Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Admin  
#1 Posted : 18 May 2005 12:10:00(UTC)
Rank: Guest
Admin

Posted By Heather Aston I have (thankfully) not been involved in the dangerous goods by road requirements for some years. Unfortunately as part of a temporary agreement we have agreed to act as a holding site and forwarding agency for the transport of some materials that are classified under the rules as "dangerous". Suddenly I am whisked into the bewildering world of tremcards, packing groups, UN classifications and incomprehensible derogations. I have just opened a copy of ADR Part 1 and it's 629 pages!! Now I am a speed-reader but that's a bit much even for me (there's a part 2 as well!). I've read the HSE's intro to ADR but it refers to the ADR document itself a lot and doesn't stand alone. The remaining HSE guidance all seems to refer to the old CDGCPL regs and I assume can no longer be relied on? I'd be very grateful if there is anyone out there who deals with this on a regular basis or perhaps is even a DGSA who could give me some help. We don't deal with Class 1 goods and as we are simply acting as a middle man, the goods are already classified, labelled and packed properly (Thank Goodness). My main questions relate to the provision of information to drivers and the marking of vehicles - who is responsibile for what and what is required? We are using a third party as carrier so the driver training, vehicle suitability and all that complicated stuff isn't our responsibility. The carrier seems to think vehicle marking (provision of the diamond-shaped placards) is down to us - surely that's not correct? Hoping someone out there knows more than me.....(not hard) Heather
Admin  
#2 Posted : 18 May 2005 14:06:00(UTC)
Rank: Guest
Admin

Posted By IanD Hi Heather Its not too bad you have got the complicated bit out of the way It is the consignor’s duty to provide the Trem Card (or emergency instructions) to the driver and the dangerous goods declaration. They goods must have been transported to your depot so therefore they should already have all the paperwork, which should be handed over to you, when you accept the load into your yard. Alternatively the consignor could forward you additional copies of the paperwork for you to supply the driver with if there is a delay in forwarding the goods. Don’t forget they instructions have to be in several languages if you are shipping within Europe. If I recall English, French and German and any other language of the country the goods are passing through. The vehicle markings should be the responsibility of the consignor, or if third party, the haulier. Again the consignor could supply you with a small supply of the diamonds so you can supply the vehicle if they arrive without them. Hope this helps Regards Ian
Admin  
#3 Posted : 18 May 2005 14:40:00(UTC)
Rank: Guest
Admin

Posted By Heather Aston Thanks Ian That's very useful. The exact situation is that we have a factory site which normally uses chemicals - some of which are classified dangerous for transport. As part of a transfer of processes, some of these chemicals need to go to another of our sites in France. As a temporary measure we are having everything delivered to one (UK) site, sorting it and sending the required materials on to France. We are doing this for ourselves not on behalf of the person who sends the goods to us, so I take that to mean that we're the consignor? The goods are already labelled - it's just a matter of us deciding which pallets need to go to France and getting them put into another lorry (not the same carrier that delivers them to us unfortunately). We have persauded our original supplier to let us have copies of their tremcards (in English & French) - presumably we should change any emergency contact details unless the original supplier is OK with theirs staying on the documentation? The bit I read said that the carrier was responsible for vehicle placards and the consignor was responsible for the tremcards and for giving the carrier the necessary information beforehand so that they turn up with the correct placards- is that not the case? Last time I was invlved in this, all that was required for dangerous goods in packages was orange plates front and rear. I assume this requirement for the diamond shaped warning signs (like the packaging labels) is new since the early 90s. Is there still an overall orange plate requirement or not? I'm now reading Part 2 of ADR - luckily Part 1 is mostly tables - but I'd still appreciate any further practical guidance/advice from those who've done this (as Ian obviously has) Heather
Admin  
#4 Posted : 18 May 2005 15:21:00(UTC)
Rank: Guest
Admin

Posted By Paul Cowell Heather, Chapter 8.1 vol II covers the document and placard requirements,Im a DGSA,if you mail me exact quantities,type of packing UN numbers i ll have a look at what your requirements are.
Admin  
#5 Posted : 18 May 2005 16:24:00(UTC)
Rank: Guest
Admin

