Calling Diesel Dave

[dieseldave]

bluenose:
Diesel Dave is there a legal minimum spill kit for a curtain sided trailer doing various ADR classes (not 1 & 7), …

Hi bluenose,

There is no actual requirement for a spill-kit as such, but a vehicle may carry a spill-kit.

When you carry Classes 3, 4.1, 4.3, 8 or 9 AND the load exceeds the relevant ADR Transport Category ‘freebie’ limit ( = full ADR applies,) then you will need at least:

• A shovel
• A drain seal
• A collecting container

This is written near the bottom of page #4 of your Instructions In Writing (IIW,) but watch out for the little letter “c,” because that tells you (right at the very bottom) which UN Classes trigger the requirement.

bluenose:
also is the fire extinguisher 12kg (1 at least 6kg)?

When a vehicle carries dangerous goods (but not in Limited or Excepted Quantities) an ADR compliant dry powder fire extinguisher of at least 2kg must be carried. This applies to all vehicles.

Once a vehicle carries in excess of the relevant ADR transport category load limit ( = when full ADR applies) then the vehicle must carry a second fire extinguisher, primarily for a tyre or brake fire.

The required size for the second fire extinguisher depends on the authorised GVW of the vehicle…

Permitted G.V.W. less than 3,500 kgs needs ANOTHER 2kg extinguisher as above, making a total of 4kgs.

Permitted G.V.W. between 3,500kgs and less than 7,500kgs needs ANOTHER 6kg extinguisher making a total of 8kgs

Permitted G.V.W over 7,500kgs ie ANY LGV needs ANOTHER 10kg extinguisher making a total of 12kgs
Once the vehicle is an LGV, it doesn’t matter whether it’s a rigid, wag and drag or an artic.

I covered the requirements for fire extinguishers in a bit more depth and with a couple of pics here:

Dangerous goods advice- UK regs and ADR - SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE - Trucknet UK

Even though the linked post looks like an old post, the info is still correct.

[peewee]

i work in a big ford parts warehouse and when we get our delivery from daventry all air bags and aerosols of paint all come in a single roller cage and the paperwork states roller is hazardous

also a mate of mine ownes a ford breakers yard and he sets the bags off as he claimns he isnt allowed to send them in post so me and his workmate set a load off in a scrap ford courior van with interesting results we broke the welds on the roof panel also put a massive dent in wheel arch great fun but dangerous so dont try it at home

[cieranc]

Brilliant, Thanks Dave.
I shall let our customer know where we stand legally, and put the ball firmly back in his court!

I appreciate the effort you’ve put into researching and answering my query so thoroughly.

[dieseldave]

peewee:
i work in a big ford parts warehouse and when we get our delivery from daventry all air bags and aerosols of paint all come in a single roller cage and the paperwork states roller is hazardous

Hi peewee,

Spot-on mate… aerosols are dangerous goods, usually UN 1950.
This is the first correct mention of Limited Quantities so far.

However, it’s not a good idea to carry airbags and aerosols in such close proximity to each other.

peewee:
also a mate of mine ownes a ford breakers yard and he sets the bags off as he claimns he isnt allowed to send them in post so me and his workmate set a load off in a scrap ford courior van with interesting results we broke the welds on the roof panel also put a massive dent in wheel arch great fun but dangerous so dont try it at home

Your mate is correct that you can’t put airbags and the like in the postal system, but that’s nothing to do with ADR.

[own_account_driver]

How does limited quantities work on aggregate?

I’m pretty sure it’s less than 8 ton to come under limited quantities in aerosols but if you had say air bags on as well would that be additional allowance or eat into the 8 ton for aerosols?

I often have quite a lot of pallets of aerosols on.

Thanks in advance

[dieseldave]

Own Account Driver:
How does limited quantities work on aggregate?

I’m pretty sure it’s less than 8 ton to come under limited quantities in aerosols but if you had say air bags on as well would that be additional allowance or eat into the 8 ton for aerosols?

I often have quite a lot of pallets of aerosols on.

Thanks in advance

Hi Own Account Driver,

Dangerous goods carried in packages under the Limited Quantities rules have no ‘allowance’ limit or aggregate that springs the rest of ADR into action. So no other parts/chapters/sections of ADR that could affect you apply to that consignment.

