Hi all.A question concerning adr.Do’es a full load of wet car batteries come under adr regulations.By wet i mean filled with acid.Our lot seem to think that it does’nt.So just asking from someone who def knows. 
i used to collect scrap batteries and wondered this myself so i phoned vosa or somebody(cant quite remember) if you are carrying over 8 tonne(might have been 6)the load comes under adr rules.i dont collect them any more so it`s no longer relevant to me
Batteries are class 8 Corrosive. Hope this helps.
markybhoy.
also if i remember right,you should have environment agency paperwork that permits you to transport them,
daftvader:
Hi all.A question concerning adr.Do’es a full load of wet car batteries come under adr regulations.By wet i mean filled with acid.Our lot seem to think that it does’nt.So just asking from someone who def knows.
Hi daftvader,
The carriage of batteries filled with acid (wet) comes up now and again, so to save me typing it all out again, please go to my answer to trigger near the bottom of this post:
In short, wet batteries are pretty much exempt from ADR if a few pre-conditions are complied with.
If anything is unclear after reading my link, please post up a question and I’ll answer it for you.
commonrail:
i used to collect scrap batteries and wondered this myself so i phoned vosa or somebody(cant quite remember) if you are carrying over 8 tonne(might have been 6)the load comes under adr rules.i dont collect them any more so it`s no longer relevant to me
Hi commonrail,
The 8 tonne (or 6) is nothing to do with ADR, but scrap batteries do come under the waste carriage Regs so a waste carrier’s licence would be needed.
markybhoy76:
Batteries are class 8 Corrosive. Hope this helps.markybhoy.
Hi markybhoy,
That’s correct mate and they also have a UN number, which depends on whether the batteries contain acid or alkali, but wet batteries aren’t subject to ADR if a few pre-conditions contained in a Special Provision (SP) in ADR are complied with.
That’s correct mate and they also have a UN number, which depends on whether the batteries contain acid or alkali, but wet batteries aren’t subject to ADR if a few pre-conditions contained in a Special Provision (SP) in ADR are complied with.
I’ll stand corrected and accept I did indeed learn something new today 
Cheers,
mark.
Hi diseldave.Thanks very much for that info.Spot on.They are all palletised and shrunk wrapped so ok to transport without adr then.Again thanks for clearing that up.
daftvader:
Hi diseldave.Thanks very much for that info.Spot on.They are all palletised and shrunk wrapped so ok to transport without adr then.Again thanks for clearing that up.
Hi daftvader,
Yes mate, no ADR licence or orange plates etc etc, so a nice easy job.
I’m glad to have helped.
Hi we regualy transport waste/scrap car batteries they do come under ADR unless you can comply with SPA 598a which is usually for new batteries where both the terminals are covered and between each layer of batteries there is a none conductive packaging ie cardboard and they are wrapped and strapped to a pallet or in a bin. Also if they are waste batteries you must have a waste carries lience and if you take them to Europe they must be moved on a TFS movement order. Also if transported in dolva bins they must be level loaded and covered to avoid contact with rain water.
Jwalker78:
Hi we regualy transport waste/scrap car batteries they do come under ADR unless you can comply with SPA 598a which is usually for new batteries where both the terminals are covered and between each layer of batteries there is a none conductive packaging ie cardboard and they are wrapped and strapped to a pallet or in a bin. Also if they are waste batteries you must have a waste carries lience and if you take them to Europe they must be moved on a TFS movement order. Also if transported in dolva bins they must be level loaded and covered to avoid contact with rain water.
Can I ask what a TFS order is please as I have carried many trailer loads of batteries from Europe to the UK
Wheel Nut:
Can I ask what a TFS order is please as I have carried many trailer loads of batteries from Europe to the UK
Hi Malc,
TFS = Trans Frontier Shipping, and it’s for the international carriage of wastes.
There’s quite a bit to plough through, but you can make a start here: 
Waste: export and import - GOV.UK
http://www.netregs.gov.uk/netregs/legislation/current/63614.aspx
I can only speak for what ADR says about the subject, cos I’m not qualified on wastes.