Posted By IanD Hi Heather Just to claify - In your situation you are responsible for providing the correct paperwork. The carrier (driver) is responsible for the vehicle marking, assuming that you give him the relevent information. We did the exact oposite. Sent all our products to our German warehouse who then supplied the customer base.
Admin  
#6 Posted : 18 May 2005 16:48:00(UTC)
Rank: Guest
Admin

Posted By Heather Aston Thanks Ian & Paul Ian - I thought that was correct. The carrier turned up for the first load last week and asked our people on site for the vehicle placards (which needless to say isn't something we keep hanging around). I've only got involved since. We hope this will only be a short term (few months) situation and then we'll get the right things delivered to the right places. Paul - thanks for the offer. I have (tried to) read Chapter 8, but I kept falling asleep! I had not spotted that the specific obligations are laid out in Chapter 1.4, which clearly I should have read properly first. I am not certain of the exact nature/classification/amount of the substances yet, but am visiting the site tomorrow to see. I'll give you a shout if I am still struggling. Thanks Heather
Admin  
#7 Posted : 19 May 2005 14:04:00(UTC)
Rank: Guest
Admin

Posted By lawrence baldwin Heather I may be coming into this a bit late and I am sure you have excellent advice. But just be aware of your quantities if not already mentioned to you because given certain criteria, you could ship under: "limited Quantities" (3.4.6, where the ADR does not apply) Excempted Quantities (1.1.3.6 where only some of the ADR applies such as Documentation and you get excemption from the majority of the ADR) Beware of differing types of hazards as well as classification is dependant on a "Table of Precedence" (2.1.3.10) Give who is advising you, amount to be shipped, number of inner and outer packages and contents thereof including UN number. (and nationality of driver if different from those countries he is driving through) Such a fun subject!!!!! Lawrence
Admin  
#8 Posted : 19 May 2005 14:33:00(UTC)
Rank: Guest
Admin

Posted By Heather Aston Thanks Lawrence I had printed off the quantity exemptions table (1.1.3.6.3 - doesn't the Chapter numbering in ADR boggle the mind!) but I think we will be exceeding the level of 1 tonne for packing Group III, which gives the quantity exemptions. I should be getting the full list of materials e-mailed to me today, then I can look them all up for classification (I'm sure our supplier does have it right, but I'd like to check...) and we'll take it from there. Luckily we only have to do this in French and English (English driver - journey from UK to France) Yes, this makes WAHR look like a stroll in the park - I'm just glad I don't have to do the CPL side any more either! Heather
Admin  
#9 Posted : 19 May 2005 20:02:00(UTC)
Rank: Guest
Admin

Posted By CHRISTOPHER HAYWARD I am also a qualified DGSA as well and did it full time until 11 weeks ago. If it is going on a ferry, don't forget the International Maritime Dangerous Goods Code aka IMDG. There are more than 2 volumes of that, although very often the differences are minor. I love the topic, but all good things come ot an end.
Admin  
#10 Posted : 29 June 2005 14:26:00(UTC)
Rank: Guest
Admin

Posted By garyh Heather, I think that your organisation requires the services of a DGSA as you are in effect consigning DGs. Also, I think that your people who handle the DGs need awareness trainng under the "new" regs............sorry to break the bad news.
Admin  
#11 Posted : 29 June 2005 15:47:00(UTC)
Rank: Guest
Admin

Posted By Peter Taylor14 contact M Butterworth 07881910144
Admin  
#12 Posted : 29 June 2005 21:32:00(UTC)
Rank: Guest
Admin

Posted By Heather Aston Gary It's not part of our "main business" and it's only a temporary arrangement for a very limited range of materials so I reckon we can squeeze into the exemption for a DGSA for the moment. I am posting at home so can't quote chapter and verse at you but I did look into this at the beginning and decide we were OK. Also we are as someone said above only doing the "simple" bit, i.e. re-consigning someone else's goods, not actually getting into the packing and labelling, which I would NOT try to do ourselves. Anyway I've already had sufficient good advice from several (qualified) posters off-line - thanks to Paul & Chris - and also from our (French) transport company and the ferry company to be confident that we know what we're doing with the dozen or so materials we are consigning. The supplier of the original materials has also been very helpful. The handling of the goods in our yard when loading them is no different from what we do now when unloading them, so our on-site drivers are already trained to handle dangerous goods. Heather
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.