ADR Labelling;

[Psuedonym]

Hi guys, long time since I was on board, no excuse just got a bit hooked on my Xbox  ok, apologies over with.

The little company I work for have a few service vehicles etc. All of which transport non flammable gases - portable exts, Ansul cylinders, gas system cylinders etc. Basically the full monty accross the company. However none of the vehicles carry the ADR green diamond non flammable warning label. I have trawled the HSE, ADR et al sites to find out what the regulations are regarding minimum weights/ quantity requirements for installing a warning label are and have sunk the depths of regulatory requirements and am drowning in data.

My question rises from a chat I had with a dept. manager who insisted the minimum weight was 300Kg compresed gas within a vehicle as this was the new reg. ( Our gas cylinder vans kitted out with lifts and correct wall strapping to transport cylinders are specially designed, carry over 300Kg yet still don't have a non flammable warning label  ) So I am a bit sceptical over this "new regulation" and would appreciate some confirmation from some experienced personnel.

Please, no general links just straight info with a direct confirmation link!

Cheers chaps

[Tom Sutton]

Check out http://www.unece.org/trans/danger/publi/adr/adr2007/English/001%20E_introvol1.pdf or my page http://www.firesafe.org.uk/html/fsequip/firesign2.htm which may be of some assistance.

[AnthonyB]

From http://www.hse.gov.uk/cdg/manual/

Limited quantities:

Acetylene, LPG and other gases are commonly carried by tradesmen such as welders and motor vehicle repair technicians. Flammable gases are in Transport Category 2.  Oxygen and gases such as carbon dioxide and argon are in Transport Category 3. Usually the small load threshold[1] exemptions will apply,

The parts of ADR which apply are then

    * Driver to have received “general awareness”, “function specific“, and “safety” training (ADR 1.3).  A training record should be kept.
    * Vehicle to be equipped with at least one 2 kg dry powder fire extinguisher which is kept in good working order.
    * The load to be properly stowed.  Note that special provisions CV9, 10 and 36 all apply in the case of these gases. In particular, CV 36 specifies:

“Packages shall preferably be loaded in open or ventilated vehicles or open or ventilated containers. If this is not feasible and packages are carried in other closed vehicles or containers, the cargo doors of the vehicles or containers shall be marked with the following in letters not less than 25 mm high:
WARNING
NO VENTILATION
OPEN WITH CAUTION

This shall be in a language considered appropriate by the consignor.”


Labels:

"Vans with hazard diamonds

Many operators of vehicles that are exempt from the requirements to display the orange plates because they are carrying under the thresholds set out in ADR at 1.1.3.6 may display danger signs They may be displayed as placards (250 mm diamonds) or labels (100 mm diamonds) They consider this to be useful to the emergency services.

Ambulances, mobile workshops, engineer's vans and road construction vehicles are examples where hazard diamonds are often displayed.

Some members of the emergency services are concerned that inappropriate action may be taken in the event of an accident involving such a vehicle. They have been advised that the vehicle may be treated as low risk (that is, as if no orange plates were displayed) because the goods should be in limited quantities or under the "small load" limits (see Main Exemptions[1]). If that is not the case, an offence is committed.
Emergency responders will take account of such external warnings in their dynamic risk assessment.

Unless carrying Class 1 (explosives) or Class 7 (radio-active substances) goods carriers displaying placards (250 mm diamonds) should be advised to have them removed. No objection need be taken to the display of labels (100 mm diamonds) as these have no relevance in this context." (source HSE)

So diamonds are not required, but in a change to previous guidance if fitted do not need to be removed for small loads unless the diamond exceeds 100mm in size

[Psuedonym]

Thanks guys, well intended I know but these are not of much use.

The UNECE link is the ADR regulatory page and one that has caused me so much grief. I simply cannot find within the detail of the regs, any reference to the minimum weights required for - non flammable pressurised gas. Either that or my brain has gone on strike through over use. I appreciate the low quantity spec but there isn't much clarity in weight requirements or pressurised gas maximum for the 100mm sticker.
HSE refer back to the ADR regs and there are plenty sites on the net trying to sell stickers or describe them but none explaining the straightforward info.

I may pull over to a VOSA test site near me on my way to work one night/ day but am a bit worried in case they are over keen and slap a fine on me  Mind you at least there will then be something on paper which I can refer to for confirmation - assuming they know. And thats not derogatory as their published prosecution rates only refer to "incorrect" or "missing" labels. None going into actual detail of wieghts and measures. By the way if a clever sales rep may wish to know 70% of the fines are for missing fire extinguishers - now there's an easy sales opportunity for someone 

[Tom Sutton]

Try this go to http://www.unece.org/trans/danger/publi/adr/adr2007/English/001%20E_introvol1.pdf then part 4.1.4.4. (page 155)and you will need the UN number of the particular gasses. Best of luck you will need it.

[Psuedonym]

Thanks TW, I have had a look within this site a couple of times but it doesnt deal with minimum weight requirements for transport diamond non flam labelling only cylinder or product packaging and have, with what sanity there is left  , have decided to give up.
I will make a few calls in the morning. Thanks again 

[AnthonyB]

Right - I've had the agony of pouring through ADR itself.

Fire extinguishers are UN number 1044, CO2 cylinders 1018, fixed system gas extinguishants 1956. All are in Transport Category 3

As such up to 1000kg may be carried and be under the small load threshold for this category & the following apply:


"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 8.1.4.2)
    * Stow the dangerous goods properly (ADR 7.5.7)

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."

A 100mm diamond is considered a label under ADR and does not meet Placard requirements and is suitable for exempted or small loads only.
Where a load comes dully under ADR placards may be required and should be 250mm. Note that 250mm diamonds are not permitted on loads under ADR thresholds and should be removed.

[kurnal]

Hi Pseudo
You should not have any grief from those VOSA guys as like all government based enforcement agencies they will be signed up to the Better Regulation Dept guidelines. They should welcome and support those who are taking the initiative to ensure they are compliant. As such your level of compliance is high even if you aint getting everything right.

Bet you dont get any straight answers out of them though.


 

[Goodsparks]

The guidance on my last ADR course was as Anthony said. If the load is out of scope - then no placards (or labels) on the vehicle and if in scope placards, plates, required ADR kit, qualified driver and paperwork.

[Psuedonym]

Having read your replies through properly (sorry Anthony!) and from the other guys' replies I understand the limitations now and can sleep soundly - apart from the ignorance of my lovely neighbours who know I am on days and nights - this dog will have his day   )

Thanks again for your help guys,

Phil

[Psuedonym]

Finally !!
 

Mr Phil Gardner
By email to philgardner7@aol.com
Case Reference: 004366/10 Monday, 22 February 2010
Dear Mr Gardner
Vehicle Diamond Labels
The provisions in ADR regarding vehicle marking are to be found in Annex A, Part 5,
Chapter 5.3. The relevant paragraph dealing with marking is 5.3.2 and the applicable
sub paragraph is 5.3.2.1.1. This requires vehicles carrying dangerous goods to have
an orange plate mark fixed at the front and the rear of them. There are other
provisions regarding additional information and further orange plate marks but these
are not relevant to vehicles carrying packaged dangerous goods. The gas cylinders
mentioned in the enquiry are packaged dangerous goods.
In addition to the orange plate mark there are requirements to placard vehicles.
Placards are the same as the hazard diamonds except that they measure 250 x
250mm. Paragraph 5.3.1.5 deals with placards on vehicles carrying packages. Apart
from classes 1 and 7 placards are not required.
The requirement to fix orange plate marks to a vehicle is further modified an
exemption related to the quantities carried per transport unit. The detail is found in
paragraph 1.1.3.6 of ADR. The key elements to note here are that this exemption
only relates to packaged dangerous goods and that the limits for application of the
exemption vary according to the class, packing group and in some cases the UN
number of the goods being carried. ADR doesn’t formally recognise Class 2.2 but
note 1 after 2.2.2.1.3 identifies gases in groups A and O as belonging to that UN
group.
Gases in groups A and O have an exemption limit of 1000 litres (if the gas is
liquefied) or 1000 litres of water capacity of cylinders (if gaseous), and this can be
found in the table 1.1.3.6.3. The dis-applications for loads up to this limit are listed in
1.1.3.6.2. and include the whole of chapter 5.3. The orange plate mark is therefore
not required and since chapter 5.3 is the only place in ADR dealing with vehicle
marking the result is no vehicle marking or placarding is required. There is though the
possibility of a warning notice as the exemption doesn’t cover CV36 of 7.5.11 but this
is dependant on the type of vehicle used and its construction.
The 100 x 100mm labels referred to in the correspondence are to be found in
Chapter 5.2 of ADR. This chapter deals with the marking of packages and each
Ext
package of dangerous goods being transported shall have the labels listed in the
dangerous goods list affixed to it. This provision is not altered by the limited load
provision.
You will realise from above that ambulances with package labels on them are
needlessly marked particularly as emergency transport is exempt from ADR
completely.
In conclusion a vehicle carrying packaged dangerous goods below the thresholds
established in ADR at 1.1.3.6.3 requires no marks, labels or placards (but may
require a ventilation warning). The vehicle must be fitted with a 2 kg dry powder (or
equivalent) fire extinguisher for flammability classes A B and C, and the driver should
have had some general awareness training commensurate with his responsibilities.
Vehicles with packaged dangerous goods over the threshold will have orange plates
front and rear. In addition ADR applies in full and this will increase the number and
size of the fire extinguishers, require an ADR trained driver, Instructions in writing and
the appropriate kit for the crew, and a company DGSA amongst other things.
Yours sincerely
Paul Markwick
Chief Executive
paul.markwick@vca.gov.uk

[kurnal]

Simples