Limited quantities

[eldor]

I’m sorry if this subject has already being covered. I’ve been meaning to ask for a few weeks now. When I did my ADR course last summer, I’m sure the instructor said that limited quantities is either ending, or you’ll need an ADR licence to carry it after 01/01/07. While this doesn’t affect me as I’ve got a full licence in packages, many of the other drivers who we work with havent got an ADR and continue to carry limited quantities and none of us are actually sure where we, or more to the point, they, stand with it. Another thing is, that if an ADR licence is now required, I presume that limited quantities loads also require a trem-card, which they very rarely do when we pick the trailers up from the dock.

So, what is the position with limited quantities■■?

Thanks in advance!

[coffeeholic]

Diesel Dave is your man for this sort of question. I’m sure he’ll give you the definitive answer later vwhen he spots your post.

[dieseldave]

eldor:
I’m sorry if this subject has already being covered. I’ve been meaning to ask for a few weeks now. When I did my ADR course last summer, I’m sure the instructor said that limited quantities is either ending, or you’ll need an ADR licence to carry it after 01/01/07.

Hi eldor, I know it’s really difficult to remember everything from an ADR course, because it comes at you in such quantity and at such speed.
The reason that 01/01/07 was so important is that the exemption from ADR driver training for vehicles of less than 3,500Kgs GVW ended on that date.
I won’t go into that, because that exemption is now dead and buried.

For me, 01/01/07 meant two things.

1. I had to buy more ADR books, so I’m £110 poorer.
2. The books got thicker.
   This happens every two years.

eldor:
While this doesn’t affect me as I’ve got a full licence in packages, many of the other drivers who we work with havent got an ADR and continue to carry limited quantities and none of us are actually sure where we, or more to the point, they, stand with it. Another thing is, that if an ADR licence is now required, I presume that limited quantities loads also require a trem-card, which they very rarely do when we pick the trailers up from the dock.

So, what is the position with limited quantities■■?

Thanks in advance!

Limited Quantities (LQs) are exemptions based on the degree of danger (quite low,)
and the method of packaging (usually small receptacles in a cardboard box.)

For the boss, the LQ exemption numbers relative to each “stuff” indicate how the consignor/consignee can take advantage of the exemption. Not all dangerous “stuff” is allowed to be carried in this way. I’d say that the best way to think of LQs is to imagine the size of box/bottle/tub of something dangerous that you could buy over-the-counter in a retail shop, ie not trade sizes. As a (very) rough rule of thumb, the largest LQ size is 5 litres, but even that doesn’t apply to all of them. The rest of this bit would probably be quite boring, so I’ll just say that there’s around 26 different combinations of inner and outer package sizes in yet another table in the ADR books

For drivers, LQs are great, because there’s absolutely no limit per vehicle, no need for orange boards, no extinguishers are needed, no ADR licence is required, and you don’t need any of the documentation that you heard about on your course. ADR’s LQ exemptions mean exactly that. You’re exempt. The same applies to the other guys on your firm who aren’t ADR trained.

If you’re carrying LQs as part of a groupage load, the LQ items are not to be counted when your boss does the calculation for whether you’re “in scope.” It’s only when the “stuff” isn’t packed in LQs that your boss needs to do this. That’s when the per-vehicle threshold limits begin to apply.
Here’s the good bit: it’s not part of a driver’s job to do the calculations. That’s been the case since 10/05/04

If you need more info, please just ask.

[Lucy]

Cheers for that Dave. We do a lot of LQ Haz (as well as a lot of full Haz, although that’s not my thing), and I’d always wondered what the actual rules were. After years of asking various different people and getting various different although equally unintelligable answers, I now finally “get it”.

[dieseldave]

Lucy:
After years of asking various different people and getting various different although equally unintelligable answers, I now finally “get it”.

No probs Lucy, I’m quite happy to answer any questions, because there’s lots of myths about ADR. You wouldn’t believe the stuff I hear from people about it, or then again, maybe you would… Please just ask.

[eldor]

Thanks for that Dieseldave

It seems pretty much the same as before then as far as we go. I remember the instructor saying that all van drivers etc will have to have an ADR licence, I must then have got this mixed up with all the other rumours and hey presto, suddenly none of us know what to think!

If its the same as before, I presume that a LQ load doesn’t need to run with orange boards up and also doesn’t need a tremcard?

The one problem I sometimes have is that every so often a trailer arrives into the dock and all the CMR’s are there, but no trem cards and its not always easy to tell wether its LQ or not as its packed in small boxes much like a LQ load would be and it can be all too easy for the company we pull for to just say “oh yeah, its LQ so you can just take it”.

