Dangerous goods advice- UK regs and ADR

Andrew Leitch:
Thank you dieseldave. :smiley:

Hi Andrew, that’s no problem mate, I’m always happy to help. :smiley:

Hi DD, just a quick note of thanks for posting your invaluable information, proved very useful and an excellent place for revision. I passed my ADR in November with L&T transport, excellent course.
Thanks again. Stu :smiley: :smiley:

teatree:
Hi DD, just a quick note of thanks for posting your invaluable information, proved very useful and an excellent place for revision. I passed my ADR in November with L&T transport, excellent course.
Thanks again. Stu :smiley: :smiley:

Hi teatree, Many thanks for that :smiley:

It’s always nice to know that my efforts are useful to folks.

:grimacing: CONGRATULATIONS on passing your ADR exams :smiley:
:smiley: :smiley: :grimacing: :smiley: :smiley: :grimacing: :smiley: :smiley:

I’ll still be here if you ever need me. :smiley:

hi dave,long time no speak.ive got a nice easy question for you…i think.weve started carrying things like cans of deodorant.normal stuff you can buy in the supermarket.typically i carry 26 pallets containing thousands of small cans.i think theyre class 2 and 3.some times the load is mixed…spray on and roll on.do i have to treat this as a hazardous load…orange plates etc? i have been,but im not sure its necessary due to the size of the containers.can you elaborate? :slight_smile:

R.D:
hi dave,long time no speak.ive got a nice easy question for you…i think.weve started carrying things like cans of deodorant.normal stuff you can buy in the supermarket.typically i carry 26 pallets containing thousands of small cans.i think theyre class 2 and 3.some times the load is mixed…spray on and roll on.do i have to treat this as a hazardous load…orange plates etc? i have been,but im not sure its necessary due to the size of the containers.can you elaborate? :slight_smile:

Hi R.D, I know what you mean mate, and you’re right too (well, very nearly :wink: )

Limited Quantity (LQ) stuff is best thought of as the kind of (dangerous goods) stuff any member of the public can buy in a retail outlet. Goods that are hardly dangerous, packaged in small receptacles contained in boxes no heavier than 30kgs.
As an alternative to boxes, shrink-wrapped trays may be used as a package for some LQ goods, but trays may only have a max weight of 20kgs each, so the consignors/consignees get some choice. Once the ‘stuff’ is packaged in one of those two ways, there’s a white diamond label that needs to be placed on the package, then you can load as many as your vehicle will carry, and you’ll not need to comply with any of ADR.

Here’s a typical box for Limited Quantity ‘stuff:’

Then they have to stick the relevant label on the box:
(In this case, UN 2984 is for hydrogen peroxide.)

The LQ code assigned to UN 2984 indicates that inner receptacles of no greater than 1 liter may be used for this product, hence the little 1 liter plastic bottles in the cardboard box above.

In the case of multiple UN numbers being contained in an LQ package, the consignor has two options.
Option #1. They’re allowed to put more than one UN number on the white label OR,
Option #2. They’re allowed to use white labels with just the letters “LQ” on them, which equally means that multiple UN numbers are contained within the package.

Aerosols are commonly carried in stretch-wrapped trays like this:
UN 1950 is a catch-all UN number for aerosols.

The LQ codes for aerosols indicate that an individual aerosol can have a max size of 1 liter, but for the nastier types of aerosol contents, this limit is reduced to 120ml.

As a point of interest, who decided to use the orange marker boards, and what reason did they give?

Shouldnt the small limited quantity stuff now carry a new label. Red E in a white background, they called it Exempted Quantitys?

Imp:
Shouldnt the small limited quantity stuff now carry a new label. Red E in a white background, they called it Exempted Quantitys?

Hi Imp, LQs and EQs are completely different animals mate.
They are both current, one has NOT replaced the other.

BTW. LQ = Limited Quantity, whereas EQ = Excepted Quantity.

