Just curious if certain products which ‘contain’ possible ADR stuff is classed as such…
For example, Generators - they contain oil, and could contain fuel/vapours…but I guess in limited quantities… would these items fall outside ADR rules?
I’m sure its a bone question, it’s just I was (many moons ago) DG qualified goods by air, and generally engines etc were classed as DG.
Grey area, some come under adr and some don’t. I’ve loaded cars that are haz but others that aren’t. Same with various used plant equipment. Some shipping lines dictate car air bags are haz, some don’t.
el_presidente:
Just curious if certain products which ‘contain’ possible ADR stuff is classed as such…For example, Generators - they contain oil, and could contain fuel/vapours…but I guess in limited quantities… would these items fall outside ADR rules?
I’m sure its a bone question, it’s just I was (many moons ago) DG qualified goods by air, and generally engines etc were classed as DG.
Hi el_presidente,
It’s not a bone question at all mate, but I’ve noted that you were IATA qualified. 
As you know, the UN gives all dangerous goods a UN number in the UN ‘orange’ book, which forms the basis for all national and international DG Regs. (EG… UN numbers, 9 Classes and 3 PGs etc)
Then the various modal authorities get involved such as ICAO/IATA for Air, UNECE for ADR and roads and the IMO for IMDG and the sea.
The modal authorities then decide how that mode will deal with the various DGs and whether they choose to regulate them and to what extent for their mode.
IATA is rightly very strict about DGs because aircraft and flying is involved, but us poor relations who drive trucks are not subject to such tight regulation by our masters… UNECE and ADR.
The answer to your question is that things such as engines and generators are generally seen by ADR as not being particularly troublesome or dangerous by road, so ADR doesn’t have a great deal to say about such items. Speaking very generally, ADR pretty much lets us get on with moving engines and generators without making the fuss that IATA (quite rightly) make of them.
You’re slightly off-beam with your notion of Limited Quantities though, because that’s pretty much the same by Air as by Road, the idea being that it’s stuff that not particularly dangerous packaged in quite small amounts per package rather than the idea of not very much on a vehicle.
By Road, the LQ exemption is commonly used by retailers for the kinds of dangerous goods that can be bought over the counter in a retail shop when packaged as you’d expect to find them in a retail shop.
Dave’s ADR trivia… A non-ADR qualified driver can drive a full load of goods packaged according to ADR’s LQ exemption sizes without any fire-extinguishers, orange plates or even an ADR licence. (They’d just need a bit of ‘ADR awareness’ training.)
Strange, but true. 
Cheers Dave…
I had lots of fun back in the day with IATA etc… and probably this previous (but rather rusty) knowledge gets me overthinking things…!
If I recall, the IATA had a rather (once trained) simplified method of determining when regs need applying - as you said, UN number, packing group etc…
back on track, as a ‘for example’ something like a generator, I’m thinking UN 3166 Class 9…for the engine… permitted without full regs if fuel and oil tanks have quantity of 5 ltrs or less?
So essentially the consignor needs to prep for movement by draining down fuel etc…?
el_presidente:
Cheers Dave…I had lots of fun back in the day with IATA etc… and probably this previous (but rather rusty) knowledge gets me overthinking things…!
If I recall, the IATA had a rather (once trained) simplified method of determining when regs need applying - as you said, UN number, packing group etc…
Hi el_presidente,
I’ve no idea about IATA tbh, but if khdgsa sees this, I’m pretty sure that he’d be able to comment.
el_presidente:
back on track, as a ‘for example’ something like a generator, I’m thinking UN 3166 Class 9…for the engine… permitted without full regs if fuel and oil tanks have quantity of 5 ltrs or less?So essentially the consignor needs to prep for movement by draining down fuel etc…?
UN 3166 is:
Engine, internal combustion or vehicle, flammable gas powered or vehicle, flammable liquid powered or engine, fuel cell, flammable gas powered or engine, fuel cell, flammable liquid powered or vehicle, fuel cell, flammable gas powered or vehicle, fuel cell, flammable liquid powered
So as you can see, UN 3166 is to be used for “engine” or “vehicle” and is not subject to ADR (at all.)
ADR doesn’t treat a generator as above, rather it’s a complete machine.
Generators and the like are a complete machine, so ADR treats them differently…
UN 3363 is
Dangerous goods in machinery or dangerous goods in apparatus
…but this UN number is also not subject to ADR.
However, the following does apply to this UN number in the general exemptions at ADR 1.1.3.1
ADR 1.1.3.1(b)
(b) The carriage of machinery or equipment not specified in this Annex and which happen to contain dangerous goods in their internal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage;
So as long as 1.1.3.1(b) is complied with, then the rest of ADR doesn’t apply at all.
ADR doesn’t mention draining down of fuel or oil etc.
However, if you remember the draining down bit from your IATA training, then it wouldn’t surprise me if that was a requirement for air transport.
There are a few surprising differences between requirements across the various modes of carriage, but it shouldn’t be too surprising when one takes into account the environment in which the different modes operate.
One of my well-used sayings when I explain this is to mention that there are no lay-byes in the sky, or that I’ve never seen a sailor trying to display an orange plate on the front and rear of his ship.
Come to think of it, a truck driver would have trouble hoisting a dangerous goods flag from his truck’s mast.
Rest easy mate, cos your generators are very probably good to go!