As you can probably tell, I’ve forgotten just about everything from my ADR course and it was only a year ago, mind you, I’d forgotten it a matter of days later because as you said, you get hit with a massive information overload in a short space of time. When I have my new one in four years time it will all make a lot more sense though as the things that are spoken about will now actually make sense to me as I’ve seen them in my work and can relate more to what they are and what they mean.

Thanks again.

[dieseldave]

eldor:
If its the same as before, I presume that a LQ load doesn’t need to run with orange boards up and also doesn’t need a tremcard?

Spot-on eldor, most people find it hard to believe, but if you’re carrying LQs, you don’t need anything. Exempt means exempt- totally. No orange boards, no ADR licence, no extinguishers, no ADR paperwork, no limit on overall quantity etc etc…
For LQs the only requirement is that it’s some sort of small bottle/tub type receptacle packed into a cardboard box of not more than 30kg total weight per box. The boxes then need some sort of white label, but I’m staying away from technical explanations here. Once the consignor has complied with that, that’s it- there’s no limit on the number of boxes- just load and go.

A lot of people (wrongly) think that limited quantities means a small amount of dangerous goods per vehicle. There are limits per vehicle, but it’s best to think of these as triggers rather than restrcitions. When these limits are exceeded (by non-LQ stuff) then the regs gradually begin to apply- orange boards and ADR licences are then needed, but that has NO CONNECTION with LQs.

eldor:
The one problem I sometimes have is that every so often a trailer arrives into the dock and all the CMR’s are there, but no trem cards and its not always easy to tell wether its LQ or not as its packed in small boxes much like a LQ load would be and it can be all too easy for the company we pull for to just say “oh yeah, its LQ so you can just take it”.

I’ve always sympathised with drivers who carry containers on this point. If the paperwork says it’s limited quantities, then you can only believe what’s written. The good bit is that a driver doesn’t write the paperwork, so if there’s a problem then somebody else wrote an untruth on a legal document- I wouldn’t be in that person’s shoes for a gold clock!!! Here’s the test: if somebody tells you it’s limited quantities, just ask them to write that on the paperwork and sign it. You can form your own judgement from their response If you ever have any concerns about this kind of thing, you should contact your boss- it’s their truck and their customer after all. Your boss has to have a DGSA, so that person will be able to give a good answer very quickly. If your boss uses a consultant DGSA, that person should have given appropriate training to your boss or the office staff so that they understand their duties. As a DGSA, it shames me to say that some of them just take the fee and do very little to earn it. It really gets me fired-up -especially with containers- when drivers are left wondering in this way, because it’s so unnecessary.
(Rant over, soap-box back in storage )

eldor:
When I have my new one in four years time it will all make a lot more sense though as the things that are spoken about will now actually make sense to me as I’ve seen them in my work and can relate more to what they are and what they mean.

That’s a great way to look at it eldor. Just think though, if you do a refresher you get the same info (updated) but in 3 days rather than 5 days. Many training providers don’t offer refresher courses, because they believe that the course should always be done at the same pace. BTW, did your training provider give you some kind of book to keep??

I might do a LQ case study explaining how it’s done in a non-technical way, if there’s enough interest, but it would probably go in the H&S forum. I’d take advice from the Moderators before I did though. In any case, I’m here for you guys- so please just ask

[eldor]

dieseldave:
That’s a great way to look at it eldor. Just think though, if you do a refresher you get the same info (updated) but in 3 days rather than 5 days. Many training providers don’t offer refresher courses, because they believe that the course should always be done at the same pace. BTW, did your training provider give you some kind of book to keep??

I might do a LQ case study explaining how it’s done in a non-technical way, if there’s enough interest, but it would probably go in the H&S forum. I’d take advice from the Moderators before I did though. In any case, I’m here for you guys- so please just ask

When I did my initial course it was basically done over two full weekends and the other drivers at my company who needed a refresher did the same course as me. I was told at the time that refresher courses were being done away with and everyone would be doing the full course? As for the book, they did give one but I’ve unfortunetely lost it, but apparently it was out of date anyway and didn’t cover some changes that had already taken place and the ones that took place on 01/01/07. Having said that, it would be useful to have in any case.

One unrelated matter is the application of labels to the trailer. I believe I’m right in saying that a trailer doesn’t need to display labels when out on the road, only when its being shipped by sea. Yet when we occasionally need to get labels from the Cobelfret office at Killingholme they almost get violent with us, ranting and raving that its illegal to be on the road without labels and we shouldn’t be on their terminal without them. When I’ve pointed out that its a trailer and not a container they just insist that trailers need labels at all times too. I dont know why they take such exception anyway, they charge an extortionate rate to our company for supplying them!

