Hello. We have a sensory service. Staff transport customers in their personal vehicles, from their homes and take them into the community/to appointments. Some of these customers have portable oxygen they must transport with them (approx 440 litres). 

Staff are not paid directly for their service. Its part of their role. The customer pays the business for the sensory service. 

Staff have business insurance, not commercial insurance on their cars. 

Im confused as to whether we would come under commercial or private transport. And if we would need a 2kg fire extinguisher? And I dont see that we need to use a hazardous sticker anywhere? Can anyone help? 

440 Litres is an odd size for medical oxygen (460 is the closest).

Business travel insurance is required for work related purposes in employee private vehicles.

Commercial insurance is where the business rather than the employees policy covers vehicles used either as company provided cars or "grey fleet" i.e. private cars being used for work purposes - any policy will be very explicit in this regard.

Private cars are not ADR vehicles meaning placards (diamonds) and extinguishers are not required.

If however the vehicles are also taxis there is the extingusiher requirement under most local authorities.

Private cars are not exempt from ADR or CDGR.

Here is some infomration specific to the question.

Transporting 460 litres of oxygen in a private car for work purposes falls under the Carriage of Dangerous Goods Regulations (CDGR) but benefits from the small load exemption since it is below the threshold of 1,000 litres for Class 2.2 gases with a subsidiary risk of Class 5.1 (oxidising). However, specific requirements must still be met. Here's a detailed breakdown:

Legal Requirements for Transporting 460 Litres of Oxygen

1. Vehicle Requirements

• Secure Loading:
  • Oxygen cylinders must be securely fastened to prevent movement during transport.
  • Use suitable restraints (e.g., straps, cradles, or racks) to keep the cylinders stable.
  • Cylinders should be stored upright unless the manufacturer specifies otherwise.
• Ventilation: Ensure the car is well-ventilated to avoid oxygen accumulation, which can increase fire risk.

2. Packaging and Labelling

• Approved Packaging:
  • Cylinders must be UN-approved and meet ADR standards.
  • Valves should be protected (e.g., with valve caps or guards).
• Labels:
  • Cylinders must display:
    • Class 2.2 label (non-flammable gas).
    • Class 5.1 label (oxidising substance).
  • Labels must be visible and in good condition.

3. Documentation

While the small load exemption reduces documentation requirements, you should still carry:

• Basic Information: A document outlining:
  • The UN number (UN 1072).
  • Proper shipping name ("Oxygen, compressed").
  • Class (2.2) and subsidiary risk (5.1).
  • Quantity being transported (e.g., "460 litres").
  • Emergency contact information.

This document is helpful in case of an incident but is not legally required under the small load exemption.

4. Driver Requirements

• Basic Training:
  • Drivers must be aware of the hazards of transporting oxygen and know what to do in an emergency (e.g., in case of a leak or fire).
  • No ADR certificate is required for quantities below 1,000 litres.
• Prohibited Actions:
  • Smoking or using open flames near the oxygen.
  • Transporting incompatible substances (e.g., flammable liquids, oils, or greases) in the same space as the oxygen.

5. Fire and Emergency Equipment

Although the small load exemption does not mandate fire extinguishers, it is strongly recommended to carry:

• A small fire extinguisher (suitable for Class A/B fires).
• Personal protective equipment (e.g., gloves) for handling cylinders.

6. Risk Assessment (Employer's Duty)

Under the Health and Safety at Work Act 1974, if the transport is for work purposes:

• The employer must carry out a risk assessment covering:
  • Hazards of transporting oxygen in a private car.
  • Emergency procedures in case of an incident.
• Provide training or guidance to the driver.

7. Specific Prohibitions

• No Smoking: Prohibited in or around the vehicle.
• Avoid Heat Sources: Ensure cylinders are kept away from heat or direct sunlight.

Practical Recommendations

While not legally required under the exemption:

• Emergency Plan: Keep a basic emergency procedure document in the vehicle.
• Inspection: Inspect cylinders before transport to ensure they are not damaged or leaking.
• Avoid Passenger Space: Store cylinders in the boot or secured compartment, separate from the driver and passengers.

Hopes. it help

Edited by user 13 January 2025 11:49:28(UTC)  | Reason: Not specified