (D) LQ
UN1993 Flamable Liquid NOS (12x5ltr) 3.0 III (D/E) LQ

Consignment #3

2 x 5ltr UN1263 3.0 II (D/E) HZ
2 x 5ltr UN1262 3.0 II (D/E) HZ
4 x 5ltr UN1263 3.0 II (D/E) LQ
12 x 500ml UN1950 Aerosols 2.1 (D) LQ
4 x 5ltr UN1993 Flamable Liquid NOS 3.0 III (D/E) LQ
1 x 25ltr UN1263 Thinners 3.0 II (D/E) HZ

Consignment #4

12 x 750ml UN1300 Turps 3.0 II (D/E) LQ
12 x 750ml UN3082 Environmental Hazardous Liquid NOS 9.0 III (E) LQ

Consignment #5

6 x 500ml UN1950 Aerosols 2.1 (D) LQ
12 x 500ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ

Consignment #6

4 x 5ltr UN1993 Flamable Liquid NOS 3.0 III (D/E) LQ
12 x 1ltr UN1993 (Oilylene/Heptane) 3.0 II LQ

• various others UN1263, UN1950, UN1300, UN1263 most 12 x 500ml LQ

I am having to trust the company I work for whether its classed as ADR or not as not qualified to say f it is or not.

i know it sounds like silly questions, but with so many vosa on the road these days always good to know the proper laws and regs so dont get caught out and its me as driver that gets blamed and responsible for any action they decide to take and company gets away scot free!!

[wheel_nut]

matthewjohnston:
when I did the adr course it was all mixed up, the screen did not work so he showed videos from day 3 on day 1 and day 1 was done on day 2 ets… still did full course but not in the proper order. He did explain things but maybe was not thorough enough in some aspects. The instructor did specifically say (maybe he was wrong), if you carry any goods that have a UN number on it whether package or drums etc then its automatic orange plate no matter what quantity, if it shows a UN number then it means it comes under adr regulations.

I am having to trust the company I work for whether its classed as ADR or not as not qualified to say f it is or not.

i know it sounds like silly questions, but with so many vosa on the road these days always good to know the proper laws and regs so dont get caught out and its me as driver that gets blamed and responsible for any action they decide to take and company gets away scot free!!

That isn’t your problem but the course should be structured

The LQ and HZ are packaged that way on purpose. Dave will be along with some thunder because I didn’t want to steal his

I would concur with Dave that the company are on the ball and the ADR trainer maybe wasn’t quite up to speed with things.

Do you know what my avatar means?

[44_tonne_ton]

Wheel Nut:

matthewjohnston:
when I did the adr course it was all mixed up, the screen did not work so he showed videos from day 3 on day 1 and day 1 was done on day 2 ets… still did full course but not in the proper order. He did explain things but maybe was not thorough enough in some aspects. The instructor did specifically say (maybe he was wrong), if you carry any goods that have a UN number on it whether package or drums etc then its automatic orange plate no matter what quantity, if it shows a UN number then it means it comes under adr regulations.

I am having to trust the company I work for whether its classed as ADR or not as not qualified to say f it is or not.

i know it sounds like silly questions, but with so many vosa on the road these days always good to know the proper laws and regs so dont get caught out and its me as driver that gets blamed and responsible for any action they decide to take and company gets away scot free!!

That isn’t your problem but the course should be structured

The LQ and HZ are packaged that way on purpose. Dave will be along with some thunder because I didn’t want to steal his

I would concur with Dave that the company are on the ball and the ADR trainer maybe wasn’t quite up to speed with things.

Do you know what my avatar means?

It’s the new sign for LQ. I was wondering why you chose that?

[dieseldave]

matthewjohnston:
As I am an agency driver although semi regular with the company dont want the company complaining I am an aqward driver and get less work or banned from site for complaining. I already complained about there being no spare digi tacho rolls in the cab and that did not go down well in transport office. Now I carry my own supply yet still no spares in cab, one vehicle I used did not even have a roll in the unit when i took it over.

