One for Diesel Dave...

ASK THE EXPERTS SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE
1

… or any other peeps in the know, I’m not fussy :wink:

Earlier this week i collected A load of waste oil drums, and for the first time
since doing my ADR, was asked to fill in part of the carrier ticket.
Name of carrier, I put my companys name
On behalf of, I put the company we were doing it for.
The chap on site said that 'No, I am the carrier and I had to put my name down,
Where it said on behalf of, I had to put my companys name.
I wasnt sure so didnt argue, however, when it came to leaving the site, the
gatehouse put down my companys name as the carrier and our customer as
the 'On behalf of :confused:
Who was right please :question:

2

Ignore the bit about Leeds, it’s written in English you suvverners will understand :stuck_out_tongue:

http://www.leeds.gov.uk/files/2006/week5/inter__24ecaa86-38f7-411f-a219-7fda5a288f59_6dbf1b95-ecd3-46fd-a64a-b017c91b6555.pdf

Nice ■■■■■ pictures :wink:

3

mighty moth:
… or any other peeps in the know, I’m not fussy :wink:

Earlier this week i collected A load of waste oil drums, and for the first time
since doing my ADR, was asked to fill in part of the carrier ticket.
Name of carrier, I put my companys name
On behalf of, I put the company we were doing it for.
The chap on site said that 'No, I am the carrier and I had to put my name down,
Where it said on behalf of, I had to put my companys name.
I wasnt sure so didnt argue, however, when it came to leaving the site, the
gatehouse put down my companys name as the carrier and our customer as
the 'On behalf of :confused:
Who was right please :question:

Hi mighty moth, Both you and the gatehouse guy were correct about the use of the word “carrier.”. :grimacing:
The “carrier” is defined as ‘the owner of the vehicle.’
:laughing: :laughing: The “chap” should be advised not to give up his day job. :wink:

TIP: If you don’t own the vehicle, you should only ever sign a waste collection document in the box marked ‘driver’s signature.’
If you follow Wheel Nut’s link, you’ll see how serious all this is. In addition to the penalties, there is also the possibility that ‘enforcement’ might also impound the vehicle. :open_mouth:

It’s perfectly OK for you to fill in the box marked ‘carrier’ with your company’s name and address. Also, you might need to fill in the boxes marked ‘vehicle reg. No.’ and ‘time of collection,’
(That’s if you’re using a proper waste collection note. These avoid the need for ‘receipts’ :wink: )
I’d also advise that when you get to the ‘dump’ site, you should check that they sign for the ‘stuff’ and write the date and time in the relevant boxes. That way, you/your boss can prove that the stated amount of waste was correctly received by a licenced disposal site.

The one part of this that’s got me wondering is the connection to ADR.
The carriage of dangerous wastes is mentioned in the ADR course, but “waste oil drums” are probably only ‘hazardous’ at the very worst.
The ADR course is all about ‘dangerous’ goods and I very much doubt that waste oil counts as ‘dangerous.’

To help me give you a good answer, was there a UN number written on the waste collection note?
Did the “waste oil drums” have a label like this on them?

I might need to add to this, depending on your answers. :smiley:

4

Wheelnut, Thanks very much for the reply mate, much appreciated.
I will have a look at that in a mo :smiley:
Diesel Dave, I put the vehicle reg down, and the time and the date in the boxes like you said.
I asked for a trem card but was told ‘Its a low hazard waste, so you need you ADR
plates up, but there is no need for tremcards’.
The drums didnt have A plaquard like in your picture but they did have a
small label on each one saying ‘low hazard waste’.

5

mighty moth:
Diesel Dave, I put the vehicle reg down, and the time and the date in the boxes like you said.

Hi mighty moth That’s great, and you were correct to do so. Nice one mate. :smiley:

mighty moth:
I asked for a trem card but was told ‘Its a low hazard waste, so you need you ADR plates up, but there is no need for tremcards’.

:open_mouth: Oh dear, that’ll be the “chap” again. He’s wrong again… :unamused:

“Chap” 0 v 2 dieseldave [not his day is it?? :grimacing:]
(I like him though, only because I’m on a hat-trick. :laughing: )

“Chap” needs to be explained that the requirements for tremcards, orange boards and an ADR licence all begin at the same point ie. when you have sufficient dangerous goods on board to trigger ADR into action.

It seems that “Chap” also needs to understand the definition of dangerous goods.
That means any substance or article listed in ADR’s dangerous goods list.

Since you’ve said that the oil drums didn’t have any labels on them and there seems to have been no UN number on your waste collection note, it follows that the ‘stuff’ you were carrying isn’t dangerous and at worst is only hazardous. (So ADR isn’t interested in it.)

I do realise that your paperwork might well have the word “hazardous” on it, but it doesn’t necessarily mean that the ‘stuff’ is also dangerous. This might be where “chap” is getting muddled. The waste Regs have some different definitions to ADR and I’d agree that it can be confusing when two sets of Regs might apply to the same job. All the more reason for “chap” to get his facts straight IMHO. :wink:

mighty moth:
The drums didnt have A plaquard like in your picture but they did have a small label on each one saying ‘low hazard waste’.

Thanks for that mighty moth, that was the last clue!!
The absence of a danger label (diamond) shows that stuff isn’t dangerous. :smiley:

:open_mouth: CAUTION :open_mouth:
:bulb: Beware of showing orange boards when there are no dangerous goods on board your vehicle. :exclamation:
:open_mouth: It could lead to confusion at the scene of an accident and is therefore a fairly serious offence. :wink:

6

Wheel Nut:
Nice ■■■■■ pictures :wink:

I see what you mean :laughing: Always seems to be flat bed transits :laughing:

7

dieseldave:
Since you’ve said that the oil drums didn’t have any labels on them and there seems to have been no UN number on your waste collection note, it follows that the ‘stuff’ you were carrying isn’t dangerous and at worst is only hazardous. (So ADR isn’t interested in it.)

So I was wrong to display orange boards then :question: :cry:

8

mighty moth:

dieseldave:
Since you’ve said that the oil drums didn’t have any labels on them and there seems to have been no UN number on your waste collection note, it follows that the ‘stuff’ you were carrying isn’t dangerous and at worst is only hazardous. (So ADR isn’t interested in it.)

So I was wrong to display orange boards then :question: :cry:

Hi mighty moth, in a word “Yes” you were wrong to have had your orange plates showing, given that the info you’ve stated above is correct…

However, you were told by “Chap” that you should display them.
The real person to tell you this is actually your boss, rather than the consignor.
If your boss tells you to display your orange boards in the circumstances you described, I’d suggest that your boss ought to speak to your company’s DGSA. :wink:

9

Thats excellent mate :smiley:
Thankyou for your help :wink: :sunglasses: