GlesgaBill:
I’ll have a stab before Dave comes along and puts you & I to rights
The firelighters you speak of would appear to be class 4.1 (Flammable solid) and are packing group 3, which means they could be carried up to 1000 kgs before the ADR regs kicked in.
Hi GlesgaBill, You’re spot on about firelighters being in Class 4.1 and PGIII, but they’re in Transport Category 4, so there’s no limit which would trigger full adherance to all the ADR Regs.
Correctly written, the ‘entry’ for firelighters looks like this:
UN 2623 FIRELIGHTERS, SOLID, 4.1, PGIII
The little trick about PGIII putting the stuff into Transport Category 3 with the 1,000kg/ltr limit doesn’t always work for everything all the time, because that’s only a rule of thumb.
jody1980:
it all goes on the size of the receptical mate… classes as ltd qty.
Hi jody1980, sorry mate, but what you said is a pretty good rule of thumb, but isn’t the case with firelighters.
jody1980:
.use to carry batteries with corrosive stickers on but there only haz at sea…
Batteries count as dangerous goods by road AND sea, but they’re exempt by road because of a special provision relating to batteries which is nothing to do with Limited Quantities.
Under this special provision, there are just a few little conditions to be complied with in order to be able to take advantage of using the special provision. I’ve written more fully about the subject of carrying batteries by road in the ADR ‘sticky’ in the H&S forum.
Santa:
Perhaps the point here is — Who is responsible?
I am not ADR trained so how am I supposed to know what is and what isn’t subject to the regulations? I take the view that it is the shipper’s responsibility to tell me.
Obviously some common sense prevails so a load of 45gallon drums with haz stickers on might be suspect, but like others here I have often carried stuff like lighter fuel, cartridges, etc having accepted the word of the shipper that it’s OK.
So — if I was found carrying hazardous goods would it be the shipper or me in the dock?
Hi Santa, that’s an excellent question mate, and one which every driver should consider.
It is for the consignor (sender) and the carrier (vehicle owner) to sort this out.
Since both of them also have a legal duty to appoint a qualified DGSA, they shouldn’t have much trouble being compliant or understanding their responsibilities.
If somebody tells you that there’s any kind of exemption in ADR for what you’re carrying, just ask them to write that fact on the paperwork, then you’re sorted.
muckles:
I remember some years ago it was big news about a load of radioactive matirial taken from the former Soviet Union to a plant in Scotland for reprocessing.
The news crews filmed a convoy which consisted of a couple of trucks carring the stuff and what looked like the entire Scotish police force and probably some military vehicles.
Considering that all concerned knew what was being carried I thought the orange plates and trem cards displayed on the trucks seemed a bit unnesserary.
Hi muckles, that sounds about right mate.
That story reminds me of reading tremcards…
I once read the tremcard for plastic explosive and all was going well until I read the ‘first-aid’ section.
It simply said ‘Not applicable.’
Santa:
Perhaps the point here is — Who is responsible?
I am not ADR trained so how am I supposed to know what is and what isn’t subject to the regulations? I take the view that it is the shipper’s responsibility to tell me.
Obviously some common sense prevails so a load of 45gallon drums with haz stickers on might be suspect, but like others here I have often carried stuff like lighter fuel, cartridges, etc having accepted the word of the shipper that it’s OK.
So — if I was found carrying hazardous goods would it be the shipper or me in the dock?
The “Consignor” (sender) has the resposibility to make sure that dangerous goods are marked & packaged as such including appropriate paperwork.
You would be the “Carrier” and would be required under The Carriage of Dangerous Goods & ADR regulations to be aware & trained etc to carry what you have on your lorry.
There may well (and i’ve been told there has been by my ADR instructor) be cases where “Consignors” have sent goods (ie-a black shrink wrapped security taped pallet of Hazardous chemicals etc) and have intentionally not informed the carrier that the goods are dangerous. In this instance, in the event of an accident say, you would be absolved of any blame, but the consignor would get their chuckies felt big style!
Is there some-one in your Transport Office who deals specifically with Hazchem? They should be able to tell you what’s above/below limits etc.
We have a designated person-who has a DGSA on the end of the phone whenever necessary.
Spot-on mate, except for the “carrier” part…
The carrier is (more or less) the owner of the vehicle, so an O/D would be both ‘carrier’ and ‘driver’ if they drive the vehicle themselves.
An employed driver is exactly that— a driver.
A carrier has far greater responsibilities than a driver under ADR.
Take a motorsport team wether it be a major one or a small clubman out for a weekends fun. Many carry there fuel and some carry exotic petrol in 45 gallon drums. So Obviously 1 drum is fine but what if they have multiple drums? Guessing their fine as there in 45 gallon drums and under the 333ltr threshold?
Hi Imp, a very interesting question indeed.
If the petrol is being moved as freight by a haulier under a transport contract and they’re making a charge for delivery then the 333ltr ‘trigger’ limit will apply before all the ADR Regs must be obeyed in full.
However, there are a number of ADR exemptions relating to the carriage of liquid fuels and yet another exemption relating to ‘private’ carriage, any of which might be utilised depending on who is doing the driving and the use to which the fuel is to be put.
i have been in our works van i.e transit, movano etc. carrying a 1000ltrs of diesel in a ibc,
wud this b under adr regs?
Hi mark h, As you’ve described above, you wouldn’t need an ADR licence or orange boards, because 1,oooltrs of diesel CAN be carried by a non-ADR trained driver.
There are quite a few exemptions which would cover you for this, but you’d best NOT carry any more than 1,000ltrs of diesel at a time. Any empty receptacles carried in addition to the full IBC don’t count though…
dieseldave:
That story reminds me of reading tremcards…
I once read the tremcard for plastic explosive and all was going well until I read the ‘first-aid’ section.
It simply said 'Not applicable.’
jody1980:
it all goes on the size of the receptical mate… classes as ltd qty.
Hi jody1980, sorry mate, but what you said is a pretty good rule of thumb, but isn’t the case with firelighters.
jody1980:
.use to carry batteries with corrosive stickers on but there only haz at sea…
Batteries count as dangerous goods by road AND sea, but they’re exempt by road because of a special provision relating to batteries which is nothing to do with Limited Quantities.
Under this special provision, there are just a few little conditions to be complied with in order to be able to take advantage of using the special provision. I’ve written more fully about the subject of carrying batteries by road in the ADR ‘sticky’ in the H&S forum.
dave i’m under the understanding that with ltd qty in a container that if the boxes are shinkwraped on a pallet they come under adr but if they are loose they are ltd qty… i was advised by my dgsa…
