Dangerous goods advice- UK regs and ADR

[dieseldave]

delboytwo:
…on this one it has a small mark on the front of the unit with the letters EX to state that its the ADR one…

its was just some thing i was wondering if there are different ones would you be required to use that type for ADR work

Hi delboytwo, Thanks for the clarification.

The requirements that you’re asking about are really a subject for vehicle manufacturers and maintenance staff.
To a lesser extent, the vehicle owner is involved too.

In ADR there are some very stringent technical standards that have to be met by vehicles for the carriage of some substances. If it is intended that a vehicle is to be used for the carriage of some substances, the vehicle will need extra certification (type approval) and a technical certificate before it’s allowed to carry those substances. The requirements are such that some vehicles must be manufactured to these standards right from the start of their lives. As a rough rule of thumb, these requirements relate to the carriage of some flammable liquids and most explosives.

For the vast majority of ADR work, perfectly ordinary vehicles will suffice.
The dangerous goods list makes it clear which types of vehicles are allowed to carry which substances, but as this can also vary depending on quantities in some cases, so I can’t be too specific. It is the vehicle owner’s legal responsibility to give a driver the correct vehicle for any given ADR job.

In order that folks don’t worry too much, I’d suggest that this really isn’t anything for an employed driver to worry about, because an employed driver isn’t legally responsible for choosing which type of tachograph is fitted to a vehicle or for allocating a vehicle to a job.

[delboytwo]

thanks dieseldave

can i ask you this when you do adr work,and you have to have the correct PPE would the tacho be classed as such as the is a ADR one available.

i thinK from when i did my ADR we was told that you should be given all PPE required for the load you are carrying

if you get what i mean

[nej]

I don,t want to pr-empt dave on this one but as a H&S rep ALL ppe must be issued to all drivers free of charge including any ppe required for ADR work which may include such items as a rubber oversuit / long gloves (which reach up to or over the elbows) wellington boots / respirator etc.

This is non - negotiable with your employer as you under no circumstances must be asked to pay or be charged for such eqpmt.

It is also the responsibility of the employer to supply the correct eqpmt. for the product you will be carrying.

[dieseldave]

delboytwo:
thanks dieseldave

can i ask you this when you do adr work,and you have to have the correct PPE would the tacho be classed as such as the is a ADR one available.

i thinK from when i did my ADR we was told that you should be given all PPE required for the load you are carrying

if you get what i mean

Hi delboytwo, I can’t add a word to what NEJ has written, except to say that the law is very clear on the subject of PPE.

As for the tacho question… err… ahem… I’ve already answered it in my last post.

[fizza]

I have not long passed my adr packages and yes i probably should know this but you get taught 1 way and then people tell you something different so here we go tryed to find in my book
when i collect a load of hazardous goods “container driver by the way”
{1} Do i sign the dgn when i am takeing the container to be loaded on the train ?
{2} Do i sign the dgn when i am takeing it straight to the dock to be put on a ship?
{3} Do i never have to sign a dgn ?
{4} should i always sign the dgn?

Rather seem like a fool now than when i get stopped
Cheer’s in advance

[nej]

On this one mate I always sign the DGNs as when you go to the docks / railhead with a container (as I am on containers as well) I have been turned away at the booking in desk cos the DGNs haven,t been signed by either me or the driver who collected the load.

Also once at Felixstowe I was turned away because the “loader / responsible person” hadn,t signed the DGN`s either on behalf of the manufacturer / warehouse!

You as the driver are as far as I am aware (but I stand to be corrected on this one by Dave) are not responsible for the actual load in the container such as it being segregated correctly if it is a mixed load.

[dieseldave]

NEJ:
On this one mate I always sign the DGNs as when you go to the docks / railhead with a container (as I am on containers as well) I have been turned away at the booking in desk cos the DGNs haven,t been signed by either me or the driver who collected the load.

Hi NEJ, This one is going to depend on which type of DGN a person is using…
ADR provides a blank example of a multi-modal DGN, but there are different versions in use eg. SITPRO produce a good DGN and it includes advice on the reverse on how to complete it. Some of the shipping lines have their own in-house versions of a DGN too.