Hi Matthew,
Could I suggest that the point you make about the spare rolls of printer paper for the digi-tacho would probably best be made in the Safety and Law forum or a separate post in this forum, where it will be seen and discussed by those better equipped than myself to answer that question??
Those folks may not look at this because of the post title.

matthewjohnston:
the first part you highlighted, i only show orange plates if it says ADR on the loading sheet, basically the sheet with the delivery addresses and pallet amounts, it will either say ADR or Non-ADR at the top, so depending on what that says is what I show or dont show.

Now here’s where I’m a little unsure because of the terminology that you (or the company) are using.
When it says ADR, does that mean that ADR applies in full, or does it mean that what you’re carrying counts towards the ADR load threshold limits for the relevant transport category?
It’s this “HZ” thing that’s throwing me at the moment, cos that’s not in ADR.

matthewjohnston:
when I did the adr course it was all mixed up, the screen did not work so he showed videos from day 3 on day 1 and day 1 was done on day 2 ets… still did full course but not in the proper order. He did explain things but maybe was not thorough enough in some aspects. The instructor did specifically say (maybe he was wrong), if you carry any goods that have a UN number on it whether package or drums etc then its automatic orange plate no matter what quantity, if it shows a UN number then it means it comes under adr regulations.

Sorry Matthew, but if the instructor said that, then he absolutely hasn’t a clue.

matthewjohnston:
All the cabs have a copy of the laminated INW in them as any can be used for ADR and all drivers trained in it. I did presume they were current but only by chance did I look at a website and thought that looks different than what I have. It seems they have not replaced any of them, you would think they would know its been updated.

Every transport company who sends or transports dangerous goods in scope of ADR must have a properly qualified DGSA, and you and your boss are both supposed to know who that is and be able to ask that person ADR-related questions.

matthewjohnston:
But as long as it does not have to be laminated I can print it off myself so at least its current and legal. But will still let them know but wether they listen is another matter, you say stuff to them and it goes in one ear and straight out other. I reported several minor faults with vehicles thats never been fixed, they nothing major but could cause problems in long term.

I can confirm that ADR contains NO requirement that the IIW has to be laminated.
I can also confirm that the old version of the IIW is now out of date and should have been replaced by 30/06/2011 at the very latest.
The new (2011) version has the ‘fish and tree’ sign and also the red triangular ‘hot mark’ at the top of page #4, whereas the old (2009) version did not.

matthewjohnston:
I will download this one
unece.org/fileadmin/DAM/tran … sh2011.pdf

Yes mate, that’s the one, but it’s the transport company’s job to deal with this, that’s why they’re required to appoint a DGSA whose duty it is to keep them up to speed with all aspects of ADR compliance.

matthewjohnston:
one thing that niggles me too is that during the adr course they said that the documents if carrying adr must be signed by the supplier/sender.

Giving the ADR instructor the benefit of the doubt for the moment… are you sure that your memory of this is to do with ADR, or could it be that the instructor was discussing a multi-modal dangerous goods transport document?
(Eg, maybe a dangerous goods shipping note [DGN] required by IMDG?)

matthewjohnston:
Basically the people i work ( cant say who they are incase one of them read this) for make and distribute the items themselves,

That’s fine mate and I completely understand why you wouldn’t wish to name them. However, they are NOT exempt from the requirement to appoint a properly qualified DGSA and do the ADR job properly even if they make and distribute their own goods. In some ways there’s even less excuse for any ignorance on their part, because they also amount to the ‘consignor,’ so they actually have even more responsibility than a company who only transports dangerous goods.

matthewjohnston:
The delivery notes I get are as follows.
Company name at top.
Billing address left, delivery address to right
then list of items, eg quantity, description of item with proper names, un number, packing group, tunnel code etc… (like list shown below)
bottom of sheet place for person receiving goods to sign and date and very bottom my company address. I keep top copy and return to office customer gets bottom copy.

thats all the sheet has, nothing else.

