Been a while since i posted and began driving for a living 
after a long slog i’ve nearly had my class C for 2 years Woohoo and drove all sorts of vehicles ranging from concrete jagers to roll on roll off skips and must admit its been a steep learning curve, but once in a while i come up against something new that im not to sure about and after some searching on internet with no avail im posting on here, hope someone can help me out with this silly question but i like to be sure when i refuse to do something 
Question : Do i need ADR to allow me to transport empty calor gas bottles ?
Depends on how many and what size, but more than likely if you read below, personally i would not want the hassle and refuse if you have not got the right ADR licence etc etc.
Class 2 (compressed and liquefied gases). In ordinary service these items are not emptied in any conventional way and it would be difficult (and possibly dangerous without specialist equipment) to determine residual contents. The main operators in this field treat all cylinders as full and do not seek to utilise the small load exemptions. Enforcement officers should also take this view (that is, that the cylinders cannot be regarded as TC4). Note that in many cases (especially carriage by users such as mobile mechanics, welders etc) the small load exemptions will apply and care needs to be taken to recognise how the load is calculated (see definition of nominal capacity below). See also the note below re aerosols
Any concerns should be itemised on the document given to the driver and followed up if necessary with the consignor or carrier as needed (via HID CI 4B). Inspectors contemplating enforcement action in cases where this advice is not appropriate or has not been followed are advised to consider risk and the intricacies of the requirements. In particular, the question of whether hazards have been nullified is not always going to be easy.
A UK derogation (see Dangerous Goods: Approved Derogations and Transitional Provisions") exempts from the documentary requirements of ADR, loads which are within the small load thresholds (see Main exemptions). ADR 1.1.3.6.3 states that for liquids and compressed gases the thresholds are calculated by reference to “nominal capacity”. That in turn is defined at 1.2.1 as:
“the nominal volume of the dangerous substance contained in the receptacle in litres. For compressed gas cylinders the nominal capacity shall be the water capacity of the cylinder”
By this definition, nominal capacity amounts to net contents for a receptacle that contains a liquid.
Thus for most cases of empty uncleaned packaging, the small load exemptions (from some of the requirements) will apply. Thus no documentation would be required for GB domestic transport. The key remaining requirements are as follows:
Train the driver at least to "general " standards (ADR 8.2.3 and 1.3)
Carry one 2 kg fire extinguisher
Ensure stowage complies with 7.5.7 (this would be needed under other road safety legislation anyway)
There is no need to display orange plates, though it would not be an offence to do so. Some trade associations advise their members to display orange plates whenever the vehicle is carrying dangerous goods, but the small load exemptions may still apply.
Adopting this approach should ensure good standards, and compliance with almost any interpretation of the requirements, and minimise the stopping of what should be low risk vehicles for ADR reasons alone.
NoobieTrucker:
Question : Do i need ADR to allow me to transport empty calor gas bottles ?
Hi NoobieTrucker,
This all hinges on the word “empty.”
If the Calor Gas “bottles” (cylinders) carried on a vehicle are truly empty, then you don’t need an ADR licence to transport them regardless of the number of cylinders carried.
When you wrote “calor gas,” am I correct in taking it that you mean propane/butane?
If there is any residual propane/butane (liquid) in the cylinders, then the weight of the propane/butane in Kgs, (NOT Litres) must be taken into account.
Sticking to doing the job without an ADR licence, the total Kgs of propane/butane cannot exceed 333Kgs, otherwise an ADR licence (and many other rules) then become mandatory.
In practice, this will depend on how many cylinders you intend to transport on a vehicle at the same time.
However, to do this job (even without an ADR licence) you do need:
- Documented ADR “awareness” training (not necessarily carried on board the vehicle)
- The cylinders must be correctly stowed and secured as per ADR requirements
- 1 X ADR compliant 2Kg dry powder fire-extinguisher
Thanks for all the information, this will give me some ammo to argue with 
or might even get my ADR out of it but doubt that will happen lol. Thanks again !!!
dieseldave:
NoobieTrucker:
Question : Do i need ADR to allow me to transport empty calor gas bottles ?Hi NoobieTrucker,
This all hinges on the word “empty.” … (etc)
Hi Dave, just to say thank you for the information and advice you give on here.
I, for one, have learned a lot from your posts.