NEJ:
Also once at Felixstowe I was turned away because the “loader / responsible person” hadn,t signed the DGN`s either on behalf of the manufacturer / warehouse!

Quite right too!!
The person responsible for stowing and securing the goods on/in the vehicle/container must sign this part. That’s quite a hefty responsibility if sea transport is involved, due to the wording of the sea Regs. As general advice, I’d suggest that a vehicle driver shouldn’t sign this part of the form if they’re in any way unsure that the standard of stowing and securing meets all applicable requirements. I wouldn’t wish to scare folks at this point, but there are circumstances, usually after some kind of spillage/incident that signing that part of the form might come back and bite somebody in the ■■■.

NEJ:
You as the driver are as far as I am aware (but I stand to be corrected on this one by Dave) are not responsible for the actual load in the container such as it being segregated correctly if it is a mixed load.

I wouldn’t attempt to correct that which is already correct.

[dieseldave]

fez:
I have not long passed my adr packages and yes i probably should know this but you get taught 1 way and then people tell you something different so here we go tryed to find in my book
when i collect a load of hazardous goods “container driver by the way”
{1} Do i sign the dgn when i am takeing the container to be loaded on the train ?
{2} Do i sign the dgn when i am takeing it straight to the dock to be put on a ship?
{3} Do i never have to sign a dgn ?
{4} should i always sign the dgn?

Rather seem like a fool now than when i get stopped
Cheer’s in advance

Hi fez, I might not actually be the best person to help with ‘container’ questions, because I’ve never done, or even been involved with that work. I can tell you that there’s nothing in ADR itself that actually requires a registration number to be written on a transport document.
I’ll stick to the dangerous goods element of your question.

The reason you don’t know the answer to this is that it wasn’t taught as part of your ADR course.
It’s the same reason that it’s also not in your textbook.
You’ll remember the ADR definitions and responsibilities of ‘consignor’ and ‘carrier,’ and that the consignor is responsible for providing your paperwork. The carrier (your boss if you’re an employed driver) is responsible to ensure that you have copies of the paperwork.

ADR provides an example of an acceptable multi-modal DGN, so I’ve reproduced it below:
There are also other perfectly acceptable versions of DGNs, as in my answer to NEJ.

In the version above, you’ll see that the carrier completes box #7 so as the driver, you can fill in this part with details of the firm you work for.
(No need for a registration number, but you can write it in the box if you want. )

There are a couple of areas of a DGN which I’d suggest need to be noted by drivers…
The shipper’s declaration:

SHIPPER’S DECLARATION
I hereby declare that the contents of this consignment are fully and accurately described
below by the proper shipping name, and are classified, packaged, marked and labeled /placarded and are in all respects in proper condition for transport according to the applicable international and national governmental regulations.

As a driver, I wouldn’t fancy putting my signature to that legal statement, but that’s just me…

Statement in connection with BOX #20

CONTAINER/VEHICLE PACKING CERTIFICATE
I hereby declare that the goods described above have been Received the above number of packages/containers/trailers in apparent good order and condition packed/loaded into the container/vehicle identified above in accordance with the applicable provisions **
MUST BE COMPLETED AND SIGNED FOR ALL
CONTAINER/VEHICLE LOADS BY PERSON
RESPONSIBLE FOR PACKING/LOADING

As a vehicle driver, and without any additional training on load securing to the correct standards, I wouldn’t sign this part either. Or to put it another way, how would I know whether my version of securing and stowing meets the requirements mentioned in the sea transport Regs.■■

In connection with BOX #21:

21.RECEIVING ORGANISATION RECEIPT
Received the above number of packages/containers/trailers in apparent good order and condition unless stated hereon: RECEIVING ORGANISATION REMARKS:

Haulier’s name

Vehicle reg. no.

Signature and date

DRIVER’S SIGNATURE

From my reading of this, the “receiving organisation” fills in this part, so, as a vehicle driver, I wouldn’t write anything here either. It seems to me that this is for the ‘consignee’ to sign.

In connection with BOX #22:

22. Name of company (OF SHIPPER PREPARING THIS NOTE)

Name / Status of declarant

Place and date

Signature of declarant

You’ll notice that BOX #22 of the form above is shaded in grey, so I’d say it goes with the ‘Shipper’s Declaration’ in the other grey shaded area of the form.