I covered the subject of EQs (with a pic of the label you mentioned) in the last post on page #3 of this topic:
Dangerous goods advice- UK regs and ADR - SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE - Trucknet UK

Just to give you an idea of how different these two concepts are…

The largest possible size of LQs is 5 liters for liquids or 6kg for solids, but there’s no limit on how many of these can be carried.

The largest possible size of EQs is 30ml or 30g (Which is a smidge over an ounce in old money. :wink: )
If you carry EQs, the is an absolute limit of 1,000 packages per vehicle, which cannot be exceeded by anybody at any time, regardless of whether they have an ADR licence or 10 sets of orange plates. :smiley:

Argh yes ooopps brain fade there. Not come across EQ’s in my line of work yet!

hi dave,thanks for the quick reply,and youve stated what i suspected.theyre deodorant cans no bigger than 250ml each,wrapped on cardboard trays of 8 or so then stacked on pallets and shrink wrapped.we get the job from another transport company who ask us to supply an ADR trained driver with the appropriate vehicle.we then pick the load up from a storage warehouse who`s operatives have no or little knowledge of ADR regs…typical :wink: the 1st time i went there they asked if i was ADR trained before they loaded the vehicle.when they started loading i thought,hang on,thats limited quantities.after getting nowhere with the loaders,i put the plates up and went on my way.after spending 20 mins trying to get a tremcard off em i must add.do i need a tremcard for limited quantities??
what started me thinking was the other day one of our non ADR drivers refused to take a load.stating it was clearly an ADR load.when i got there to swap trailers with him he handed me the paperwork and moaned it was obvious he couldnt take it.the load was being taken to transport company then loaded into containers.so the paperwork included diamonds to go on that.i think that spooked our driver :laughing:

ive told my office before that im sure its non ADR as the individual cans arent in scope,but then they went on about the combined quantity.who am i to argue :unamused:

Hi R.D

:open_mouth: :wink:

This is probably going to end in tears for somebody in an office… :laughing: :laughing: :laughing:

R.D:
hi dave,thanks for the quick reply,and youve stated what i suspected.theyre deodorant cans no bigger than 250ml each,wrapped on cardboard trays of 8 or so then stacked on pallets and shrink wrapped.we get the job from another transport company who ask us to supply an ADR trained driver with the appropriate vehicle.

First question: Are there white diamond labels on the packages?

This looks like more LQ numptyism on the part of some office bods, so nothing new there then :unamused:
If there are white diamond labels on the packages, there is absolutely no legal need for an ADR trained driver regardless of the quantity of LQs carried.

R.D:
we then pick the load up from a storage warehouse who`s operatives have no or little knowledge of ADR regs…typical :wink: the 1st time i went there they asked if i was ADR trained before they loaded the vehicle.

That’ll not be the operatives’ fault, the blame for this nonsense rests in the office. :unamused:
A consignor should ask to see an ADR licence before loading enough dangerous goods onto a vehicle to trigger ADR into action. This isn’t required for the carriage of LQs, because LQs are EXEMPT ADR, so why would anybody need an ADR licence for that job ? :unamused:

R.D:
when they started loading i thought,hang on,thats limited quantities.after getting nowhere with the loaders,i put the plates up and went on my way.

You’re spot-on about the LQs, so why did you put the plates up?

R.D:
after spending 20 mins trying to get a tremcard off em i must add.do i need a tremcard for limited quantities??

Tremcards died in the UK on 01/07/09. They have been replaced by a four-page document that covers everything you could possibly carry. You didn’t need a Tremcard for LQs, nor do you need the new four-page document for LQs. If your office bods don’t know this, I’d suggest that you ask your boss who the firm’s DGSA is so that you can get good info to keep you legal. If firms carry enough dangerous goods to be subject to ADR, they’ve needed a properly qualified DGSA since 31/12/1999.

R.D:
what started me thinking was the other day one of our non ADR drivers refused to take a load.stating it was clearly an ADR load.when i got there to swap trailers with him he handed me the paperwork and moaned it was obvious he couldnt take it.the load was being taken to transport company then loaded into containers.so the paperwork included diamonds to go on that.i think that spooked our driver :laughing:

I can quite understand that mate, especially if the guy hasn’t had an ADR licence before.
I’ve covered the marking requirements for ISO containers in the first post at the very top of this page. If you read that, you’ll see that large ‘placard’ markings are required for any amount of dangerous goods carried in an ISO container, but the job might not need orange plates or an ADR licence.

