ADR Packaging and labelling

I am slightly confused by this. It may be even simpler that what I think even. I see that for the different categories there are different amounts allowed to be carried in order to be exempted from ADR rules

Category 4 - Unlimited amount
Category 3 - up to 1000 kgs
Category 2 - up to 333 kgs
Category 1 - up to 20 kgs
Category 0 - 0 kgs

So, for example, if 900 kgs under Transport Category 3 are transported on a vehicle then no ADR labelling is required? But I read in my book that all vehicles carrying ADR goods must display an orange rectangle at the front of the vehicle. I also read that any vehicle carrying goods under Packaging groups 1,2 or 3 (this corresponds to Categories 1 to 3 above) must also have an orange rectangle to the rear. I’m not seeing an exemption if you like. Can anybody help here?

I do have one or two other questions.

dieseldave is ye man he’ll be along in a bit. :wink:

m.a.n rules:
dieseldave is ye man he’ll be along in a bit. :wink:

Thanks. There’s no panic.

Mooping:
I am slightly confused by this. It may be even simpler that what I think even. I see that for the different categories there are different amounts allowed to be carried in order to be exempted from ADR rules

Category 4 - Unlimited amount
Category 3 - up to 1000 kgs
Category 2 - up to 333 kgs
Category 1 - up to 20 kgs
Category 0 - 0 kgs

Hi Mooping,

You’re sort of correct so far, but…

When carrying amounts indicated above (or less) then you’re only exempt from the main provisions of ADR.

You will still need:

  • 1 x 2kg ADR compliant fire extinguisher
  • Some kind of documented ADR awareness training

Mooping:
So, for example, if 900 kgs under Transport Category 3 are transported on a vehicle then no ADR labelling is required? But I read in my book that all vehicles carrying ADR goods must display an orange rectangle at the front of the vehicle. I also read that any vehicle carrying goods under Packaging groups 1,2 or 3 (this corresponds to Categories 1 to 3 above) must also have an orange rectangle to the rear. I’m not seeing an exemption if you like. Can anybody help here?

Firstly, what book are you reading?
I’m not quite sure what you mean by "ADR labelling?

Mooping:
I do have one or two other questions.

Your confusion is caused by the book, or the reader of the book. :laughing: :wink: :smiley:

:bulb: Just as a little pointer… if you’re an employed driver, then this isn’t your problem.

I was reading the Clive Pidgeon book ‘A Study Guide for the Operator Cert of Professional Competence’.

I’ll be back later probably tomorrow for my next question. Thanks for that DieselDave.

Mooping:
I was reading the Clive Pidgeon book ‘A Study Guide for the Operator Cert of Professional Competence’.

I’ve not read that book.
I sometimes teach the dangerous goods (ADR) part of Operator CPC, but everybody that I’ve taught that for uses EOS.
Not that it’s a problem though, because the dangerous good questions (if you get any) aren’t too difficult…

I’ll try to clarify what’s been written so far.
You’ve already got the answer to what’s needed when you’re carrying at or less than the limits for the relevant ADR Transport Categories that you’ve correctly identified. So in the example you gave (900kg of substances in ADR Transport Category 3,) you only need what I’ve mentioned in the two bullet points in my post above.

========================

Let’s now imagine that you’re to carry 1,100kg of the same stuff…

That total exceeds the ADR Transport Category vehicle load limit, so all applicable rules apply, so you’ll then need…
(These are the main ones you might be asked for in the exam, but there are a few more in real life.)

  • An ADR trained driver, who has their ADR card on board the vehicle.
  • The same fire extinguisher as in my earlier bullet point above PLUS a second ADR compliant fire extinguisher to give the required total amount of extinguishant for the vehicle’s permitted GVW
  • An ADR compliant Transport Document (= delivery note)
  • Instructions in Writing (IIW) in case of accident/emergency
  • The vehicle equipment and PPE specified in the IIW for the Class of dangerous goods being carried
  • A reflective orange plate is to be displayed at the front AND at the rear of the vehicle (so TWO plates both 40cm X 30cm)
  • Vehicle placards (25cm X 25cm) to be displayed on both sides and the rear for Classes 1 or 7 (so NOT needed for Classes 2,3,4,5,6,8 or 9 for a journey by road)
  • Your company would need to appoint a DGSA

As I said, I’ve only covered the main things that you’re likely to be asked in the exam you’re taking.

Mooping:
I’ll be back later probably tomorrow for my next question.

I might have already answered it, but fire away! :grimacing:

Dont know about his, but you’ve answered one of my main confusions and I’ve done the 5 day ADR course, so dont worry Mooping if you forget a few bits. :slight_smile:

Would be surprised if it doesnt ask about limited quantity items and the requirements for that, eg: supermarkets.

trevHCS:
Dont know about his, but you’ve answered one of my main confusions and I’ve done the 5 day ADR course, so dont worry Mooping if you forget a few bits. :slight_smile:

Hi trevHCS,

The dangerous goods questions for the Operator CPC exam are different to the exam questions you did when you took your ADR course in that they’ll need written answers if it comes in the case study.

trevHCS:
Would be surprised if it doesnt ask about limited quantity items and the requirements for that, eg: supermarkets.

That’s a possibility!!

OK thank you.

Now I come to the next bit I’m a little unsure about which is ‘Limited Quantities’. Do ‘Limited Quantities’ packaging tie in with the ‘Transport Categories’? I mean how are the different dangerous goods decided upon how to carry them and in what kind of packages? My notes say that when goods are put into small packages which are then placed in overpacks or cartons then many ADR rules don’t apply? What determines the size of the packages acceptable or does this tie in with the amounts in the ‘Transport Categories’. I see there’s no exemption for marking once the vehicle GVW exceeds 12 tonnes and the dangerous goods exceeds 8 tonnes. Sorry if they are foolish questions but sometimes things aren’t clear because you try to over complicate or have overlooked something then it clicks when you get the answer from another source/angle. Thanks.

