Q&A ADR ADVICE
76 TRUCKING Summer 2019 http://www.truckingmag.co.ukIBC issues
Q
I have a client for which my company
carries UN 1760, a corrosive liquid, in
1000-litre IBCs. The client has informed me
there are three types of this liquid and we
can only carry two of them in IBCs. I have
checked on this and found there are now
three divisions to Class 8, Corrosives.
The problem I have is my company
cannot ascertain what the difference is
between the three divisions. This means we
don’t know which one of three cannot be
carried in an IBC. Another issue is we
cannot find any class eight with division
labels for the IBCs.A
It sounds very likely you are mixing up
ADR with CLP. The latter being
classification and labelling of packages;
effectively being for the end user, for
example the small red diamond shapes
you would see on a bottle of bleach. This
does, indeed, have three divisions
(Corrosive to skin, Corrosive to eyes and
Corrosive to metal). This has no bearing
on ADR, which has one Corrosive without
any divisions.
The three types you have been advised of,
I assume, would be the packing groups,
which are used to ascertain the danger. UN
1760 does have three different packingObviously, the leaking drum could not
be loaded on the vehicle, so it would be
placed within a ‘salvage package’ which
would contain the drum and any leakage
from it.Cooling down
Q
When we load oil additive, which is
slightly hotter than 100 degrees C,
we have to use an ADR-trained driver.
What I would like to do is use the ADR-
trained driver to bring the tanker back to
our depot, wait for the oil additive to cool
down below 100 degrees C, and then use
one of our non-ADR trained drivers to
deliver the load.
I have been told I can’t do this, but I am
confused as to why. Once it is colder than
100 degrees C, it isn’t covered by ADR
anymore, is it?A
This would be regarded as being an
‘elevated temperature’ liquid, which is
stated in ADR as being a liquid that is
carried, or handed over for carriage, at or
above 100 degrees C. Accordingly, as it was
handed over for carriage at a temperature
above that, it will remain subject to the
regulations even when it has cooled.
Unfortunately, in this case, as it was
handed over to you for carriage at that
temperature, it will remain fully subject to
regulations at the lower temperature and,
as such, the driver will require an ADR
Driver Training Certificate. nADR
ADVICE
Our expert answers your
questions concerning
the movement of
dangerous goods
By Keith Antrobus
PHOTOGRAPHY VARIOUSgroups. Packing Groups I & II are permitted
to be carried in IBCs, whereas Packing
Group I, being the most dangerous, is not
permitted to be carried in an IBC.
Obviously, this eliminates the
requirement for you to find labels with
divisions shown on them. As a point of
interest though; even if there were several
divisions of the class, the label would, very
probably, only show the figure 8 anyway. If
you look at class 2, for example, this does
have three divisions; however, only the
figure 2 is shown. The same is relevant for
classes 4 and 6. Class 5, for historical
reasons, is unique in showing 5.1 and 5.2.
Hypothetically, if there were to become
several divisions within class 8, it would
still only show the figure 8.Salvage package
Q
What is a ‘salvage package’? My
company has a new job carrying these.
They sound to me as though they are
broken or used packages, and I am not very
happy about having to carry them.A
I see your point – the name does
rather give the impression of a
package that has been salvaged and
re-used. A salvage package, though, is
actually a package which contains a
damaged or leaking package, or even
packages of dangerous goods that don’t
conform to ADR requirements.
If you are going to be carrying these on a
regular basis, I assume you work in the
waste industry. A typical use of a salvage
package would be if, for example, a drum
had been dropped and started to leak. It
would need to be removed from site and
transported to a waste facility.SEND US YOUR QUESTIONS
Please contact Altrain ADR with your
dangerous goods questions by sending your
query by email to: [email protected]