As for signing the DGN, I’d say it’s a question of whether you think that the part called “driver’s signature” in the bottom center of the form above is part of BOX #21 or not.

As pointed out by OVLOV JAY in another post, ( HERE ) there’s no harm in having a separate ADR compliant ‘transport document’ to cover the part of the overall journey during wich the container is actually on board your vehicle. If you did this, there’s no requirement for either a driver’s signature or a registration number, because ADR’s requirents for a transport document are quite simple compared to IMDG’s requirements. Therefore, if you have an IMDG compliant transport document on board your vehicle, you’re far in excess of ADR’s requirements and therefore bullet-proof (transport document-wise) if you’re stopped on the road.

fez:
Rather seem like a fool now than when i get stopped

No mate, you’re no fool, and the fact that you asked the question proves it.

I hope this helps… a bit… maybe…

[nej]

Hi dave, ref: to the signing of the DGN`s on containers when delivering to such places as Railheads & Docks, if you turn up with the co.name / vehicle reg. / drivers signature missing off the docs. they will not:

A) Acccept the Container,

B) Turn you away even if you are not the driver who loaded & or delivered the box ex depot as some other driver loaded it, as it also it annoys me when some of our lazy drivers don,t sign the DGN`s and just take the box back to our yard for a lift off for someone else to take to the docks or railhead!

As personally I don,t like signing for someone elses load as you say it might come back to bite you with a vengeance!

[dieseldave]

Copied from here: ADR + driving licence counterpart? - SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE - Trucknet UK

thedeerhunter270:

My boss tells me, its law, I must carry both parts of my driving licence when carrying hazardous goods?

I can’t see why - but there you go.

Hi thedeerhunter270, the regulations for carrying dangerous goods come in several ‘layers,’ depending on the method of packaging and/or the total amount carried.

If you’re carrying Limited Quantities, Excepted Quantities, or a load that’s below the relevant ADR transport category threshold for the goods, then you’ll not need an ADR certificate.

If the load you’re carrying is in excess of the relevant ADR threshold for the transport category of the goods, you need the extinguishers, orange boards, documentation, ADR licence etc.

What I think your boss might mean is that when you’re carrying a load that’s in excess of the ADR threshold, you need a form of photographic ID ALSO. BTW, this has been the case since 2005 in the UK. I imagine that your boss thinks it’s easier for him to require you to carry your photocard driving licence in order to meet that requirement.

To answer your original question as you wrote it, there’s no requirement as such to carry both parts of your driving licence when carrying dangerous goods.

[nej]

Just one for dave on fines for non-compliance of safety equipment.

If the Police / Vosa do a “Hazmat” road side check and a PG9 (delayed or immediate is issued), if there is a prosecution for non-compliance of the above does the consignor and carrier or the driver receive a fine or all are fined?

I understand that the Police / VOSA enforce the ADR regs on behalf of the HSE but I contacted the HSE & they put me in touch with the DFT who said they didn,t know either so they couldn,t answer the question as the HSE said it was the responsibility of the DFT to enforce the law.

Going back over old ground could you tell me, as we collect batteries from overseas in containers for delivery in the UK, they are marked with placards showing class 8 corrosives I assume that only ADR qualified drivers would be allowed to transport them by road, but one of our shipping agents says that the regs have changed and if the batteries are palletised and cannot fall over or be damaged in transit and are secure in the container, then ADR regs don,t apply but my argument is that as containers are sealed at the loading point for transit by sea, you as the driver do not know if the batteries have fallen over or are damaged in transit and may be leaking and therefore are imho covered by ADR regs.

BTW dave I will do my best to arrange the meeting with the pope some time in July due to possible work commitments in June !

[mrflibble]

Hi Dave,

I note your previous post on LPG Propane cylinders where the limit is 333 kg nett total, but I’m pretty sure that that’s not the LQ limit is it?

I’m pretty sure we’ve talked about it on the phone, but it’s probably a good idea to get it written down so that it’s useful for other people (and I’ve forgotten what you said… )

What would be the LQ limits on:

1. LPG Propane for driver’s personal use (cooking, etc.)
2. LPG Propane used as fuel for a forklift carried on the vehicle

I’m thinking of both ADR and IMDG here, as we have to do some of our journey by boat.