Many thanks again

[jase]

DieselDave,could you please explain to me why some consignor’s always use DGN’S to put LQ consignments on as i always thought that if you have a Dgn then you must have a tremcard or is that no true?
I run under IMDG rules as well as ADR rules as i’m on container’s.

[eldor]

jase:
DieselDave,could you please explain to me why some consignor’s always use DGN’S to put LQ consignments on as i always thought that if you have a Dgn then you must have a tremcard or is that no true?
I run under IMDG rules as well as ADR rules as i’m on container’s.

LQ are hazardous by sea and the DGN’s are to give to the ferry/shipping company who transport your trailer/container by sea. So long as its LQ you don’t need a tremcard, just a DGN to hand to the guys at the port. I’m sure Dave will correct me if I’m wrong

[jase]

Thank’s Eldor,i often think it would be much simpler to abolish Lq and just make thing’s easy by the product’s either hazardous or not,never mind about the size of the recipticle.
After all whether its 33 000 ltrs of petrol in one tank or 33 000 ltrs in 1 ltr bottles its still hazardous and it will still go bang!

[dieseldave]

eldor:
When I did my initial course it was basically done over two full weekends and the other drivers at my company who needed a refresher did the same course as me. I was told at the time that refresher courses were being done away with and everyone would be doing the full course? As for the book, they did give one but I’ve unfortunetely lost it, but apparently it was out of date anyway and didn’t cover some changes that had already taken place and the ones that took place on 01/01/07. Having said that, it would be useful to have in any case.

OOPS. The info given to you by the training provider is supposed to be accurate and relevant.
They might have fallen down on that, but I’m always here

eldor:
One unrelated matter is the application of labels to the trailer. I believe I’m right in saying that a trailer doesn’t need to display labels when out on the road, only when its being shipped by sea. Yet when we occasionally need to get labels from the Cobelfret office at Killingholme they almost get violent with us, ranting and raving that its illegal to be on the road without labels and we shouldn’t be on their terminal without them. When I’ve pointed out that its a trailer and not a container they just insist that trailers need labels at all times too. I dont know why they take such exception anyway, they charge an extortionate rate to our company for supplying them!

Many thanks again

Eldor, it appears that you’ve forgotten very little You’re spot-on again about the trailer not needing placards (big labels) when out on the road. From your description, you did just the packages part, without tanks. I’m also thinking you didn’t cover classes 1 & 7. I’m also assuming that you’re doing unaccompanied trailers, rather than containers. Let me know if I’m wrong??

FOR EXPORTS. (Packages, except classes 1 & 7)
You don’t need placards whilst on the road. When you arrive at the docks, they’ll tell you what you need. If it’s a drop-trailer for unaccompanied shipment, you’ll need four placards- one each for the two sides, front and rear. That’s when the sea regs (IMDG) take over. Some consignors will give you the relevant placards at the loading address. If so, you choose whether to put them on the trailer for the road leg of the journey.
(It might depend on whether it’s raining )

FOR IMPORTS. (Packages, except classes 1 & 7)
Once the trailer is off the boat, you have a choice. IMDG no longer applies, so you can remove the placards if you like.

Either way up, ADR has no requirement for placarding trailers loaded with packages. (It does IF it’s classes 1 or 7, or a vehicle carrying a container) As far as vehicle markings go you’d need the orange boards, if you’re in scope.

eldor:
ranting and raving that its illegal to be on the road without labels

If they’re being really picky, they’re technically right about their terminal (only because it’s theirs. ) If it were me, I’d tell the boss and suggest your company’s DGSA has a word with them. If they insist on selling you placards before letting you on the road with an import trailer- that could be serious, because they might be taking your boss’ money when there’s no need. (Unless you’re doing container work.)

[dieseldave]

jase:
DieselDave,could you please explain to me why some consignor’s always use DGN’S to put LQ consignments on as i always thought that if you have a Dgn then you must have a tremcard or is that no true?
I run under IMDG rules as well as ADR rules as i’m on container’s.