Jwalker78:
Hi we regualy transport waste/scrap car batteries they do come under ADR unless you can comply with SPA 598a which is usually for new batteries where both the terminals are covered and between each layer of batteries there is a none conductive packaging ie cardboard and they are wrapped and strapped to a pallet or in a bin.
Hi Jwalker78,
SP598(a) is indeed for new batteries.
There’s also SP598(b) which covers used batteries.
SP598 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… if the above is complied with, the batteries aren’t subject to the requirements of ADR.
Jwalker78:
Also if they are waste batteries you must have a waste carries lience and if you take them to Europe they must be moved on a TFS movement order. Also if transported in dolva bins they must be level loaded and covered to avoid contact with rain water.
Agreed, but I’ve no idea what a “dolva bin” is.
Also as you said, if compliance with the above cannot be achieved, eg, if the used battery cases were damaged and leaking, then the batteries would fall to be regulated by ADR, because they’d be in ADR Transport Category 3, so there would be a 1,000kg threshold limit on the gross weight of the batteries and the following would also apply:
In the relevant Packing Instruction [P801 and P801(a)] ADR uses the term “battery box” and that’s also where it stipulates exactly what you said about level loading and keeping water away.
P801 applies to both new and used batteries
P801
The following packagings are authorised
(1) Rigid outer packagings;
(2) Wooden slatted crates;
(3) Pallets.
Additional requirements:
- Batteries shall be protected against short circuits.
- Batteries stacked shall be adequately secured in tiers separated by a layer of non conductive material.
- Battery terminals shall not support the weight of other superimposed elements.
- Batteries shall be packaged or secured to prevent inadvertent movement. Any cushioning material used shall be inert.
Additionally, P801 applies to used batteries:
P801a
Stainless steel or solid plastics battery boxes of a capacity of up to 1 m3 are authorized provided the following provisions are met:
(1) The battery boxes shall be resistant to the corrosive substances contained in the storage batteries;
(2) Under normal conditions of carriage, no corrosive substance shall leak from the battery boxes and no other substance (e.g. water) shall enter the battery boxes. No dangerous residues of corrosive substances contained in the storage batteries shall adhere to the outside of the battery boxes;
(3) The battery boxes shall not be loaded with storage batteries to a height greater than the height of their sides;
(4) No storage battery containing substances or other dangerous goods which may react dangerously with one another shall be placed in a battery box;
(5) The battery boxes shall be either:
(a) covered; or
(b) carried in closed or sheeted vehicles or containers.
Multi-modal transport.
The batteries can be carried by Eurotunnel without restriction.
For ferry crossings, IMDG’s requirements are slightly more stringent than ADR’s, in that there’s a 45deg tilt test without leakage specified.
Then there are requirements stemming from other Regulations such as Waste Regs and TFS (amongst others,) but I’ve not studied them so I’m not qualified to comment on those.
dieseldave:
Wheel Nut:
Can I ask what a TFS order is please as I have carried many trailer loads of batteries from Europe to the UKHi Malc,
TFS = Trans Frontier Shipping, and it’s for the international carriage of wastes.
I can only speak for what ADR says about the subject, cos I’m not qualified on wastes.
Thanks folks. That is why I didn’t have a clue what a TFS was, because the many trailers I did were loaded with new batteries, as the original question I believe. It was a cracking load, in and out of the back doors, 22 ton and less than a foot above the trailer bed.
Wheel Nut:
Thanks folks. That is why I didn’t have a clue what a TFS was, because the many trailers I did were loaded with new batteries, as the original question I believe. It was a cracking load, in and out of the back doors, 22 ton and less than a foot above the trailer bed.
Hi Malc,
You would have known what a TFS is if you’d turned up at that ADR course. 
BTW, I’m running another at the same location next week, so consider yourself invited (again.)
Wheel Nut:
Can I ask what a TFS order is please as I have carried many trailer loads of batteries from Europe to the UK
I spotted that there was a clue in your question…
Since the transport you did was import to the UK, I think you would have been issued with another country’s equivalent of a TFS, which probably has a different name in their language.