I think we are fortunate to have you here.
That’s all, just thanks.
3 wheeler:
… care needs to be taken to recognise how the load is calculated …
Hi 3 wheeler,
How very true.
Wherever your info came from, it doesn’t quite address the OP’s question correctly because it’s based on some inaccuracies.
“Calor gas” is normally propane or butane, but we’ll wait for the OP to confirm that.
If I’m correct that we’re speaking of propane/butane, the definitions are a little different, which makes a difference to how it’s done…
Propane (UN 1978) and Butane (UN 1011) are Liquefied Petroleum Gases (LPG) as per the following definition:
ADR 1.2.1
“Liquefied Petroleum Gas (LPG)” means a low pressure liquefied gas composed of one or more light hydrocarbons which are assigned to UN Nos. 1011, 1075, 1965, 1969 or 1978 only and which consists mainly of propane, propene, butane, butane isomers, butene with traces of other hydrocarbon gases;
ADR 1.1.3.6.2 allows certain exemptions, provided that the figures given for the relevant ADR Transport Category given in ADR 1.1.3.6.3 are not exceeded. ADR 1.1.3.6.3 also goes on to say how the calculation is to be done.
It is important to recognise how the load is calculated, because then (and only then) do we know whether (and which) exemptions apply.
LPG is calculated differently to that great chunk of text that you posted in an important way.
ADR 1.1.3.6.3
For solids, liquefied gases, refrigerated liquefied gases and dissolved gases, net mass in kilograms;
So, for LPG the actual weight of the liquefied gas in each cylinder is what is to be counted.
For those who wish to be excruciatingly exact, the procedure would be for the consignor to weigh each cylinder at the time of it being exchanged by the end-user, or at the time of loading.
An LPG cylinder must have the empty weight of the cylinder stamped on it, so it wouldn’t be too difficult to know how many Kgs of gas are being carried on a vehicle.
However, ADR provides an easy answer to the OP’s question in the section that describes the responsibilities of the various participants.
ADR 1.4.2.1.1
The consignor of dangerous goods is required to hand over for carriage only consignments which conform to the requirements of ADR. In the context of 1.4.1, [1.4.1 = General Safety Measures] he shall in particular:(a) Ascertain that the dangerous goods are classified and authorized for carriage in accordance with ADR;
(b) - (e) snipped for clarity
3 wheeler:
… Any concerns should be itemised on the document given to the driver and followed up if necessary with the consignor…
The OP is a driver, who works for the carrier.
ADR 1.4.2.2.2 allows the carrier to rely on information provided by the consignor, so if the consignor says that the cylinders are empty, then they’re empty and the legal responsibility for telling the truth to the carrier rests where it belongs.
If the load calculation for LPG is correctly applied, a non-ADR trained driver can carry 7 (seven) of the large 47Kg (net) propane cylinders without the need for an ADR licence. (The empty weight of the actual cylinder is disregarded.)
7 X 47 = 329, which is less than the ADR Transport Category (TC2) load limit in 1.1.3.6.3 for Propane (333 net Kg.)
You’d need an awful lot of ‘empty’ propane cylinders on a vehicle before you got anywhere near 333 net Kgs 
Now for the misleading part…
3 wheeler:
In particular, the question of whether hazards have been nullified is not always going to be easy.
Somebody might be getting their exemptions a bit mixed-up here.
The exemption that relies on nullified hazards is this one:
ADR 1.1.3.5Empty uncleaned packagings (including IBCs and large packagings) which have contained substances of Classes 2, 3, 4.1, 5.1, 6.1, 8 and 9 are not subject to the conditions of ADR if adequate measures have been taken to nullify any hazard. Hazards are nullified if adequate measures have been taken to nullify all hazards of Classes 1 to 9.
The “nullified hazards” bit would make it that the job is “not subject to the conditions of ADR,” and doesn’t impact on the separate ‘small load’ exemption at 1.1.3.6.2 - 3, which as you’ve pointed out DOES require some of ADR to be obeyed.
OnlyAlan:
dieseldave:
NoobieTrucker:
Question : Do i need ADR to allow me to transport empty calor gas bottles ?Hi NoobieTrucker,
This all hinges on the word “empty.” … (etc)
Hi Dave, just to say thank you for the information and advice you give on here.
I, for one, have learned a lot from your posts.
I think we are fortunate to have you here.That’s all, just thanks.
Haha you might as well just drop your trousers and bend over… at least a ■■■■■■■… Lol
.
Unbelievable, are you saying I need an ADR for a ■■■■■■■ now?
What categories would I need?
6, Toxic substances?
9, Miscellaneous dangerous goods?
Or would I be exempt cos I’ve had a vasectomy? Does that make it ‘non-clinical waste’.
Is there an exemption if I am just off-loading?
The more I read the more complicated it gets.
Think the gas was Butane, i work for the council at the moment and we don’t normally take gas cylinders, but on a particular job a client wanted me to take 3 bottles away, as i was not sure i said no anyway but always like to know for sure the next time, also even though i was told they were empty they would still need to be secured would they not?
Hi,
I find this funny and Dieseldave your comment
“Wherever your info came from, it doesn’t quite address the OP’s question correctly because it’s based on some inaccuracies.”
Can be answered by …It came directly from the latest HSE pages , Lock stock and barrel. !!!
My ADR and driving licences all came to an end a while ago on medical grounds , so my knowledge from memory would have been out of date…hence the HSE bit.
FFS if they cannot get it right what chance some poor sod behind the wheel.
NoobieTrucker:
Think the gas was Butane, i work for the council at the moment and we don’t normally take gas cylinders, but on a particular job a client wanted me to take 3 bottles away, as i was not sure i said no anyway but always like to know for sure the next time, also even though i was told they were empty they would still need to be secured would they not?
Hi NoobieTrucker,
You could have taken the three butane (or propane) cylinders (full or empty) without the need of an ADR licence or orange plates etc, because even if they were full cylinders… you wouldn’t have had more than 333Kg net on board.
If the cylinders were of the largest variety, 3 X 47Kg = 141Kg net which is nowhere near the 333Kg net allowance.
Both 3 wheeler and myself were correct to say that you would need:
- Documented ADR “awareness” training (not necessarily carried on board the vehicle)
- The cylinders must be correctly stowed and secured as per ADR requirements
- 1 X ADR compliant 2Kg dry powder fire-extinguisher
3 wheeler:
Hi,
I find this funny and Dieseldave your comment“Wherever your info came from, it doesn’t quite address the OP’s question correctly because it’s based on some inaccuracies.”
Can be answered by …It came directly from the latest HSE pages , Lock stock and barrel. !!!
Hi 3 wheeler,
The info was inaccurate in that no mention was made of the relevant method for calculating LPG as required by ADR, which therefore went on to leave NewbieTrucker without the info he asked for in his specific situation.
To be fair to both the HSE and I, their advice and ADR references are pretty much what I said in my post above, except that I realised that it was very probably LPG that was the subject of NewbieTrucker’s question.
I did a little trawling and came up with the source of the info you posted:
http://www.hse.gov.uk/cdg/manual/commonproblems/emptyuncleaned.htm
I hadn’t read that when I posted, but I have now that I trawled for it.
Having now read the whole of it, I’m standing my ground that it doesn’t address the specific question as asked by NewbieTrucker in his OP.
ADR (and UK CDG) have some twists and turns, such as Exemptions, Special Provisions, Transitional Measures and Derogations, which can apply to specific jobs or specific substances and alter things by relaxing some rules or making other rules more stringent.
3 wheeler:
My ADR and driving licences all came to an end a while ago on medical grounds , so my knowledge from memory would have been out of date…hence the HSE bit.
FFS if they cannot get it right what chance some poor sod behind the wheel.
IMHO, they did get the info they gave correct, as far as it went.
To be clear, I’m not saying that the HSE were incorrect, I’m simply saying that the info might have gone a little further in what it said. The HSE faces the same problems as anybody else who posts info on the Internet in that it is extremely difficult to write ‘general’ info and hope to cover every eventuality, so that’s why I asked for the name of the gas and mentioned that it depends on how many cylinders were involved.
Many people (including ADR trained drivers) don’t seem to understand that (in the UK) an employed driver isn’t actually responsible for very much when it comes to the carriage of dangerous goods.