R.D:
ive told my office before that im sure its non ADR as the individual cans arent in scope,but then they went on about the combined quantity.who am i to argue :unamused:

That’s tricky mate, it’s always difficult for a driver to tell office bods something, so you’re probably right to keep your head down. :wink:

However, you could always send them to me for an explanation of how their DGSA isn’t doing what a DGSA is supposed to do, followed by a straight fact that the combined quantity of LQs making any difference whatsoever is a classic ADR myth. The combined quantity rules are for use ONLY when the job ISN’T being done as LQs. :unamused:
LQs are their own system of EXEMPTION. There is absolutely NO linkage between those two concepts, you’re either doing the job one way, or you’re doing the job another (separate) way.
It’s not your fault R.D, but this shows that some office bods just aren’t fit for purpose. :unamused: :laughing: :grimacing:

Imp:
Argh yes ooopps brain fade there.

Hi Imp, Not to worry mate, that’s why I’m here to help everybody. :smiley:

:bulb: It’s only after talking about a subject and using the right language that true understanding is reinforced.

Imp:
Not come across EQ’s in my line of work yet!

The notion of excepted quantities (EQs) has already existed for quite a number of years in the Regs for carrying dangerous goods by air, known as IATA. EQs is just their version of what ADR calls LQs, the difference being that the individual package and receptacle size limits in IATA are tiny in comparison to what ADR allows as LQs.

Once you take into account that IATA is for aeroplanes and the potential consequences of any in-flight incident, you should be able to see why ADR allows exemption of much larger receptacles and packages in vehicles by road.
:bulb: Just remember that there are no lay-byes in the sky. :smiley: :stuck_out_tongue:

Due to the above differences between modal Regs (air and road,) there was a legal inconsistency for the drivers who haul air-freight by road. It was often the case that air freight in a truck fell to be regulated by ADR when it was already exempted from a more stringent set of Regs (IATA.) To address the problem, the regulatory authorities for the various modes got together and decided to copy and paste the EQ part of IATA into ADR for the purpose of standardising the modal Regs with each other. At the same time, it was also decided to copy and paste the EQ stuff from IATA into the Regs for carrying dangerous goods by sea (IMDG) and also into the Regs for carrying dangerous goods by rail (RID.) At least on the subject of EQs, the various modes of carriage are now all singing from the same hymn-sheet at last. :smiley:

Just one for “Diesel dave”

With regards to Fire extinguishers under ADR regs is there a legal requirement to have them serviced / checked / certified on an annual basis or is it legal just to ensure that they are in the “Green” zone on the gauge at all times ?

NEJ:
Just one for “Diesel dave”

With regards to Fire extinguishers under ADR regs is there a legal requirement to have them serviced / checked / certified on an annual basis or is it legal just to ensure that they are in the “Green” zone on the gauge at all times ?

I am going to jump in here, the extinguishers must be serviced and certified, the appliance must be sealed and the expiry date, not the testing date must be clearly visible.

In Europe we always had a problem with British fire appliances because the testers refused to do this, there were many 90FF exchanging hands in that period.

Dave I answered this one (correctly I hope) in exchange for that Pint of frothy Pivo you got me last week :stuck_out_tongue:

Thanks for the prompt reply on that one “wheel nut” and hopefully you are right.

And now the next question does the same rules apply to extinguishers in “non ADR vehicles” i.e. trucks fitted with say a 2kg fire extinguisher for example which are not on ADR work just general haulage etc. :question:

NEJ:
Thanks for the prompt reply on that one “wheel nut” and hopefully you are right.

