matchbox:
I worry just who, should VOSA or whoever pull over one of our vehicles, will get wrong when it is found that just about every day, non ADR lads are going out in our place over their LQ’s
“Limited Quantities” (LQs) is a commonly misunderstood concept. (That statement includes many bosses and ADR trained drivers.) LQs relate to the size of an inner receptacle packed inside some other form of package. If you comply with this, there is NO LIMIT to the amount on the vehicle. The LQ exemptions are usually used for movements of dangerous goods packaged ready for retail sale to the public. LQs are a way of transporting SOME less dangerous “stuff” without being over-burdened by the full weight of the regulations. For instance, LQ exemptions wouldn’t be allowed for exocet missiles or hand grenades!!
matchbox:
since our place is using the 1000 unit rule on all but class 2 chemicals.
UN Class 2 is gases and NOTHING ELSE
I’m guessing, but maybe they/you mean transport category 2, which is a different thing altogether. The limit for transport category 2 is 333 litres/Kgs.
matchbox:
I know it’s wrong to blanket 1000unit rule the stuff, but when trying to brooch this subject I have been scowled at.
There is a limit of 1,000 litres/kgs for “stuff” in transpot category 3 (Don’t confuse this with UN Class 3, which is flammable liquids ONLY)
matchbox:
“Whatever,” Thats my attitude now, but I do worry that as one of the vehicle loaders, as well as a driver also, WITH an ADR, should I not be checking all of the HAZ that comes thru?
If you work as a loader, you need EXTRA training not covered on an ADR course. ADR is a course for DRIVERS. A loader usually works for a "consignor "or a “carrier,” both of which have legal definitions and RESPONSIBILITIES. Without the LEGALLY REQUIRED function-specific training what exactly would you be checking and how??
ADR 2007 1.3.2.2 Function-specific training
Personnel shall receive detailed training, commensurate directly with their duties and responsibilities in the requirements of the regulations concerning the carriage of dangerous goods.
AND
ADR 2007 1.2.1
“Loader” means any enterprise which loads dangerous goods into a vehicle…
“Carrier” means the enterprise which carries out the transport operation
AND
The requirements of 1.2.1… concerning the definitions of participants and their respective obligations shall not affect the provisions of domestic law concerning the legal consequences (criminal nature, liability, etc.) stemming from the fact that the participant in question is e.g. a legal entity, a self-employed worker, an employer or an employee.
“Our hero” may find this of interest:
ADR 2007 1.4.2.2.4 If, during the journey, an infringement which could jeopardize the safety of the operation is observed, the consignment shall be halted as soon as possible bearing in mind the requirements of traffic safety, of the safe immobilisation of the consignment, and of public safety. The transport operation may only be continued once the consignment complies with applicable regulations.
Clue: a leaky IBC IS an infringement.
So, how could you demonstrate to VOSA/HSE (if you were asked) that you’re a competent and trained loader?? You could obviously demonstrate that you’re a correctly trained DRIVER, because you can prove that, but that’s as far as you’re currently trained.
matchbox:
I am only employed as a driver after all, and I load the vehicles as an ‘xtra service’ for which I am paid! A whopping £20 xtra a day!
Not worth it if I’m gonna end up in court. Or my mate who loads with me in a morning.
Two things are now blindingly obvious to me:
1. You are doing a job entailing legal responsibilities for which you are not trained.
2. Your firm are probably falling down BIG-TIME on SEVERAL important aspects of the dangerous goods regulations in allowing current (illegal) practices to continue.
As Clint Eastwood once said in a film “do you feel lucky?”
Was liquid acid actually leaking from the top, before “our hero” intervened?? Or was it just vapour?? The vapour is also very corrosive and the appropriate PPE should have been used in such close proximity- did he■■?