The only thing that happens once 8t of Limited Quantities is exceeded is that there becomes a requirement to display vehicle markings.

Two of these:
.

Or two of these:
.

Please remember that there are two different UN numbers for airbags as mentioned by Malc and I above, and so it will depend on whether the airbags are assembled into components…

The airbags in Class 9 are nothing to do with Limited Quantities, because they are completely exempted (by a separate exemption,) therefore these could be carried in addition to any amount of any other UN Classes of dangerous goods packaged in Limited Quantities. The two exemptions are completely different to each other and do not affect each other even when carried on the same vehicle.

The airbags in Class 1.4G have a 500kg NEM limit, which has no connection to Limited Quantities.
The airbags in Class 1.4G will always attract some of ADR’s requirements that I’ve mentioned in my post above.
However, your question is a little different in that the OP wasn’t considering carrying different UN Classes on the same vehicle. The rules for mixed UN Classes are very complicated when UN Class 1 is involved, so to save me from a great deal of typing, could I please ask if you intend to carry UN 0503 please?

[own_account_driver]

Hi

Thanks, no it would typically be pallets of aerosols and pallets of bottles of solvents UN12…■■ alcohols, acetone etc. Have never been 100% on whether I can have less than 8 ton of each or combined.

[dieseldave]

Own Account Driver:
Hi

Thanks, no it would typically be pallets of aerosols and pallets of bottles of solvents UN12…■■ alcohols, acetone etc. Have never been 100% on whether I can have less than 8 ton of each or combined.

Hi,

Thanks for the extra info, now it’s an easy question for me to answer.

It seems possible that somebody might have been applying the idea of the Transport Category ‘freebie’ limits to the carriage of Limited Quantities, and that’s a very common error.

Limited Quantities is a specific exemption that can only apply to some dangerous goods.
When dangerous goods are to be moved by use of the Limited Quantity exemption, there are conditions that have to be met, such as the size, type and weight of the inner receptacles and the overall package. Once these conditions have been met, then the only thing that a driver will notice is the requirement to mark the vehicle as in my reply to you above.

As a (very) rough guideline, the max size of Limited Quantity is usually 5L, but some UN numbers have an even smaller allowance per receptacle. The ususal max overall size of a finished Limited Quantity package is 30kg, but some forms of package are only allowed to be a max of 20kg. This is all for the consignor and consignee to get sorted long before a driver arrives to load the stuff, so a driver isn’t usually involved in this.

As long as the conditions for the carriage of dangerous goods packaged in Limited Quantities have been met, there’s no requirement that they are all of the same UN number, so it’s perfectly possible that multiple UN Classes and multiple UN numbers are carried on the same vehicle.

The other exemption (sometimes called ‘the small load exemption’,) is only to be used when the dangerous goods are NOT packaged in Limited Quantities, such as IBCs, drums, jerricans, or other larger forms of package. This exemption is conditional upon the quantity of dangerous goods to be carried AND the level of danger posed by the dangerous goods.

ADR has 5 Transport Categories ( = levels of danger), which each have a ‘freebie’ allowance.

TC 0 = No freebies ( = Full ADR will ALWAYS apply to any/every load.)
TC 1 = 20kg/Ltr freebie ( = Full ADR will ALWAYS apply to any/every load once the limit is exceeded)
TC 2 = 333kg/Ltr freebie ( = Full ADR will ALWAYS apply to any/every load once the limit is exceeded)
TC 3 = 1,000kg/Ltr freebie ( = Full ADR will ALWAYS apply to any/every load once the limit is exceeded)
TC 4 = Unlimited freebie ( = Full ADR will NEVER apply, because there is no limit to the ‘freebie’.)

It is therefore possible that you could be asked to carry dangerous goods that fall into more that one Transport Category, but there is a way for the carrier to calculate whether full ADR applies to that job. This is the carrier’s repsponsibility NOT the driver’s.

It is also possible to carry some dangerous goods packaged in Limited Quantities PLUS some other dangerous goods packaged in ‘normal’ packages as long as the two separate exemptions are obeyed.

The mistake that many people make is to do a mix-and-match of the two exemptions, which is guaranteed to lead to confusion.