Evening lads and lasses.
Got sent for a collection after I had done my shops this morning, didnt know what it was till I got there turned out it was Aerosol spray paint.
Eventually after being loaded I had 22 pallets with just over 50, 000 aerosols on board now work is only 10 miles away but aerosols are aerosols and given a hit do go with a bang, I would have thought you need adr to move that many as its still pressurised gas.
Jeff.
I, before doing an ADR course, was just like you, worrying about what was and wasn’t ADR…
Now, the 1 thing I learnt during a week long course was, it’s not your job to know what is and isn’t ADR, so don’t worry about it.
If you’ve not been told that you’re in scope, then just secure it as normal and crack on 
nope …comes under limited quantity’s
Thanks lads was a “is it or isnt it moment” 
Daytrunker:
Thanks lads was a “is it or isnt it moment”
As Dieseldave explained it to me, there’s so many different products - probably thousands - some are ADR all the time, some are sometimes. There’s stuff you can’t carry together, stuff you can carry in same trailer but must be segregated, and stuff that doesn’t matter. etc etc…
We are but drivers, we can’t possibly know all this, there’s a guy being paid mega bux - either in your firm or your firm pays him - to know this ■■■■, and if it goes wrong, it’s him who pays the price.
So, as I said before, don’t worry about it
It’d be better if we knew this ■■■■ without doing an ADR course though, since once you’ve done one, you’ve got your ADR only to find you didn’t need it all those times you were unsure 
Liited quantities chap. It’s all down to the individual container size. If it was a tanker full of pressurised gas or paint it’d be ADR, but little tins… no problem.
Much the same as Hazardous goods in machinery (e.g. fuel in the tank of a vehicle), bloody big petrol tanker… ADR required,
but you don’t need an ADR licence to drive a car transporter !!!
I had that quandary, carrying 12t of fork lift truck batteries, full of acid and a fair bit of lead, seems its a limited amount but the debate is still raging on in work
Though should the batteries actually be in the flt’s its classed as fuel for the accompanying vehicle and is fine 
In a similar vein, saw a fuel tanker on suspended tow on the M25 the other day. Does the recovery driver need an ADR licence, or is the fact that the tanker driver was in the cab with him make it OK.
trucken:
In a similar vein, saw a fuel tanker on suspended tow on the M25 the other day. Does the recovery driver need an ADR licence, or is the fact that the tanker driver was in the cab with him make it OK.
Recovery is exempt. I’ve recovered all sorts including an ambulance, but I wasn’t a train paramedic 
What you would normally try and do though, if it was an artic fuel tanker, is see if you could get another pet-reg vehicle to take the tanker, but not always possible, especially if on a motorway, very limited time to shift it.
Daytrunker:
Eventually after being loaded I had 22 pallets with just over 50, 000 aerosols on board now work is only 10 miles away but aerosols are aerosols and given a hit do go with a bang, I would have thought you need adr to move that many as its still pressurised gas.
Hi Jeff,
You can rest easy mate, cos those who have said it’s Limited Quantities (LQs) and so no ADR is needed are correct.
I’d add that in this case, the distance to be travelled isn’t a relevant factor.
The LQ rules for the aerosols you carries are that each aerosol can’t be bigger than 1 L, and the boxes can’t weigh more than 30Kg.
You need to mark a vehicle carrying LQs in the following circumstances…
IF your permitted GVW is >12t AND you are carrying >8t of LQ goods, then you need to mark the vehicle with either two orange plates (front and rear) OR two LQ placards (front and rear.)
LQ Placard (250mm X 250mm)
trucken:
In a similar vein, saw a fuel tanker on suspended tow on the M25 the other day.Does the recovery driver need an ADR licence, …
Hi trucken,
In normal circumstances, the recovery driver needs an ADR licence.
trucken:
… or is the fact that the tanker driver was in the cab with him make it OK
No mate, that’s a very common ADR myth. Those are the rules for a qualified driver supervising a learner driver.
ADR makes it plain that “the driver shall hold a certificate…” The key word is “driver” so when being carried in a recovery vehicle, the tanker driver is simply a passenger.