TIA…

[dieseldave]

NEJ:
Just one for dave on fines for non-compliance of safety equipment.

If the Police / Vosa do a “Hazmat” road side check and a PG9 (delayed or immediate is issued), if there is a prosecution for non-compliance of the above does the consignor and carrier or the driver receive a fine or all are fined?

Sorry NEJ, but this is outside a DGSA’s remit.
I could take a lot of space with my answer to this by quoting from the definitions and responsiblities of those concerned in the carriage of dangerous goods in the UK, but it really boils down to the internal procedures of whichever organisation (police/vosa/hse) discovers an offence and their policy on how it’s to be prosecuted. Sorry if I appear to be evasive, but IMHO your question on enforcement and penalties is best put to a practicing H&S lawyer.

What I can tell you though is that our CDG Regs contain no details of penalties and that they’re made under the Health and Safety at Work etc Act 1974, hence penalties being outside my remit as a DGSA.

NEJ:
I understand that the Police / VOSA enforce the ADR regs on behalf of the HSE but I contacted the HSE & they put me in touch with the DFT who said they didn,t know either so they couldn,t answer the question as the HSE said it was the responsibility of the DFT to enforce the law.

I have a feeling that you maybe didn’t speak to the appropriate person at the HSE, because it is written UK law that:

CDG 2007 Reg 92:
Enforcement
92.–(1) The enforcing authorities for these Regulations are–
(a) the Health and Safety Executive in relation to road and rail;
(b) the Secretary of State for Transport in relation to road and inland waterways; and
(c) the chief officer of police of each area in relation to road.

I wonder what the appropriate person at the HSE would make of their colleague’s answer to you.

NEJ:
Going back over old ground could you tell me, as we collect batteries from overseas in containers for delivery in the UK, they are marked with placards showing class 8 corrosives I assume that only ADR qualified drivers would be allowed to transport them by road, but one of our shipping agents says that the regs have changed and if the batteries are palletised and cannot fall over or be damaged in transit and are secure in the container, then ADR regs don,t apply but my argument is that as containers are sealed at the loading point for transit by sea, you as the driver do not know if the batteries have fallen over or are damaged in transit and may be leaking and therefore are imho covered by ADR regs.

Ahh, a straightforward question…
I suspect that the agent is correct.

The question is about carrying either UN 2794 or UN 2795?</Mystic Dave mode.>
If I’m correct in that, then SP598 applies:

598
The following are not subject to the requirements of ADR:
(a) New storage batteries when:

• they are secured in such a way that they cannot slip, fall or be damaged;
• they are provided with carrying devices, unless they are suitably stacked, e.g. on pallets;
• there are no dangerous traces of alkalis or acids on the outside;
• they are protected against short circuits;
  (b) Used storage batteries when:
• their cases are undamaged;
• they are secured in such a way that they cannot leak, slip, fall or be damaged, e.g. by stacking on pallets;
• there are no dangerous traces of alkalis or acids on the outside of the articles;
• they are protected against short circuits.
  “Used storage batteries” means storage batteries carried for recycling at the end of
  their normal service life.

The only thing I’d add to that is that it’s fine as long as it’s written on the paperwork that the carriage is ADR exempt by SP 598.

The fact that a driver can’t check inside a sealed container means that you can take the agent’s word for it that everything inside it is compliant.

NEJ:
BTW dave I will do my best to arrange the meeting with the pope some time in July due to possible work commitments in June !

I’ve heard that one before.

[dieseldave]

MrFlibble:
I note your previous post on LPG Propane cylinders where the limit is 333 kg nett total, but I’m pretty sure that that’s not the LQ limit is it?

Hi MrFlibble, There’s no connection between the 333kgs nett ‘freebie’ and the notion of Limited Quantities.

