ADR or not

Was due to take a trailer containing pump equipment today from Wakefield to Great Yarmouth, but when I got to the customer it had changed to a 20 foot tanktainer that was, according to the customer, clean and therefore wouldn’t need adr boards up. (They blanked off the boards with UN 1977 on them, which is liquid nitrogen.)

When I get there, I’m to wait while the guys down there transfer a similar tanktainer containing liquid nitrogen into the tank I’ve just brought down, and then bring the now empty tank back, and again the boards are blanked off.

Now I am convinced that this is illegal, as there would still be residue in the now empty tank and it would be ‘in scope’, but they tell me that as long as it’s vented to air, the liquid turns to gas and goes into the atmosphere, the result being that the nitrogen cleans the tank out, and no boards needed.

Who’s right and who’s wrong here?

I need a definitive answer on this one, as if what I suspect is correct, then the agency will be getting my wrath over it.

By the way, I no longer have my adr before anyone asks, as I let it lapse about 4 years ago.

Ken.

I wouldn’t have tought it was hazardous.
The hazardous thing about liquid nitrogen is that it has a very low temperature. Nitrogen as a gas is inert, and 70% of air is nitrogen. Aircraft and race cars have nitrogen filled tyres, hardly a good idea if it’s hazardous.

muckles:
Aircraft and race cars have nitrogen filled tyres

And my car.

On topic though, if it has a UN number and was in a bulk tank, then it should be ADR until the tank has been cleaned. I may be wrong but I doubt it.

muckles:
I wouldn’t have tought it was hazardous.
The hazardous thing about liquid nitrogen is that it has a very low temperature. Nitrogen as a gas is inert, and 70% of air is nitrogen. Aircraft and race cars have nitrogen filled tyres, hardly a good idea if it’s hazardous.

A lot of trucks too.

Quinny:
I need a definitive answer on this one, as if what I suspect is correct, then the agency will be getting my wrath over it.

Hi Ken,

In most instances a 20’ tank container (being >3,000 liters) is normally ‘in scope’ when empty, but uncleaned as you said.

However, please rest easy mate, cos I make it that the customer was correct because of a perfectly legitimate exemption contained in ADR.

Here’s how:

Exemptions related to the carriage of gases
The provisions laid down in ADR do not apply to the carriage of:

ADR 2011 1.1.3.2(c) Gases of Groups A and O if the pressure of the gas in the
receptacle or tank at a temperature of 20 °C does not exceed 200 kPa (2 bar) and if the gas is not a liquefied or a refrigerated liquefied gas. This includes every kind of receptacle or tank, e.g. also parts of machinery and apparatus;

Note: In the above exemption, nitrogen is a gas of group “A.” (“A” = asphyxiant.)

Before they depressurised the tank, you would have been subject to ADR even when empty, because you would have indeed been carrying:
UN 1977 NITROGEN, REFRIGERATED LIQUID, 2.2

However, once they depressurised the tank sufficiently and the remaining liquid nitrogen ‘boiled off’ and reverted to being just a vapour, it then became plain ordinary:
UN 1066 NITROGEN, COMPRESSED, 2.2
Then, when there’s no remaining liquid nitrogen and the tank is depressurised to <2bar, you’re able to take advantage of the quoted exemption without being in scope of ADR.

This is the only bit that they got wrong.

the result being that the nitrogen cleans the tank out

The reason they’re wrong is that the tank wouldn’t contain clean fresh air.
Instead, there’d be nitrogen at atmospheric pressure, but that’s clearly allowed by the exemption. :wink:

muckles:
I wouldn’t have tought it was hazardous.
The hazardous thing about liquid nitrogen is that it has a very low temperature. Nitrogen as a gas is inert, and 70% of air is nitrogen. Aircraft and race cars have nitrogen filled tyres, hardly a good idea if it’s hazardous.

Hi muckles,

Nitrogen is definitely dangerous goods, there’s no question about it.

The danger from nitrogen is that it belongs to a group of gases known as “asphyxiant” gases, which are carried in UN Class 2.2. (ADR calls them “group ‘A’ gases.”)
Other examples of asphyxiant gases in Class 2.2 are carbon dioxide, helium and argon, but there are a number of others.

john_costigan:

muckles:
Aircraft and race cars have nitrogen filled tyres

And my car.