Drift:
I had that quandary, carrying 12t of fork lift truck batteries, full of acid and a fair bit of lead, seems its a limited amount but the debate is still raging on in work
Hi Drift,
There’s no need for quandary and/or debate about the carriage of ‘wet’ batteries…
ADR regards batteries as ‘articles’ (= not a substance) so we reckon them quite simply by their net weight, regardless of trying to work out how much lead/acid is in them.
There’s also absolutely no connection to limited amount or limited quantity, so the debate is a lot less confusing once we know we can ignore irrelevant stuff like that.
ADR has a Special Provision (SP) which applies to the carriage of ‘wet’ batteries.
SP 598 The following are not subject to the requirements of ADR:
(a) New storage batteries when:
- they are secured in such a way that they cannot slip, fall or be damaged;
- they are provided with carrying devices, unless they are suitably stacked, e.g. on pallets;
- there are no dangerous traces of alkalis or acids on the outside;
- they are protected against short circuits;
(b) Used storage batteries when:
- their cases are undamaged;
- they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
- there are no dangerous traces of alkalis or acids on the outside of the articles;
- they are protected against short circuits.
"Used storage batteries" means storage batteries carried for recycling at the end of their normal service life.
So, just to be clear… you can carry ‘wet’ batteries in any size/amount without ADR provided that the above is complied with.
If the above is not complied with, then you can carry up to and including 1,000 Kgs of them without an ADR licence, but you would need a 2Kg ADR compliant fire extinguisher.
If the above is not complied with, and you need to carry more than 1,000 Kgs of them, then all applicable provisions of ADR will apply, such as ADR licence, orange plates, documentation, vehicle equipment and fire extinguishers etc.
Drift:
Though should the batteries actually be in the flt’s its classed as fuel for the accompanying vehicle and is fine
The principle is correct but this is what ADR says about that exemption:
ADR 1.1.3.1(b)
The provisions laid down in ADR do not apply to:
(b) The carriage of machinery or equipment not specified in this Annex and which happen to contain dangerous goods in their internal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage;
There is another exemption for liquid fuels, but it’s a different exemption to the one you’ve mentioned for a battery in an FLT.
Thank you all for the advice much appreciated 
dieseldave:
Drift:
I had that quandary, carrying 12t of fork lift truck batteries, full of acid and a fair bit of lead, seems its a limited amount but the debate is still raging on in workHi Drift,
There’s no need for quandary and/or debate about the carriage of ‘wet’ batteries…
ADR regards batteries as ‘articles’ (= not a substance) so we reckon them quite simply by their net weight, regardless of trying to work out how much lead/acid is in them.
There’s also absolutely no connection to limited amount or limited quantity, so the debate is a lot less confusing once we know we can ignore irrelevant stuff like that.ADR has a Special Provision (SP) which applies to the carriage of ‘wet’ batteries.
SP 598 The following are not subject to the requirements of ADR:
(a) New storage batteries when:
- they are secured in such a way that they cannot slip, fall or be damaged;
- they are provided with carrying devices, unless they are suitably stacked, e.g. on pallets;
- there are no dangerous traces of alkalis or acids on the outside;
- they are protected against short circuits;
(b) Used storage batteries when:
- their cases are undamaged;
- they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
- there are no dangerous traces of alkalis or acids on the outside of the articles;
- they are protected against short circuits.
"Used storage batteries" means storage batteries carried for recycling at the end of their normal service life.
So, just to be clear… you can carry ‘wet’ batteries in any size/amount without ADR provided that the above is complied with.
If the above is not complied with, then you can carry up to and including 1,000 Kgs of them without an ADR licence, but you would need a 2Kg ADR compliant fire extinguisher.
If the above is not complied with, and you need to carry more than 1,000 Kgs of them, then all applicable provisions of ADR will apply, such as ADR licence, orange plates, documentation, vehicle equipment and fire extinguishers etc.