Written on ADR documentation correctly, what you’re carrying is:
UN 1978 PROPANE, 2.1 (B/D)
Transport Category 2

The LQ code for propane is: LQ0, which means that there is NO LQ exemption available under ADR 3.4.6, however that’s got NOTHING to do with the 333kg nett ‘freebie’ limit, which is in ADR 1.1.3.6. (Very different. )
Under ADR (by road) you get to carry 333kg nett of propane without the full weight of the ADR Regs applying to you, because it’s in Transport Category 2. This is a completely different exemption, because this exemption applies per vehicle NOT per package.
In practice, this means that you can carry propane in gas cylinders on a vehicle (truck) by road in quantities UP TO 333kgs nett. ( don’t count the gross weight of the cylinder in the calculation. )Therefore, you can carry any combination of cylinder sizes, PROVIDED that you don’t exceed 333kgs nett per vehicle.

If you can comply with the above, all that needs to be on the vehicle is 1 X 2kg dry-powder fire-extinguisher. NO orange boards, NO ADR licence, NO Tremcard (IIW), NO extra vehicle equipment.
There’s one extra requirement for an international road journey: You will need a correctly completed ‘transport document,’ which can be a CMR, but I’d stress that the way of filling in the required info on a CMR is very important.

MrFlibble:
What would be the LQ limits on:

1. LPG Propane for driver’s personal use (cooking, etc.)
2. LPG Propane used as fuel for a forklift carried on the vehicle

I’m thinking of both ADR and IMDG here, as we have to do some of our journey by boat.

I’m guessing that a driver would have butane as cooker fuel, but that’s not really going to affect anything here.
Sorry mate, but again I’m going to have to say: forget Limited Quantities.
The drivers’ cooker fuel is for private use, therefore that is ADR exempt (1.1.3.1) and DOESN’T count towards the 333kgs load limit.

To answer your Q2, I need a little clarification please…
Are you carrying a whole FLT with an attached propane cylinder as its fuel, or are you saying that the purpose of the propane cylinders you’re carrying is to power FLTs when you get to your destination??

As far as a sea journey by ferry is concerned when carrying <333kgs nett propane, the IMDG Code isn’t of concern to you, except…
You’ll need a multi-modal dangerous goods note (DGN) to present to the booking clerk, you’ll be issued 3 placards per vehicle carrying propane, which will need to be placed: one on each side and one on the rear
Size = 250mm X 250mm
You’ll also need to obey any instructions given by the ship’s crew with regard to where they want you to park your vehicle whilst it’s on the ferry.
TIP: Only place these placards on the vehicle(s) for the ferry journey, THEY AREN’T REQUIRED BY ROAD, so I’d remove them the minute you get off the ferry.

[mrflibble]

dieseldave:

MrFlibble:
I note your previous post on LPG Propane cylinders where the limit is 333 kg nett total, but I’m pretty sure that that’s not the LQ limit is it?

Hi MrFlibble, There’s no connection between the 333kgs nett ‘freebie’ and the notion of Limited Quantities.

Yes, that’s what I thought from reading your earlier posts.

dieseldave:

MrFlibble:
What would be the LQ limits on:

1. LPG Propane for driver’s personal use (cooking, etc.)
2. LPG Propane used as fuel for a forklift carried on the vehicle

I’m thinking of both ADR and IMDG here, as we have to do some of our journey by boat.

I’m guessing that a driver would have butane as cooker fuel, but that’s not really going to affect anything here.
Sorry mate, but again I’m going to have to say: forget Limited Quantities.
The drivers’ cooker fuel is for private use, therefore that is ADR exempt (1.1.3.1) and DOESN’T count towards the 333kgs load limit.

Yes, that’s what I thought from our previous conversation (there’s an echo in here )

dieseldave:
To answer your Q2, I need a little clarification please…
Are you carrying a whole FLT with an attached propane cylinder as its fuel, or are you saying that the purpose of the propane cylinders you’re carrying is to power FLTs when you get to your destination??

OK, I’ll go into a bit more detail. The reason for asking is twofold:

1. Whilst on the Easter convoy, someone (I can’t remember who) pointed out to one of our drivers that the fact that he was carrying two cylinders of propane (25 kg each IIRC) meant that ADR applied, and that the fact that it was two separate cylinders was the issue - only one cylinder was allowed, irrespective of the size. I smelt a “MMTM” rat, and thought I’d get it confirmed by someone who knows what he’s talking about

The cooking fuel is definitely propane (I know I’m colourblind, but I know the difference between a bright red cylinder and a bright blue one… ), as the driver in question often cooks for the whole convoy when they stop overnight in a layby (or have a fry-up in the morning), so they’ve got a big 3-burner cooker. However, as it’s probably legitimate to claim it as “private use”, it’s irrelevant as you say.

