Whilst at a recent conference a rather vigorous discussion was observed with regards to what is required under ADR with regards to Limited Quantities (LQ). So what are LQ and what exactly are the requirements?
LQ allows for the fact that smaller quantities, and those packed in smaller containers, of dangerous goods pose a lesser risk when they are transported than larger quantities. Due to this not all of the requirements of ADR apply when only LQ are being transported. In order to determine if a specific dangerous good can be carried as LQ Column 7(a) of Table A needs to be reviewed. The code present relates to the limits, below which, it can be transported as LQ. Not all dangerous goods can be carried as LQ because even when in small quantities they still pose a significant hazard, these have a 0 present in the column.
Where products classified as dangerous goods are being transported under the LQ threshold, due to the reduced risk, then they may be carried without application of all the provisions of ADR. The following, however, still are:
In order for the dangerous goods to remain under the LQ threshold the gross weight of the package must not exceed 30kg, 20kg for shrink wrapped trays. If dangerous goods above the LQ thresholds are being transported with those below it then all the requirements of ADR, effecting the driver and vehicle, apply.
The main bone of contention during the observed discussion was driver training. Whilst the requirement for an ADR license, as listed in Chapter 8.2 of ADR, is not a requirement the general training requirements, as listed in Chapter 1.3 of ADR, due remain. This states that all personnel involved in the transport of dangerous goods need to familiar with the general requirements of the provisions for the carriage of dangerous goods. In addition to this personnel require appropriate training for their duties and responsibilities.
It should also be remembered that dangerous goods regulations are not the only regulations which impact on the transport of dangerous goods. The Health and Safety Executive have made it clear that training is also a requirement of the Health and Safety at Work Act and that they will prosecute employers who are in breach of this requirement.
So are you compliant with all the requirements? Would your drivers know what the hazards were of a load bearing a LQ label or what to do is a package was dropped and split open?
If you would like further information on ADR or compliance with industry regulations please feel free to contact us