AndrewG:
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.
Hi Andy,
I didn’t realise the size of the problem. 
From your description of the job, all I can say is that there’s something seriously amiss.
Every company who sends out that volume of dangerous goods has to have a qualified DGSA, and so does every carrier, so that includes O/Ds.
I’ve no idea what DGSA is in Spanish, so I can’t help with a translation, but I can say that the requirement is in the current (2015) version of ADR, so it can be found in the ADR books (written in any language) at subsection 1.8.3.1
If your man looks at ADR 4.1.1.1, he’ll see that the drums should not be a sticky mess.
The beauty of the ADR system is that it all ultimately comes from the UN via the UNECE, and the fact that the players all speak different languages makes absolutely no difference, so there’s no hiding place for anybody.
Spain IS a member of ADR, so they’ve agreed to it whether your consignor like the idea or not.
Here’s the part that should get the sender’s attention…
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…Ascertain that the dangerous goods are classified and authorized for carriage in accordance with ADR; …
Furnish the carrier with information and data in a traceable form and, if necessary, the required transport documents and accompanying documents
As far as I can tell from your post, even the classification isn’t being carried out correctly, but let’s not forget one thing…
The Spanish (and French) police have copies of ADR written in their languages, so I’d say it’s only a question of time until there’s a rather expensive problem for all concerned because there seems to be quite a lot going on that might not quite “conform to the requirements of ADR.”
Now for the vehicle owner’s (the carrier) part…
ADR 1.4.2.2.1 … where appropriate, the carrier shall in particular:
(a) Ascertain that the dangerous goods to be carried are authorized for carriage in accordance with ADR;
(b) Ascertain that all information prescribed in ADR related to the dangerous goods to be carried has been provided by the consignor before carriage, that the prescribed documentation is on board the transport unit or if electronic data processing (EDP) or if electronic data interchange (EDI) techniques are used instead of paper documentation, that data is available during transport in a manner at least equivalent to that of paper documentation;
I’m hoping that if you can get the consignor to have a word with their DGSA, then they might start doing things differently.