In my case, yes I carry butane, but it’s a much smaller cylinder (only a couple of kg).

1. I am considering trying to get a forklift which we would be carrying on the vehicle with the gas. I haven’t decided whether to go for diesel or LPG yet - both have their advantages.

If I decide to go with LPG, then we would, at the very least, carry one cylinder on the forklift itself, plus one spare so that one can be in use whilst the other is taken away for refilling. The spare cylinder could travel on another vehicle if that makes life easier.

I probably couldn’t get away with claiming that forklift fuel was “personal possessions”, so that would would probably have to be covered under the regs.

At the moment, the second question is somewhat hypothetical as you can see, but needless to say, any hassle we’d need to go through for ADR etc. would influence the choice of forklift (i.e. diesel-powered vs LPG-powered)

[dieseldave]

MrFlibble:

dieseldave:

MrFlibble:
I note your previous post on LPG Propane cylinders where the limit is 333 kg nett total, but I’m pretty sure that that’s not the LQ limit is it?

Hi MrFlibble, There’s no connection between the 333kgs nett ‘freebie’ and the notion of Limited Quantities.

Yes, that’s what I thought from reading your earlier posts.

Hi MrFlibble, No problems there then.

dieseldave:

MrFlibble:
What would be the LQ limits on:

1. LPG Propane for driver’s personal use (cooking, etc.)
2. LPG Propane used as fuel for a forklift carried on the vehicle

I’m thinking of both ADR and IMDG here, as we have to do some of our journey by boat.

I’m guessing that a driver would have butane as cooker fuel, but that’s not really going to affect anything here.
Sorry mate, but again I’m going to have to say: forget Limited Quantities.
The drivers’ cooker fuel is for private use, therefore that is ADR exempt (1.1.3.1) and DOESN’T count towards the 333kgs load limit.

No problems here either…

MrFlibble:
Yes, that’s what I thought from our previous conversation (there’s an echo in here )

Spot-on again mate.

dieseldave:
To answer your Q2, I need a little clarification please…
Are you carrying a whole FLT with an attached propane cylinder as its fuel, or are you saying that the purpose of the propane cylinders you’re carrying is to power FLTs when you get to your destination??

Aha, now you can see why I asked.

MrFlibble:
OK, I’ll go into a bit more detail. The reason for asking is twofold:

1. Whilst on the Easter convoy, someone (I can’t remember who) pointed out to one of our drivers that the fact that he was carrying two cylinders of propane (25 kg each IIRC) meant that ADR applied, and that the fact that it was two separate cylinders was the issue - only one cylinder was allowed, irrespective of the size. I smelt a “MMTM” rat, and thought I’d get it confirmed by someone who knows what he’s talking about

That guy hasn’t a clue.
The number of cylinders makes absolutely no difference, the ‘freebie’ limit is 333kgs nett, so he’s made up his answer from complete nonsense.
Even 2 of the largest propane cylinders is nowhere near half of the limit, he’s miles out.
In fact, you can carry seven of the large (47kg nett) propane cylinders and still be exempt.
7 X 47kgs = 329kgs, just nicely inside the limit.

MrFlibble:
The cooking fuel is definitely propane (I know I’m colourblind, but I know the difference between a bright red cylinder and a bright blue one… ), as the driver in question often cooks for the whole convoy when they stop overnight in a layby (or have a fry-up in the morning), so they’ve got a big 3-burner cooker. However, as it’s probably legitimate to claim it as “private use”, it’s irrelevant as you say.

I’d insert a little note of caution just here…
If it were me, I’d make sure that the cylinder is connected to the cooker and the valves turned off, as it might be hard to convince a foreign enforcement official that a ‘loose’ cylinder isn’t part of the cargo, unless you’re well below the 333kgs nett ‘freebie’ limit.
Also, propane and butane would have to be totalled together if they’re cargo, because they’re both in the same Transport Category, so the 333kgs nett ‘freebie’ limit would apply to the whole total.

MrFlibble:
In my case, yes I carry butane, but it’s a much smaller cylinder (only a couple of kg).