Mooping:
Now I come to the next bit I’m a little unsure about which is ‘Limited Quantities’. Do ‘Limited Quantities’ packaging tie in with the ‘Transport Categories’?

Hi Mooping,

NO mate, the ADR Transport Categories are to do with the total load of dangerous goods on the vehicle when the dangerous goods are packaged in ‘normal’ packages such as Drums, Boxes, IBCs, jerricans etc.

The concept of Limited Quantities (LQs) is best thought of as the type of dangerous goods that one can quite legally buy in a retail shop, AND when packed in the form that you’d expect to see in a retail shop.

These are two completely different exemptions, and they’re used for completely different purposes.

Mooping:
I mean how are the different dangerous goods decided upon how to carry them and in what kind of packages?

Initially, this all comes from a customers enquiry to the factory that manufactures the dangerous goods.
Then the factory (the consignor) packages up the goods according to the customer’s order, provided that it’s legal under ADR.
This is one of the reasons for the ADR requirement for consignors and carriers both to have a qualified DGSA, whose job it is to monitor and advise the company on such things. (And plenty else besides!!)

Mooping:
My notes say that when goods are put into small packages which are then placed in overpacks or cartons then many ADR rules don’t apply?

The dangerous goods that can be bought by the public in a retail shop all have permitted LQ inner packaging sizes. Typically, these inner packaging sizes depend on the exact substance and vary between 100ml - 5L, which must be packaged into a fibreboard (=ADR’s word for cardboard) and an overall mass not exceeding 30kg. The only permitted variant is when a stretch-wrapped tray is used, such as the way that aerosols are carried. A stretch wrapped tray cannot exceed 20kg.
(I’ve only given you the sizes as a guideline, you won’t be asked for this kind of detail in the exam. :wink: )

Once the dangerous goods are packaged as LQs as I’ve described above, then we can carry that load under the rules that apply to LQs.
In this case, the driver only needs:

  • Some ADR ‘awareness’ training that has been documented. (NOT an ADR licence, regardless of the amount carried.)
  • A vehicle whose permitted GVW exceeds 12t is required to display an LQ placard (25cm X 25cm) on the front and rear of the vehicle.

LQ placard

LQ.gif

Mooping:
What determines the size of the packages acceptable or does this tie in with the amounts in the ‘Transport Categories’.

As above, but there is no connection to Transport Categories.

Mooping:
I see there’s no exemption for LQ marking once the vehicle GVW exceeds 12 tonnes and the dangerous goods exceeds 8 tonnes.

Correct, but I added the red bit to avoid confusion.

:bulb: The orange plates are only used when a load packaged in a ‘normal’ way (= NOT packaged as LQs :wink: ) exceeds the relevant Transport Category vehicle load limit.

Mooping:
Sorry if they are foolish questions but sometimes things aren’t clear because you try to over complicate or have overlooked something then it clicks when you get the answer from another source/angle. Thanks.

As long as that other source isn’t an RDC waiting room, then you’re in with a shout at getting a correct answer. :smiley:

The next question that you might not have thought of yet…

Q: What happens when a vehicle is already subject to orange plate rules, but some awkward sod sticks a few pallets of LQs on as well?

A: No action needs to be taken in regard to vehicle markings, just stick with the orange plates and crack on!!.

For the exam you’re taking, you need to understand the difference between the actions needed when carrying LQs, the actions needed when carrying at or below the relevant Transport Category load limit, and the actions needed when carrying a load which is subject to all ADR requirements, so I’d advise to read the bit in your book about the need for the driver to carry an ADR training certificate, fire extinguishers, IIW and PPE.

The CPC exam questions don’t go into detail about permitted package sizes or how a consignor chooses which packagings to use, because that’s the stuff of a DGSA exam and you’d need the two ADR books with you to answer that.

I hope this helps. :smiley:

Thank you DieselDave. That explanation clears things up for me. I need to digest it now.

Happy New Year!

dieseldave:
You will still need:

  • 1 x 2kg ADR compliant fire extinguisher

* Some kind of documented ADR awareness training

Oh yes Dave…this is another bit which raises a question as I carry ADR good and hold the card but I haven’t in the course of my work heard of this. Does this awareness training need to be offered by an external body or can it be something in-house as long as it’s documented?

Mooping:

dieseldave:
You will still need:

  • 1 x 2kg ADR compliant fire extinguisher

* Some kind of documented ADR awareness training

Oh yes Dave…this is another bit which raises a question as I carry ADR good and hold the card but I haven’t in the course of my work heard of this. Does this awareness training need to be offered by an external body or can it be something in-house as long as it’s documented?

Hi Mooping,

It can be done by an external body, my suggestion for this is that the driver sits in on day #1 of an ADR course, but just for DCPC purposes.
That way, the driver gets ‘documented’ proof that he’s ADR aware PLUS 7hrs towards his/her DCPC.
Days 2 and 3 of the same course can be used in the same way. (No ADR exams to sit.)

This training can be done in-house by somebody who knows what they’re on about, as long as it fits ADR’s required criteria.
The company’s DGSA will be able to advise the boss on this.
ADR ‘awareness’ might have been mentioned on the ADR course that you attended, but it’s easily forgotten once you have the ADR card.

Thank you DieselDave. I’m fine for now. :smiley: