Rank: Forum user 
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Hi,
We have IBC's delivered to one of our sites that contain a detergent / disinfectant chemical (non-flammable but r36/38 irritant and r50 fish unfriendly).
A smaller depot nearby uses a smaller amount of the same chemical. Rather than have another large IBC delivered we are considering dispensing a small amount of the chemical (<25kg) into a suitable container and transporting it by road (400 yards) to the sub-depot. Besdies obvious financial benefits this will stop space being taken up at the sub depot for a little used chemical.
It has been said that we need a "license" of some kind to do this.
Besides the data sheet saying so, the quantities involved mean that surely ADR don't apply, and as this isn't 'waste' the environment agency aren't to bothered about it.
Have I missed anything or do I need a license? If so, which one? As long as I have suitable control measures (PPE, spill control, suitable containers, labelling etc.) is there any legal requirement stopping me from transporting a 25kg drum of chemical by road.....
Regards,
Ian
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Rank: Super forum user
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Ian.
Have a look at section 14 of the SDS- that's where you should find the UN number- if one has been assigned. From what you have said I don't think there will be one.
If that's the case, then ADR regs don't apply.
Who said that you need a license? Perhaps they could be more specific.
Andy
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Rank: Forum user
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That's what I thought - there's no UN number in s14 so ADR doesn't apply.
They've told me it is the chemical supplier telling us we need a license as the "seal is broken" ?!?!
Think they're trying to scaremonger us into ordering another IBC...
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Rank: Super forum user
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quote=Phillips20760]That's what I thought - there's no UN number in s14 so ADR doesn't apply.
They've told me it is the chemical supplier telling us we need a license as the "seal is broken" ?!?!
Think they're trying to scaremonger us into ordering another IBC...
That's lost me. Ask them to point you to the relevant regulation that says you need a license. Andy
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Rank: Forum user
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(the supplier don't want us dispensing chemicals as it will reduce their IBC sales)
Thanks for your help, I'll ask them to point out the relevant regulation.
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