Hi John,

I’m able to offer you and muckles a different exemption for those items:

Exemptions related to the carriage of gases
The provisions laid down in ADR do not apply to the carriage of:
ADR 2011 1.1.3.2(d) Gases contained in the equipment used for the operation of the vehicle (e.g. fire
extinguishers), including in spare parts (e.g. inflated pneumatic tyres); this exemption also applies to inflated pneumatic tyres carried as a load

ADR regulates the transport of dangerous goods by road, so as a general rule, dangerous goods used in connection with the functioning of the vehicle are exempt.
:bulb: If that weren’t the case, then just about every motorised vehicle on the road would need orange plates just because of the fuel in its own tank.

john_costigan:
On topic though, if it has a UN number and was in a bulk tank, then it should be ADR until the tank has been cleaned. I may be wrong but I doubt it.

You’d be correct in the vast majority of instances when it comes to the question of ADR applying (in full) to the moving of empty but uncleaned tanks on the roads, but on this occasion the customer was correct.
:bulb: For exactly the reason you gave, I’ll add that I completely understand why Ken had his doubts.

dieseldave:
This is the only bit that they got wrong.

the result being that the nitrogen cleans the tank out

The reason they’re wrong is that the tank wouldn’t contain clean fresh air.
Instead, there’d be nitrogen at atmospheric pressure, but that’s clearly allowed by the exemption. :wink:

But it is badly wrong Dave, as you mentioned asphyxiant gas.

The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) and decides to stick his head inside to see how they work :open_mouth:

Composition of “air” Nitrogen 78% Oxygen 21% Argon 1%

After discharging a tank of IPA and using a nitrogen blanket, the tank is empty but still unclean. It was suggested that Bob Hurst from Castleford died in Marl Germany because of this misunderstanding.

Wheel Nut:

dieseldave:
This is the only bit that they got wrong.

the result being that the nitrogen cleans the tank out

The reason they’re wrong is that the tank wouldn’t contain clean fresh air.
Instead, there’d be nitrogen at atmospheric pressure, but that’s clearly allowed by the exemption. :wink:

But it is badly wrong Dave, as you mentioned asphyxiant gas.

The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) and decides to stick his head inside to see how they work :open_mouth:

Composition of “air” Nitrogen 78% Oxygen 21% Argon 1%

After discharging a tank of IPA and using a nitrogen blanket, the tank is empty but still unclean. It was suggested that Bob Hurst from Castleford died in Marl Germany because of this misunderstanding.

That’s a very fair point Malc, and the dangers of asphyxiation are very commonly misunderstood.
Nitrogen is commonly used as a ‘gas blanket’ to prevent flammable atmospheres from forming.
For instance, Propane tanks are emptied of propane, then purged with nitrogen, then welding or other hot work can be safely carried out without fear of an explosion, because nitrogen contains no oxygen.
I’m keeping this one on-topic though, because Ken’s OP wasn’t speaking of a nitrogen ‘blanket.’

Nitrogen is correctly said to be an ‘inert’ gas, so it’s neither toxic, nor flammable nor reactive in a chemical sense.

I have some American figures that suggest the extent of the lack of understanding of the dangers of nitrogen asphyxiation. The figures come from OSHA (= similar to the HSE in the UK.)

Nitrogen incident statistics.jpg

Going back to the OP, Ken was asked to move a depressurised tank that had contained refridgerated/pressurised nitrogen, which is subject to a perfectly legitimate ADR exemption.
In the normal way of ADR, anybody could be forgiven for remembering that any residue of dangerous goods remaining in a tank, would therefore mean that carriage by road is subject to full ADR as a result.

However, even if the tank is fully depressurised right to the point where it’s at atmospheric pressure, most people don’t realise what’s actually in the tank at that time.
The answer is that there would still be pure nitrogen, but at atmospheric pressure.
:bulb: It certainly wouldn’t mean that the atmosphere inside the tank is breathable. For the atmosphere to be breathable, the nitrogen atmosphere would first need to be purged/ventilated with fresh air and the % confirmed by a properly certificated gas analysis device.

:bulb: Although the normal air we breathe contains 21% oxygen, humans can encounter breathing difficulties if the oxygen level drops (for whatever reason) to approx 19% (or less.)