You can have a larger cylinder, but I’d leave it connected to the cooker to avoid any possible confusion with foreign enforcement types.

MrFlibble:

1. I am considering trying to get a forklift which we would be carrying on the vehicle with the gas. I haven’t decided whether to go for diesel or LPG yet - both have their advantages.

If I decide to go with LPG, then we would, at the very least, carry one cylinder on the forklift itself, plus one spare so that one can be in use whilst the other is taken away for refilling. The spare cylinder could travel on another vehicle if that makes life easier.

Strange to relate, but the LPG cylinder correctly mounted and connected to the FLT wouldn’t count either.
Yet another (different) exemption at work here.
Only the spare LPG cylinder(s) would count towards the 333kgs nett ‘freebie’ limit.
(Remember that the 333kgs nett is per vehicle. )

MrFlibble:
I probably couldn’t get away with claiming that forklift fuel was “personal possessions”, so that would would probably have to be covered under the regs.

The FLT defo isn’t personal use, that’s why I’ve come up with a different exemption for it.

MrFlibble:
At the moment, the second question is somewhat hypothetical as you can see, but needless to say, any hassle we’d need to go through for ADR etc. would influence the choice of forklift (i.e. diesel-powered vs LPG-powered)

There’d be no influence from ADR to affect your choice of LPG Vs Diesel for an FLT carried as cargo, because the Diesel fuel contained in the FLT’s normal fuel tank would attract the same exemption, so please don’t let that be a limiting factor in your choice of FLT.

If you weren’t carrying any other dangerous goods, and you carried a diesel-powered FLT, you could fill the FLT’s tank AND carry 1,000ltrs of Diesel, cos the ‘freebie’ limit for Diesel is 1,000ltrs. Still per vehicle too. Just imagine, 5 X 200ltr drums of Diesel on board, and STILL being exempt from the vast majority of ADR.
It’s all true I tell ya!!

Knowing what you do, I can think of lots of perfectly legitimate ways that you could carry tons of dangerous goods on a convoy without any of your drivers needing ADR or you getting involved in lots of formalities. It’s simply a case of me knowing and employing the correct exemptions, whilst never forgetting that most exemptions have one or two little conditions attached.

[mrflibble]

dieseldave:
That guy hasn’t a clue.

That’s what I thought

dieseldave:
If it were me, I’d make sure that the cylinder is connected to the cooker and the valves turned off, as it might be hard to convince a foreign enforcement official that a ‘loose’ cylinder isn’t part of the cargo, unless you’re well below the 333kgs nett ‘freebie’ limit.

Well,

1. He’d be well below the “freebie” limit, as I doubt he’d be carrying more than 50 kg
2. It’s pretty obvious what it’s intended for - the cooker is strapped to the load bars on the body sidewalls at the back, and the bottles are strapped underneath
3. In my case, I use a pallet tank (folding plastic box the size of a pallet) to contain all my personal stuff (clothes, tools, truck spares, cooking equipment, etc.), so it’s pretty obvious - partly to avoid the customs people thinking that my personal stuff is part of the load, and partly to avoid my personal stuff ending up being part of the load, as I’ve already lost a sleeping bag that way… .

dieseldave:
Also, propane and butane would have to be totalled together if they’re cargo, because they’re both in the same Transport Category, so the 333kgs nett ‘freebie’ limit would apply to the whole total.

Yes, I assumed that would be the case.

[mrflibble]

dieseldave: You have a PM

[andydisco]

Dave

heres a question for you

can you carry an ibc with 1000 litre of red diesel in and a cage containing an oxygen cylinder and an acetylene cylinder on the same vehicle ? i reckon you cant as its a mixed load but our DGSA says i can whos right?

[dieseldave]

Andydisco:
Dave

heres a question for you

can you carry an ibc with 1000 litre of red diesel in and a cage containing an oxygen cylinder and an acetylene cylinder on the same vehicle ? i reckon you cant as its a mixed load but our DGSA says i can whos right?

Hi Andydisco, your DGSA is correct mate.

You’re spot-on about mixed loads though and there are certain mixed loads that aren’t permitted, so you were quite right to ask your DGSA in case somebody was trying to mislead you.

You did get a good answer, so all’s well that ends well.