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Safety Geek  
#1 Posted : 03 December 2019 11:59:25(UTC)
Rank: Forum user
Safety Geek

Hello fellow practitioners, 

I am currently assessing and reviewing the arrangements in place for the safe transportation of small quantities of LPG in a commercial vehicle (Mercedes Vito).

Back ground information in to this is that we have multiple field-based engineers who install smart meters for both electric and gas.  As a result, there is a requirement to carry a single 400g Rothenberger Propane cartridge (blow torch) to undertake gas meter pipe works to solder the pipe joints.

The cartridge is contained within a "hot works kit" that also has a 1kg dry powder fire extinguisher. 

In addition to this we also retrofit the vehicles with a wind powered rotary ventilator for the rear storage compartment. 

As a result of the review I have been looking at both Leaflet 1 - BCGA The Carriage of Small Quantities of Gas Cylinders on Vehicles and BCGA GN27 - Guidance for the Carriage of Gas Cylinders on Vehicles but it’s not quite clear what is required. 

It states that a minimum of a 2kg dry powder extinguisher is required but there are no given LPG levels that I can see where is applicable or not. 

Can I please ask if there are any practitioners on the forums that have experience in this field? 







Edited by user 03 December 2019 15:13:26(UTC)  | Reason: Typo errors.

#2 Posted : 03 December 2019 12:46:14(UTC)
Rank: Forum user

Have a look at Carriage of Dangerous Goods on the HSE website, this states:

Small load exemptions (ADR

21. Small load exemptions relate to the total quantity of dangerous goods carried in packages by the "transport unit" (usually the van or lorry, but also any trailer). It is the transport category (TC) that determines the load limits (thresholds). Many substances are assigned a packing group but these are not synonymous in all cases with TC. TC is given in column 15 of Table A in ADR (Chapter 3.2). If that is not available, the table at ADR part needs to be consulted. Load limits for the different transport categories are given below. For convenience this has been amended in accordance with the derogation but it needs to be used with care.

22. Small load exemptions do not apply to tankers or bulk carriage.

23. If a vehicle is carrying under the small load threshold, many of the requirements of ADR are not applicable. The table below summarises the position. Some care needs to be taken, as "what is not exempted is still required".  In most cases the remaining obligations are:

  • General training for driver (ADR 1.3.2). A record should be kept (ADR 1.3.3)
  • Carry one 2 kg dry powder fire extinguisher or equivalent (ADR
  • Stow the dangerous goods properly (ADR 7.5.7)

24. Note that use of these exemptions is optional. For example, a carrier may choose to display the orange plates as long as the vehicle is carrying dangerous goods.

25. All vehicle marks (orange plates) must be removed when no dangerous goods are being carried.

Examples of small load application

26. LPG. This is in transport category 2. The "small load threshold" is 333 kg and there is no LQ provision.. The result is that all cylinders count towards the load limit, but if that is less than 333 kg, the "minimum" ADR requirements apply.


Hope that helps

thanks 2 users thanked wjp62 for this useful post.
CptBeaky on 03/12/2019(UTC), Safety Geek on 03/12/2019(UTC)
#3 Posted : 03 December 2019 13:11:10(UTC)
Rank: Super forum user

Looks to me like you will need to upgrade to a 2kg dry powder extinguisher.

Beyond that you have it covered

Safety Geek  
#4 Posted : 03 December 2019 15:21:31(UTC)
Rank: Forum user
Safety Geek

Thank you for all your replies everyone, it's much appreciated. 



Dazzling Puddock  
#5 Posted : 03 December 2019 17:16:41(UTC)
Rank: Forum user
Dazzling Puddock

I would say you are exempt from ADR altogether as what you are describing is Carriage that is "ancillary" to main activity.      

"A driver taking dangerous goods with him for use with some machine or process that will be operated on arrival will be exempt."

If you have risk assessed that a 1kg F/E is enough then I would stick to that.

#6 Posted : 04 December 2019 11:28:42(UTC)
Rank: Super forum user

I’m also not convinced a single (or 2 ) of these small aerosol cartridges would fall under ADR and its requirements. Otherwise every plumber would need an ADR licence! As well as the exemption above you may also want to look at the exemptions for aerosols to see if it meets that criteria.

Obviously proper storage in the back is good as noted in the above posts, and perhaps an extinguisher ( but run away is an option! And get others out of the area) of appropriate size. ADR driver training – seems overkill.

ADR is not a nice read, but is available free on the internet if you look hard enough ( try page 6 and 130).


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