Wheel Nut:
The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) :
.

None taken. :laughing: :laughing:

Thanks for the answers guys, I now know that in future, it will be safe to pull the empty tank and that the blanking off of the boards is ok.

Mind you, the 15 hour shift I got off the back of it was a Brucie bonus as well… :smiley:

Just as an added piece of info, the tank WAS at 0 bar pressure once emptied, as I checked the gauge myself.

Ken.

dieseldave:

muckles:
I wouldn’t have tought it was hazardous.
The hazardous thing about liquid nitrogen is that it has a very low temperature. Nitrogen as a gas is inert, and 70% of air is nitrogen. Aircraft and race cars have nitrogen filled tyres, hardly a good idea if it’s hazardous.

Hi muckles,

Nitrogen is definitely dangerous goods, there’s no question about it.

The danger from nitrogen is that it belongs to a group of gases known as “asphyxiant” gases, which are carried in UN Class 2.2. (ADR calls them “group ‘A’ gases.”)
Other examples of asphyxiant gases in Class 2.2 are carbon dioxide, helium and argon, but there are a number of others.

I’m well aware of the dangers of asphyxiation, I wasn’t aware it was still an ADR issue. I thought the ADR issue was purely the way an inert gas was stored, i.e. Under pressure or at such a low temperature it would cause death or major injury to anybody who came into contact with it.

Wheel Nut:
The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) and decides to stick his head inside to see how they work :open_mouth:

I’m sure this goes without saying, but sticking your head in a tank, even an empty one, without taking all necessary precautions is never a good thing, and could end quite messily

plannerman:

Wheel Nut:
The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) and decides to stick his head inside to see how they work :open_mouth:

I’m sure this goes without saying, but sticking your head in a tank, even an empty one, without taking all necessary precautions is never a good thing, and could end quite messily

But you know what drivers are? otherwise why as plannerman would you treat them all like children?

muckles:

dieseldave:

muckles:
I wouldn’t have tought it was hazardous.
The hazardous thing about liquid nitrogen is that it has a very low temperature. Nitrogen as a gas is inert, and 70% of air is nitrogen. Aircraft and race cars have nitrogen filled tyres, hardly a good idea if it’s hazardous.

Hi muckles,

Nitrogen is definitely dangerous goods, there’s no question about it.

The danger from nitrogen is that it belongs to a group of gases known as “asphyxiant” gases, which are carried in UN Class 2.2. (ADR calls them “group ‘A’ gases.”)
Other examples of asphyxiant gases in Class 2.2 are carbon dioxide, helium and argon, but there are a number of others.

I’m well aware of the dangers of asphyxiation, I wasn’t aware it was still an ADR issue. I thought the ADR issue was purely the way an inert gas was stored, i.e. Under pressure or at such a low temperature it would cause death or major injury to anybody who came into contact with it.

Hi muckles,
The dangers you’ve mentioned are very real indeed and cannot be ovelooked.

However (and this might sound somewhat technical,) I was speaking of the absolute basics of classification. Starting right from scratch, nitrogen has the ADR classification code of “A,” which means that its primary danger is asphyxiation. This places nitrogen in UN Class 2.2 for that reason alone. The other dangers that you mentioned then come into play if applicable.

When I addressed the precise issue raised in Ken’s question, I had to leave pressure and temperature out of the mix, because Ken said that they were no longer a factor.

plannerman:

Wheel Nut:
The customer told the driver it was “clean,” so the driver is a nosey little beggar (not Quinny) and decides to stick his head inside to see how they work :open_mouth:

I’m sure this goes without saying, but sticking your head in a tank, even an empty one, without taking all necessary precautions is never a good thing, and could end quite messily

Hi plannerman,

You’re spot-on mate, and there’s plenty of evidence that people have done exactly what you said should go without saying.

Sticking your head in any tank is really not a good idea, because there’s probably not a breathable atmosphere in there. Asphyxiation is a silent killer and there are many gases/vapours that don’t have an odour to warn us of their presence.

There are proper tank entry procedures, which if followed by correctly trained people, allow workers to enter tanks safely.

That is just one reason why i no longer have an adr licence :confused: To much hassle :unamused: