Are fireworks ADR

UK PROFESSIONAL DRIVERS FORUMS THE UK PROFESSIONAL DRIVERS FORUM (INTERACTIVE)
21

DJC:

alcraw62:

DJC:
It’s not the responsibility of the driver to know what is ADR and what isn’t, of course it’s common sense though to flag a concern if you’re loading 26 pallets of TNT though.

So if I get pulled by VOSA and they find a load of DG’s in the back, which are out of scope of limited quantities, then I have nothing to worry about? That’s not what I have heard from other drivers.

Shouldn’t have a problem if you’re transporting unobtainium with class 9 stickers, to someone who hasn’t been on an ADR course it wouldn’t be obvious that it is. I’m not sure the exact treatment or assumption but DD will, I would assume it comes down to the circumstances, what you were told and your intent.

You have a good point there DJC, but there is a very clear legal responsibility on the consignor ( = sender) in ADR:

Here’s what ADR has to say about it:

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. , he shall in particular:
(a) Ascertain that the dangerous goods are classified and authorized for carriage in accordance with ADR;

There’s a bit more that says:

(b) Furnish the carrier with information and data in a traceable form

:bulb: There are plenty more requirements he’s got to adhere to as well!!

So the onus (and legal responsibility) is on the consignor.

If the consignor tells porkies and misleads anybody else in the transport chain, it could come right back at him. :open_mouth:

22

DJC:

alcraw62:

DJC:
It’s not the responsibility of the driver to know what is ADR and what isn’t, of course it’s common sense though to flag a concern if you’re loading 26 pallets of TNT though.

So if I get pulled by VOSA and they find a load of DG’s in the back, which are out of scope of limited quantities, then I have nothing to worry about? That’s not what I have heard from other drivers.

Shouldn’t have a problem if you’re transporting unobtainium with class 9 stickers, to someone who hasn’t been on an ADR course it wouldn’t be obvious that it is. I’m not sure the exact treatment or assumption but DD will, I would assume it comes down to the circumstances, what you were told and your intent.

Eludium is banned from any A roads and cross channel ferries now.

23

Surrey Driver:
Shotgun cartridges are routinely sent and packaged as LQs these days (since ADR2013) - I would add pictures but not sure how to do that…

Yes mate, you’re quite right about that, but it’s easier to say that shotgun cartridges (usually UN 0012) can be carried in any quantity because are in 1.4S along with lots of other things like small fireworks, some flares etc.

To comply with ADR’s LQ rules, shotgun cartridges would normally have to be in individual boxes of not more than 5kg (NEQ), and within a larger box of not more than 30kg. If that suits all parties concerned, then that’s fine.

However, if (for any reason) the LQ size limits can’t be adhered to, then any size boxes will do, and there’s still no load limit because they’re in 1.4S.

24

Wheel Nut:
Eludium is banned from any A roads and cross channel ferries now.

Welcome back. :wink:

25

albion:

AJF3011:
If they’re classed in category 1.4S you can carry an unlimited amount without requiring ADR.
This category is basically for goods that only contain a very small amount of explosive.

That one, though fireworks can also be 1.4G in which case the 333kg rule applies.

Hi albion,

1.4G has a limit of 500kg NEQ if it’s carried nationally within the UK, but 333kg NEQ is correct if the journey is international.

26

wing-nut:

dieseldave:
Hi wing-nut,

I can answer your questions if you tell me the letter that goes with the 1.4 please.

I can give you an even better answer if you give me the UN number and whether the journey was international or domestic please. :smiley:

Sorry dd, as I’d refused to carry them until I’d found out about ADR I didn’t have access to them. All the stores except mine had theirs collected by other drivers during the night so don’t think I’m too popular. :frowning: :frowning:
Did speak to one driver who said he thinks it was 1.4G but I’ll find out for sure next year if I’m still there.

Hi wing-nut,

Here’s how it plays out…

1.4G has a ‘freebie allowance’ limit of 500kg NEQ if it’s carried nationally within the UK.

1.4S has no limit.

NEQ = Net Explosive Quantity and is the same as NEM = Net Explosive Mass.

NEQ or NEM is the actual weight of explosive material, so it means that (for ADR purposes) we DON’T count the weight of the boxes, wrappings, cardboard tubes or plastic spikes commonly found on fireworks.

So, this means that you can carry various ‘freebie allowances’ of explosive substances (depending on the exact substance) completely legally without an ADR licence.

Strange but true!! :open_mouth:

My gut feeling is that it would have been OK for you to have carried that one pallet, but I don’t blame you for raising the question cos what you’d been asked to do would be quite concerning to most non-ADR people.

27

OVLOV JAY:
ADR class 1 licence required. Not a run of the mill job. I’ve had an ADR for 11 years and I can’t carry them.

Hi OVLOV JAY,

Just like other dangerous goods, UN Class 1 has some freebie limits on offer.

I know that you’re aware of the 5 Transport Category limits for international journeys:

TC 0 = 0
TC1 = 20
TC 2 = 333
TC 3 = 1,000
TC 4 = unlimited.

For domestic UK journeys, this alters a bit, but only for UN Class 1…

The UN Class 1 stuff in ADR TC 1 is removed and placed in UK TC 1A which has a limit of 50 (instead of 20)
The UN Class 1 stuff in ADR TC 2 is removed and placed in UK TC 2A which has a limit of 500 (instead of 333)

So the UK TC list looks like this

TC 0 = 0
TC 1 = 20
TC 1A = 50 (only relates to UN Class 1)
TC 2 = 333
TC 2A = 500 (only relates to UN Class 1)
TC 3 = 1,000
TC 4 = unlimited

So, UK rules allow for a larger ‘freebie’ for lots of UN Class 1 stuff, you couldn’t make it up, but it all true!! :open_mouth:

:bulb: The Secretary of State for Transport said it’s OK, so that’s good enough for me. :wink: :smiley:

28

dieseldave:

OVLOV JAY:
ADR class 1 licence required. Not a run of the mill job. I’ve had an ADR for 11 years and I can’t carry them.

Hi OVLOV JAY,

Just like other dangerous goods, UN Class 1 has some freebie limits on offer.

I know that you’re aware of the 5 Transport Category limits for international journeys:

TC 0 = 0
TC1 = 20
TC 2 = 333
TC 3 = 1,000
TC 4 = unlimited.

For domestic UK journeys, this alters a bit, but only for UN Class 1…

The UN Class 1 stuff in ADR TC 1 is removed and placed in UK TC 1A which has a limit of 50 (instead of 20)
The UN Class 1 stuff in ADR TC 2 is removed and placed in UK TC 2A which has a limit of 500 (instead of 333)

So the UK TC list looks like this

TC 0 = 0
TC 1 = 20
TC 1A = 50 (only relates to UN Class 1)
TC 2 = 333
TC 2A = 500 (only relates to UN Class 1)
TC 3 = 1,000
TC 4 = unlimited

So, UK rules allow for a larger ‘freebie’ for lots of UN Class 1 stuff, you couldn’t make it up, but it all true!! :open_mouth:

:bulb: The Secretary of State for Transport said it’s OK, so that’s good enough for me. :wink: :smiley:

To be fair my lot have always steered clear. Not worth the hassle of putting drivers through the test and putting extra insurance on just for a couple of fireworks loads every September

29

dieseldave:

albion:

AJF3011:
If they’re classed in category 1.4S you can carry an unlimited amount without requiring ADR.
This category is basically for goods that only contain a very small amount of explosive.

That one, though fireworks can also be 1.4G in which case the 333kg rule applies.

Hi albion,

1.4G has a limit of 500kg NEQ if it’s carried nationally within the UK, but 333kg NEQ is correct if the journey is international.

Can I have a pass for late at night, no orange book to hand and what’s UK work? :wink:

More of a 1.1-1.2 carrier

30

dieseldave:

Wheel Nut:
Eludium is banned from any A roads and cross channel ferries now.

Welcome back. :wink:

I just pop in every now and again just to make sure everything is OK :slight_smile:

31

albion:

dieseldave:

albion:

AJF3011:
If they’re classed in category 1.4S you can carry an unlimited amount without requiring ADR.
This category is basically for goods that only contain a very small amount of explosive.

That one, though fireworks can also be 1.4G in which case the 333kg rule applies.

Hi albion,

1.4G has a limit of 500kg NEQ if it’s carried nationally within the UK, but 333kg NEQ is correct if the journey is international.

Can I have a pass for late at night, no orange book to hand and what’s UK work? :wink:

More of a 1.1-1.2 carrier

Hi albion,

UK work is when you forget to get on a ferry and deliver to some random UK place without leaving dry land. :laughing: :laughing:

Strangely, if you carry 1.1B to 1.1J and 1.2B to 1.2J and stay within our shores, you can go to 500kg NEQ without a night permit, or the need of full adherence to ADR. :smiley:

32

dieseldave:
Hi wing-nut,

Here’s how it plays out…

1.4G has a ‘freebie allowance’ limit of 500kg NEQ if it’s carried nationally within the UK.

1.4S has no limit.

NEQ = Net Explosive Quantity and is the same as NEM = Net Explosive Mass.

NEQ or NEM is the actual weight of explosive material, so it means that (for ADR purposes) we DON’T count the weight of the boxes, wrappings, cardboard tubes or plastic spikes commonly found on fireworks.

So, this means that you can carry various ‘freebie allowances’ of explosive substances (depending on the exact substance) completely legally without an ADR licence.

Strange but true!! :open_mouth:

My gut feeling is that it would have been OK for you to have carried that one pallet, but I don’t blame you for raising the question cos what you’d been asked to do would be quite concerning to most non-ADR people.

Thanks for your help DD. They asked me again to collect some tonight and after reading your comments I agreed so they’re happy now. They were 1.4G and UN number was 0336.

33

I always end up looking up the UK stuff, all our lads ( and lass ) have ADR anyway.

PS ancient as I am, I’ve only just got out of referring to the NEC :wink:

34

Heres another one for you Diesel Dave as you seem on top of the ADR regs.
I do only European work and occasionally pick up a tilt full of orange oil and hear conflicting advice re toxicity, i know its not particularly dangerous stuff but still has its hazards, whats the rulings on this stuff please? Its loaded or shall i say slung on from the sides and invariably some drums leak, theyre always filled using battered old recycled drums, the yard we pick it up from in Malaga is a real sticky mess :frowning:
Thanks- Andy.

35

AndrewG:
Heres another one for you Diesel Dave as you seem on top of the ADR regs.
I do only European work and occasionally pick up a tilt full of orange oil and hear conflicting advice re toxicity, i know its not particularly dangerous stuff but still has its hazards, whats the rulings on this stuff please? Its loaded or shall i say slung on from the sides and invariably some drums leak, theyre always filled using battered old recycled drums, the yard we pick it up from in Malaga is a real sticky mess :frowning:
Thanks- Andy.

I remember Orange Oil as a marine pollutant and class 9 but as I have been out of it a long time will leave it to Dave

36

wing-nut:

dieseldave:
Hi wing-nut,

Here’s how it plays out…

1.4G has a ‘freebie allowance’ limit of 500kg NEQ if it’s carried nationally within the UK.

1.4S has no limit.

NEQ = Net Explosive Quantity and is the same as NEM = Net Explosive Mass.

NEQ or NEM is the actual weight of explosive material, so it means that (for ADR purposes) we DON’T count the weight of the boxes, wrappings, cardboard tubes or plastic spikes commonly found on fireworks.

So, this means that you can carry various ‘freebie allowances’ of explosive substances (depending on the exact substance) completely legally without an ADR licence.

Strange but true!! :open_mouth:

My gut feeling is that it would have been OK for you to have carried that one pallet, but I don’t blame you for raising the question cos what you’d been asked to do would be quite concerning to most non-ADR people.

Thanks for your help DD. They asked me again to collect some tonight and after reading your comments I agreed so they’re happy now. They were 1.4G and UN number was 0336.

Hi wing-nut,

The last line you wrote was the key piece of info I needed, so now I can say…

On a UK journey, you can carry 500kg NEQ (or less) of UN 0336 without an ADR licence.

However, you DO need 1 X 2kg ADR compliant dry powder fire extinguisher and some ADR awareness training which has been documented, but NOT a proper ADR licence.

You will also need a proper ADR compliant Transport Document ( = Delivery Note) if the NEQ exceeds 50kg.
If the NEQ is 50kg or less, then any old type of company delivery doc will be acceptable.

For easy reference:

On UK work, your max limit is 500kg NEQ if the label looks like this:

1.4G small.gif

However, there’s NO limit if the label looks like this:

1.4S small.gif

Now for the strange bit…
On UK work, you can carry the 1.4Gs to a max of 500kg NEQ as above, but it is perfectly possible to fill the rest of a full sized artic with 1.4S (regardless of NEQ for the 1.4S) and still not need an ADR licence or orange plates, cos there’s nothing to say that you can’t use the two different exemptions at the same time and there’s no prohibition on carrying G’s with S’s.

Strange but true!! :open_mouth:

37

AndrewG:
Heres another one for you Diesel Dave as you seem on top of the ADR regs.
I do only European work and occasionally pick up a tilt full of orange oil and hear conflicting advice re toxicity, i know its not particularly dangerous stuff but still has its hazards, whats the rulings on this stuff please? Its loaded or shall i say slung on from the sides and invariably some drums leak, theyre always filled using battered old recycled drums, the yard we pick it up from in Malaga is a real sticky mess :frowning:
Thanks- Andy.

Hi Andy,

Since the sender is responsible for providing the description, the first question I have to ask you is:

What is written on the CMR as the description of the goods please?

38

Hi Dave, from what i recall from the last load was 95% d limonene, (Valencia orange oil) skin and eye irritation and flammable. Theres two of us Brit O/D’s out here both doing work for the same company and hear conflicting reports on its hazards and its only ever us that pull these tilts loaded to the gunnels with the sticky mess,the spanish guys always seem to able to avoid it (no surprise there :unamused: )
Appreciate any pointers here.

Andy.

39

AndrewG:
Hi Dave, from what i recall from the last load was 95% d limonene, (Valencia orange oil) skin and eye irritation and flammable. Theres two of us Brit O/D’s out here both doing work for the same company and hear conflicting reports on its hazards and its only ever us that pull these tilts loaded to the gunnels with the sticky mess,the spanish guys always seem to able to avoid it (no surprise there :unamused: )
Appreciate any pointers here.

Andy.

Hi Andy,

As far as I can tell, D-Limonene is legally classified as a dangerous substance as follows:

It’s product name is:
(4R)-4-Isopropenyl-1-methylcyclohexene (D-Limonene)

For dangerous goods purposes and ADR it is called dipentene and it’s description on paperwork should be:

UN 2052 DIPENTENE, 3, PGIII

(Spanish = No ONU 2052 DIPENTENO, 3, GEIII)

The figure “3” means that it is a Flammable Liquid of UN Class 3.
The Roman “III” means that it presents a low danger
(I = high danger, II = medium danger and III = low danger)

As such, you can carry it in packages (IBCs, drums etc) without an ADR licence or orange plates etc provided that you carry no more than 1,000L on board a vehicle at a time.
I noticed your reference to “the sticky mess” so seeing that we’re speaking of Spain and knowing the size of their fines… :open_mouth:
ADR says:

(ADR 4.1.1.1) … No dangerous residue shall adhere to the outside of packagings …

A properly made out CMR containing the description that I’ve made bold (above) and stating the type and number of packages along with the total number of litres of the stuff will more than cover ADR’s Transport Document requirements.
You will also need 1 X 2kg ADR compliant dry powder fire extinguisher.

For sea transport, (different Regs called IMDG) you will also need a properly made out multi-modal DGN and 3 X Class 3 placards (250mm X 250mm) to be placed on two sides and the rear of a vehicle for sea transport.
If the trailer is to be shipped unaccompanied, then you’d need an extra (total = 4) placard for the front of the trailer.

3_.gif

:bulb: Since you’ve mentioned that O/Ds are involved, it’s also worth pointing out that they personally bear some responsibility for some of the above.

40

The last load i took was 34,000 litres of the stuff so it looks like i may be a tad over on the allowed limit!
Many of these old barrels are leaking to the extent its coming through the trailer floor and we cant backload until theyre washed out its been that bad on occasions. Ill certainly be pointing this out to the co. i do work for and show them the info youve kindly given me.

Many thanks- Andy.