The time when a driver was responsible for the calculation of whether a dangerous goods load was ‘in scope’ ended at midnight on 09/05/2004. This was foreseen by the requirement for companies to appoint a properly qualified DGSA, which came into force on 01/01/2000 and allowed folks to get used to the new way of doing things.
dieseldave:
3 wheeler:
Hi,
I find this funny and Dieseldave your comment“Wherever your info came from, it doesn’t quite address the OP’s question correctly because it’s based on some inaccuracies.”
Can be answered by …It came directly from the latest HSE pages , Lock stock and barrel. !!!Hi 3 wheeler,
The info was inaccurate in that no mention was made of the relevant method for calculating LPG as required by ADR, which therefore went on to leave NewbieTrucker without the info he asked for in his specific situation.
To be fair to both the HSE and I, their advice and ADR references are pretty much what I said in my post above, except that I realised that it was very probably LPG that was the subject of NewbieTrucker’s question.
I did a little trawling and came up with the source of the info you posted:http://www.hse.gov.uk/cdg/manual/commonproblems/emptyuncleaned.htm
I hadn’t read that when I posted, but I have now that I trawled for it.
Having now read the whole of it, I’m standing my ground that it doesn’t address the specific question as asked by NewbieTrucker in his OP.
ADR (and UK CDG) have some twists and turns, such as Exemptions, Special Provisions, Transitional Measures and Derogations, which can apply to specific jobs or specific substances and alter things by relaxing some rules or making other rules more stringent.
3 wheeler:
My ADR and driving licences all came to an end a while ago on medical grounds , so my knowledge from memory would have been out of date…hence the HSE bit.
FFS if they cannot get it right what chance some poor sod behind the wheel.IMHO, they did get the info they gave correct, as far as it went.
To be clear, I’m not saying that the HSE were incorrect, I’m simply saying that the info might have gone a little further in what it said. The HSE faces the same problems as anybody else who posts info on the Internet in that it is extremely difficult to write ‘general’ info and hope to cover every eventuality, so that’s why I asked for the name of the gas and mentioned that it depends on how many cylinders were involved.
Many people (including ADR trained drivers) don’t seem to understand that (in the UK) an employed driver isn’t actually responsible for very much when it comes to the carriage of dangerous goods.
The time when a driver was responsible for the calculation of whether a dangerous goods load was ‘in scope’ ended at midnight on 09/05/2004. This was foreseen by the requirement for companies to appoint a properly qualified DGSA, which came into force on 01/01/2000 and allowed folks to get used to the new way of doing things.
Glad I no longer drive anymore , but i am glad the driver is not likely to be the one put in the ■■■■ as most drivers would never get the DGSA you speak of.
Perhaps I should do the course it may find me a job I can do from home.
3 wheeler:
Glad I no longer drive anymore , but i am glad the driver is not likely to be the one put in the [zb] as most drivers would never get the DGSA you speak of.
Hi 3 wheeler,
The law on DGSAs is quite straightforward…
DGSA is a proper qualification that can ONLY be obtained by passing at least three exams, there are no grandfather rights, nor is there any qualification considered as being equivalent.
The qualified DGSA can be the owner of the company, an employee of the company OR a person not directly employed by the company (= a retained consultant.)
If a company or person meets the legal definition of ‘consignor’ they/he must have a DGSA.
If a company or person meets the legal definition of ‘carrier’ they/he must have a DGSA.
The UK has a number of exemptions from the requirement to appoint a DGSA, but these are only relevant in specific situations.
If a company transports dangerous goods, the drivers should be made aware of who their DGSA is, because that’s the person who can give a qualified opinion/advice regarding a given situation.
3 wheeler:
Perhaps I should do the course it may find me a job I can do from home.
I’d advise you to save your money, because the course is relatively expensive (I teach it)… not much change from £1,000 once you’ve paid for the course, bought your law books and paid your exam fees. The exams are notoriously difficult to pass, which is reflected in the high fail rates. All this is with no guarantee of employment/consultancy afterwards unless you have some sort of network already in place. 
Doing freelance DGSA work from home as I do is perfectly possible, but sometimes you do need to visit places and see what’s going on for yourself. It’s possible to make your living from DGSA work, but you’d need a large number of clients.
To get around this problem, I also teach the drivers’ ADR course for a number of different providers… then by doing both things it becomes liveable, but the downside to it is that there’s lots of travelling to be done on non-teaching days.