And now the next question does the same rules apply to extinguishers in “non ADR vehicles” i.e. trucks fitted with say a 2kg fire extinguisher for example which are not on ADR work just general haulage etc. :question:

Definitely if they go abroad. I had 3 fire extinguishers in my French owned truck and they were often checked for the sticker in a control even when empty. Expiry date is the important one on all documents, certificates and licences in the EU. It may be a case of if they are there, they must be legal.

I found this on an H&S site
The portable fire extinguishers shall be:

Kitemarked (or equivalent independent approval) to EN3
Serviced to national standards (i.e. BS 5306-3) to guarantee functional safety

Clearly marked with the next service date (month, year format)
Installed on the transport units in a way that they are easily accessible to the vehicle crew

Installed in such a way that the fire extinguishers shall be protected against the effects of the weather so that their operational safety is not affected

Please note the above amends ruling of the ADR came in to force in British law on 1st January 2007 where upon it will be an offence not to adhere to these minimum extinguisher requirements.

Firstly our vehicles are not on international work.

Now this is where the grey area comes in as under current VOSA rules for NON-ADR vehicles it appears you don,t need a fire extinguisher in the cab or on the vehicle, but presumably if you do have one then it is a requirement that the extinguisher must be fully compliant!

Can you give me the details of the HSE website / section / page you found it on mate?

NEJ:
Firstly our vehicles are not on international work.

Now this is where the grey area comes in as under current VOSA rules for NON-ADR vehicles it appears you don,t need a fire extinguisher in the cab or on the vehicle, but presumably if you do have one then it is a requirement that the extinguisher must be fully compliant!

Can you give me the details of the HSE website / section / page you found it on mate?

hi mate found this

hse.gov.uk/cdg/manual/crew.htm#fireext

you may find this good as well

hse.gov.uk/cdg/manual/crew.htm

Wheel Nut:

NEJ:
Just one for “Diesel dave”

With regards to Fire extinguishers under ADR regs is there a legal requirement to have them serviced / checked / certified on an annual basis or is it legal just to ensure that they are in the “Green” zone on the gauge at all times ?

I am going to jump in here, the extinguishers must be serviced and certified, the appliance must be sealed and the expiry date, not the testing date must be clearly visible.

In Europe we always had a problem with British fire appliances because the testers refused to do this, there were many 90FF exchanging hands in that period.

Dave I answered this one (correctly I hope) in exchange for that Pint of frothy Pivo you got me last week :stuck_out_tongue:

Hi Malc and NEJ. :smiley:

Malc has this one spot-on!!

I’d just add that I covered the requirements for fire-extinguishers in the first post on page #3 of this sticky.

Here’s a link: Dangerous goods advice- UK regs and ADR - SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE - Trucknet UK
Just for you NEJ, that post covers the carriage of LQs, carriage below ADR threshold and carriage when full ADR applies. It even has some nice little piccies too, so how’s that for service?? :smiley:

I also agree that the UK fire-extinguisher service interval is one year.

:blush: :blush: Now then Malc, this is one time that being teetotal has come back to bite me, so I have to ask whether Pivo is some kind of beer??

dieseldave:
:blush: :blush: Now then Malc, this is one time that being teetotal has come back to bite me, so I have to ask whether Pivo is some kind of beer??

Pivo or Piwo certainly is Beer, as you understand the hazardous side of things, Beer has a couple of things with dangerous properties used in it’s manufacture.

UN 1170 which is more commonly known as Ethanol, other ingredients are added which have side effects, one makes things rise, and, well you get the idea!

Brewers Yeast and Brewers Droop :stuck_out_tongue:

Material Safety Data Sheet

Be careful what you drink.

Thanks for the replies to the question guys but I am still at a loss as to whether a fire extingusher is required for general haulage not just for “LQ`s”.

I did look at page 3 dave and it is simple in the requirements if you are on LQ`s but not on general as I said as I would think (possibly wrongly) that if you have an extinguisher whatever size then it must be serviced annually to comply ( a bit like if you have side marker lights then they must work if fitted).

But the question is one of is it a requirement to have a fire extinguisher in the cab / on the vehicle if you are not on ADR duties?

I can,t find anything on the VOSA / HSE website to confirm or deny this !