That info is slightly more than than the minimum info required by ADR, so your delivery notes seem OK to me.

matthewjohnston:
I did quickly write down a basic list of one days work that I delivered, the quantity was all in cases eg:- not 12 units of 250ml, so was 12 cases with x amount inside each case. Basically pallet was cases of goods a meter high.

Consignment #1

12 x 250ml UN1263 3.0 II (D/E) LQ
6 x UN1993 - Flamable Liquid NOS, 3.0 III (D/E) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ
1 x 25ltr Thinners UN1263 3.0 II (D/E) HZ
12 x 500ml UN1993 Flamable Liquids NOS 3.0 III (D/E) LQ
12 x 250ml UN3269 Polyester Resin 3.0 III (E) LQ
14 seperate items all UN1950 Aerosols (12x400ml) 2.1 (D) LQ

Consignment #2

UN2924 Flamable Liquid Corrosive NOS 3.0 (8) III (D/E) LQ
UN1950 Aerosols 12 x 500ml 2.1 (D) LQ
UN1993 Flamable Liquid NOS (12x5ltr) 3.0 III (D/E) LQ

Consignment #3

2 x 5ltr UN1263 3.0 II (D/E) HZ
2 x 5ltr UN1262 3.0 II (D/E) HZ
4 x 5ltr UN1263 3.0 II (D/E) LQ
12 x 500ml UN1950 Aerosols 2.1 (D) LQ
4 x 5ltr UN1993 Flamable Liquid NOS 3.0 III (D/E) LQ
1 x 25ltr UN1263 Thinners 3.0 II (D/E) HZ

Consignment #4

12 x 750ml UN1300 Turps 3.0 II (D/E) LQ
12 x 750ml UN3082 Environmental Hazardous Liquid NOS 9.0 III (E) LQ

Consignment #5

6 x 500ml UN1950 Aerosols 2.1 (D) LQ
12 x 500ml UN1950 Aerosols 2.1 (D) LQ
12 x 400ml UN1950 Aerosols 2.1 (D) LQ

Consignment #6

4 x 5ltr UN1993 Flamable Liquid NOS 3.0 III (D/E) LQ
12 x 1ltr UN1993 (Oilylene/Heptane) 3.0 II LQ

I’ve had a look at the six consignments that you’ve listed above.
From what you’ve written, my comments are:

• All the items with “LQ” written next to them DO NOT COUNT when calculating whether a load is subject to ADR or not.
• The items that I’ve coloured blue DO count towards whether ADR applies or not.
• The items coloured blue make a total of 70 liters.
• The ADR limit for the items coloured blue is 333 liters, so ADR does NOT apply in full to this load.
• Therefore; you could, if you/the company wish, load another 263 liters of this transport category of dangerous goods (TC 2) and still NOT be in-scope of full ADR.

matthewjohnston:

• various others UN1263, UN1950, UN1300, UN1263 most 12 x 500ml LQ

Again, anything that is LQ doesn’t ever count towards whether ADR applies in full.

matthewjohnston:
I am having to trust the company I work for whether its classed as ADR or not as not qualified to say f it is or not.

Up to now, and from what you’ve written, I’d say that it sounds like the company seem to know the score when it comes to knowing whether ADR applies in full or not.
IF ADR doesn’t apply in full there’s no need to display the orange plates, nor do you need to carry your ADR licence, nor do you need the IIW. Those things only become a requirement when ADR does apply in full.

matthewjohnston:
i know it sounds like silly questions, but with so many vosa on the road these days always good to know the proper laws and regs so dont get caught out and its me as driver that gets blamed and responsible for any action they decide to take and company gets away scot free!!

It’s not silly questions at all mate.
However, you (and possibly your ADR instructor ) are quite wrong about who is responsible for what though, cos the whole of what’s being discussed here is a joint responsibility between the consignor and the carrier. Your employer meets BOTH of these definitions, and there’s nothing you’ve mentioned so far that’s actually your responsibility.

Further to your original question… you can leave the orange boards folded when carrying the load mentioned above, because ADR doen’t apply in full.

Sometimes, it’s actually good when you’re wrong about something eh??

I hope this helps.