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Mersey  
#1 Posted : 11 February 2015 15:33:21(UTC)
Rank: Forum user
Mersey

Does anyone know the rules around transporting chemicals ? ADR regs are over 1000 pages long I am trying to look for exemptions the reason being.

We are one site with two buildings but the buildings are separated by a public highway 150M maximum distance to travel We have a stock of 1M3 IBC's on site that contain 50% Sodium hydroxide, and others that contain 5% Peroxyacetic acid. We have ran out of chemical at one building and need to transport the IBC from building A to building B 150M on a public road. The idea was to load our transits van and to transport the IBC to the other site, but I'm almost sure that this is not legal so I've stopped the job. There seems to be some exemptions within the regs but they seem open to interpretation. Wondering whether anyone knows the rules for transporting this volume of chemicals in a van with an untrained driver and no signage even though its only 150M travel distance


I'm pretty sure I know the answer but would like to put it out there anyway
Mersey  
#2 Posted : 11 February 2015 15:35:25(UTC)
Rank: Forum user
Mersey

I have heard that exemptions exist around type of chemical volume of chemical and distance travelled, thats the reason for the post.
Andrew W Walker  
#3 Posted : 11 February 2015 15:47:26(UTC)
Rank: Super forum user
Andrew W Walker

Mersey.

Do you know the 'packing group' of the goods?

Lets take the Sodium- If its PG III then you will be able to carry 1000 litres without the driver having to do the driver ADR. There will be parts of ADR that you will have to comply with. Labelling, documentation and some form of driver training amongst others.

If its PG II then you can only carry 333 litres.

A bit more info please

Andy
Mersey  
#4 Posted : 11 February 2015 15:54:39(UTC)
Rank: Forum user
Mersey

Will it say on the IBC or the MSDS about the packing group?
Andrew W Walker  
#5 Posted : 11 February 2015 15:55:55(UTC)
Rank: Super forum user
Andrew W Walker

Mersey wrote:
Will it say on the IBC or the MSDS about the packing group?



Data sheet- should be section 14
Mersey  
#6 Posted : 11 February 2015 15:59:04(UTC)
Rank: Forum user
Mersey

Packing group 2 for both of them
Mersey  
#7 Posted : 11 February 2015 16:02:00(UTC)
Rank: Forum user
Mersey

Thanks for the guidelines much appreciated I take it from this we are not allowed to transport it in the transit van
Andrew W Walker  
#8 Posted : 11 February 2015 16:16:54(UTC)
Rank: Super forum user
Andrew W Walker

If you carry those products above 333 litres then its full blown ADR.

Orange plate, driver training , fire extinguishers, transport document, instructions in writing...

Hope this helps

Andy
Mersey  
#9 Posted : 11 February 2015 16:18:44(UTC)
Rank: Forum user
Mersey

thanks a mil saved me lots of reading greatly appreciated
toe  
#10 Posted : 11 February 2015 20:29:16(UTC)
Rank: Super forum user
toe

Reasonable practicably - foreseeable - Risk v Time, cost, and effort. Business liabilities, etc....

IMHO - given the information in the post, if this is a one off event, I would conduct a RA and put it in the transit for the short journey. Before people jump on the band wagon I know this may not strictly be legal compliant, but sometimes these type of decisions have to be made.

The general risk is a RTA, environmental spillage - will having full blown ADR, Orange plate, driver training , fire extinguishers, transport document, instructions in writing...

Prevent an accident from happening?
Roundtuit  
#11 Posted : 11 February 2015 21:31:16(UTC)
Rank: Super forum user
Roundtuit

150 Metres across a public road - not being delivered to a customer but transferred between two locations within the same business - are we really in to the transport of Dangerous Goods including raising DG Notes for trans-shipment within a business?

Would concur with exceptional events - consider the risks, ensure it is as secure as the IBC can be (capped/sealed valve outlet, closed filling/venting port etc.) spill kit / drain covers available in case it tips (judging from the post these would be presumed to be available) and move it on an FLT to save any debate about segregation between the load and the vehicle driver.

Yes possible debates over road tax and insurance for the FLT - but with appropriate identifiable Banks Men not considerably different to off loading to a warehouse from the public highway.

Or if still nervous decant the IBC's to 205 Ltr steel drums and move these in the Transit Van one at a time to be under the thresholds..
Roundtuit  
#12 Posted : 11 February 2015 21:31:16(UTC)
Rank: Super forum user
Roundtuit

150 Metres across a public road - not being delivered to a customer but transferred between two locations within the same business - are we really in to the transport of Dangerous Goods including raising DG Notes for trans-shipment within a business?

Would concur with exceptional events - consider the risks, ensure it is as secure as the IBC can be (capped/sealed valve outlet, closed filling/venting port etc.) spill kit / drain covers available in case it tips (judging from the post these would be presumed to be available) and move it on an FLT to save any debate about segregation between the load and the vehicle driver.

Yes possible debates over road tax and insurance for the FLT - but with appropriate identifiable Banks Men not considerably different to off loading to a warehouse from the public highway.

Or if still nervous decant the IBC's to 205 Ltr steel drums and move these in the Transit Van one at a time to be under the thresholds..
Jane Blunt  
#13 Posted : 12 February 2015 08:19:18(UTC)
Rank: Super forum user
Jane Blunt

If you decide to decant (which is a good idea, although the act of decanting has its own risks), try to choose containers that are made from the same material as your IBC (which I am guessing will be high density polythene). Sodium hydroxide is incompatible with zinc and aluminium, and acids are usually incompatible with most metals.
Adams29600  
#14 Posted : 12 February 2015 15:50:03(UTC)
Rank: Forum user
Adams29600

A Dangerous Goods Safety Advisor (DGSA) will be able to set you right.

My opinion, if it goes on the public highway then the requirements and/or exemptions of CDG will apply regardless of distance.
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