Aren’t LQs a barrel of fun?? (No don’t answer that )

Jase You hit the nail on the head by mentioning IMDG. Everything we’ve talked about so far is ADR stuff, so you’ve asked a great question. A DGN is required by IMDG for ALL dangerous goods. When carrying LQs by road as part of a multi-modal journey, you might have a DGN even though ADR doesn’t require it. The DGN is used by the shipping lines so that the location and stowage of dangerous goods can be accurately recorded on a ship’s manifest. For instance, IMDG’s rules for the segregation of dangerous goods are far stricter than ADR. Under IMDG, there are also requirements for where the dangerous goods are stowed on a ship eg in a hold or on a weather deck, sometimes “not near the crew’s living quarters” is stipulated. Also, the IMDG regs generally have much smaller limits than ADR.

Without technicality, the easiest way to think of this is to imagine that the environment in which a ship operates is very different to how it is for a truck on a road. If we have an emergency, we can phone 999. What happens when a ship has an emergency in the middle of the Atlantic.■■ IMDG is very different to ADR in many areas. (That’s why only the IMDG markings are taught on an ADR course.)

Tremcards are sometimes required by ADR, but have no connection with a DGN. You might have one or the other, or sometimes both.

[dieseldave]

eldor:
LQ are hazardous by sea and the DGN’s are to give to the ferry/shipping company who transport your trailer/container by sea. So long as its LQ you don’t need a tremcard, just a DGN to hand to the guys at the port. I’m sure Dave will correct me if I’m wrong

No need for any correction eldor, cos you ain’t wrong.
I’ve answered jase’s question exactly the same as you, but I padded it out a bit.

[jase]

Thank’s Dave,thats cleared it up for me.

[dieseldave]

We’ve been looking at this from a driver’s point of view, but there are others in the “transport chain,” such as consignors, carriers (the owners of trucks) and consignees. There’s also something that we might bear in mind: There’s about 3,000 entries in ADR for “stuff” that is dangerous. For LQs, there’s also 26 different combinations of inner and outer sizes to consider.

jase:
Thank’s Eldor,i often think it would be much simpler to abolish Lq and just make thing’s easy by the product’s either hazardous or not,never mind about the size of the recipticle.

The idea behind LQs is that there should be a relaxation of all those horrendously technical regs for SOME dangerous goods that aren’t really dangerous. So, not everything is allowed to be done as LQs. Imagine this: I’m only carrying one exocet missile, and it’s a small one so the regs shouldn’t apply. Of course that’s nonsense.

jase:
After all whether its 33 000 ltrs of petrol in one tank or 33 000 ltrs in 1 ltr bottles its still hazardous and it will still go bang!

Well, maybe not quite jase. If it’s in a tanker then petrol is regulated as you said, but it’s perfectly legal to transport petrol in LQs, the theory says that the whole lot wouldn’t go off in one go as it might with a tanker. Would every receptacle break, if the truck overturned?? I’d guess probably not.

Now we might spare a thought for the others in the transport chain. Let’s say that a shopkeeper wants to sell Acetone (nail polish remover.) Provided that it’s carried as LQs, that’s perfectly fine. No great expense to the consignor, after all they don’t then need the UN approved packagings (cheaper) your boss doesn’t need to pay for ADR training and fancy kit for the trucks (cheaper for him too.) So it’s cheaper for the end user.

Acetone has other uses, so now an industrial user wants to buy it for use in a factory’s manufacturing process. That consignee won’t thank us for turning up with silly little boxes, which would take ages to empty into a big vat at the factory. They’d probably want it in drums or IBCs. Once the receptacle for acetone is bigger than 3litres ADR takes an interest, because of the danger. BTW, the regs treat Acetone as being as dangerous as Petrol. Once Acetone isn’t in LQs, then the limit is 333litres per vehicle. If you’re carrying more than 333litres, then the full weight of ADR applies and you’d need orange boards and an ADR trained driver, paperwork, equipment, tremcard (IIW) and all the rest…

Yes, I’m the first to say it’s tricky, but I’d balance that by saying that’s why it’s not part of a driver’s job to know the limits any longer. 10/05/04 was a good day for drivers. In the UK, we’ve been working towards this since 31/12/99, cos that’s when we first required DGSAs. No longer can bosses say “you’ve done the course, so you should know.” IMHO, a driver’s job is hard enough, so I think ADR got it just right when it says to leave all the technicalities to somebody sitting in a nice warm office.

[dieseldave]

I’ve had a trawl through the H&S forum, because I’ve now remebered that I wrote about LQs for a member called Matchbox, who also needed the legal quotes to show his boss. Beware that the quotes won’t be correct now, because the new UK Dangerous Goods Regs came out on 01/07/07 and my post was written using the “old” Regs when they were in force. Much of the actual info is still correct by coincidence.

Anyway, it’s HERE