Drift:
Though should the batteries actually be in the flt’s its classed as fuel for the accompanying vehicle and is fineThe principle is correct but this is what ADR says about that exemption:
ADR 1.1.3.1(b)
The provisions laid down in ADR do not apply to:
(b) The carriage of machinery or equipment not specified in this Annex and which happen to contain dangerous goods in their internal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage;
There is another exemption for liquid fuels, but it’s a different exemption to the one you’ve mentioned for a battery in an FLT.
Cheers Dave, very informative and helpful
Drift:
Cheers Dave, very informative and helpful
Hi Drift,
I aim to help, so here’s a little extra…
When you carry ‘wet’ batteries in compliance with the above, it might be an idea to have something like this written on the paperwork…
“Carriage not subject to ADR by reason of ADR SP 598”, or similar wording.
That way, any roadside spot-checks will take only a minimal amount of time because your paperwork gives them something to reference.
SP 598 can only apply once the conditions attaching to it (as above) are fully complied with, so it’s a useful exemption to know if you carry ‘wet’ batteries often or in large amounts.
Thanks again Dave
I often carry narrow aisle batteries weighing in around 2t each so this is great info that I will print off and keep with me in my folder.
At risk of hijacking the thread a bit more would the same be applicable to gas bottles?
We often carry up to four or five usually with a flt on board, would this be the ruling they are used as a fuel source for the vehicle being delivered so it would be exempt?
Occasionally I also deliver drums of red diesel 25l x6 to one of our depots.
Sorry for nicking your brain power but this is good and interesting stuff for me
Cheers.
dieseldave:
trucken:
In a similar vein, saw a fuel tanker on suspended tow on the M25 the other day.Does the recovery driver need an ADR licence, …
Hi trucken,
In normal circumstances, the recovery driver needs an ADR licence.
trucken:
… or is the fact that the tanker driver was in the cab with him make it OKNo mate, that’s a very common ADR myth. Those are the rules for a qualified driver supervising a learner driver.
ADR makes it plain that “the driver shall hold a certificate…” The key word is “driver” so when being carried in a recovery vehicle, the tanker driver is simply a passenger.
Thanks Dave. It was just one of those situations where you see something and think, I wonder if…
Drift:
Thanks again Dave
I often carry narrow aisle batteries weighing in around 2t each so this is great info that I will print off and keep with me in my folder.
Hi Drift,
If those 2t batteries are ‘wet’ and the provisions of SP 598 are complied with, then you’re good to go with as many of them as you like.
Drift:
At risk of hijacking the thread a bit more would the same be applicable to gas bottles?
We often carry up to four or five usually with a flt on board, would this be the ruling they are used as a fuel source for the vehicle being delivered so it would be exempt?
Sorry mate, 'fraid not.
You need a different exemption for the (propane) gas bottles.
That exemption is based simply on the amount carried.
The exemption limit for propane is 333Kgs net, so you ONLY count the net contents of the cylinders for ADR purposes.
If you use this exemption, adding the following to your paperwork might keep any stop/checks to a minimum time…
“Carriage in accordance with ADR 1.1.3.6” (Don’t forget your ADR compliant 2kg extinguisher!!)
If an FLT happens to have a gas cylinder attached and connected, then you can look upon that as a freeby.
Drift:
Occasionally I also deliver drums of red diesel 25l x6 to one of our depots.
Sorry for nicking your brain power but this is good and interesting stuff for me
This one uses the same exemption, but the limit is more generous for diesel fuel at 1,000L, so your 25L x6 isn’t anywhere near being a problem.
If you use this exemption, adding the following to your paperwork might keep any stop/checks to a minimum time…
“Carriage in accordance with ADR 1.1.3.6” (Don’t forget your ADR compliant 2kg extinguisher!!)
It gets a little trickier if you need to carry some propane and some diesel at the same time, so because of the different limits there is then a little calculation to perform.
It is possible to carry both at the same time and still escape ADR though.
trucken:
It was just one of those situations where you see something and think, I wonder if…
Hi trucken,
Yes mate, it’s one of the most commonly asked questions and a very long standing ADR myth, but I can see how it got you and lots of other people to start wondering.