Also called ADR 1.1.3.6. The exemption, every driver should know.

Pay attention or pay the price.

As a driver, you should know how to calculate thresholds according to ADR 1.1.3.6. Why? Let me tell you my story, and you will see. Many years ago we had a job. One collection in Ireland and multi drops in France. That was a groupage logistic company. So we had several drops in France and the load was hazardous. Of course, we marked the lorries got the proper documents and hit the road. The last drop in France was in a beautiful village. But the road which takes you there was protected from lorries transporting dangerous goods. You know this sign.Few drivers took the chance and hit that road, others tried to avoid that part and looked alternative roads.  But all alternative solution was much longer distance, wasted time and money. But what can you do? How can you use this road without breaking the law? Is there any chance? YES! Check the exemptions in ADR whether you can apply or not.

This is Not LQ or EQ and I can’t apply any further exemption except……….one. By the end of the trips, only a few palettes left on the trailer. So I checked exemption related to quantities carried per transport unit. And guess what? Before I started to drive to the last drop I checked the threshold  according to ADR 1.1.3.6. I made a note on the CMR, closed the orange plate, and hit the shortest road to that village. So I’m going to show you how to save time and money and use this regulation in a proper way.

Let’s face it. The orange plate vs. authorities is the same as red clothes vs. bulls.

 

 

 

 

The regulation, thresholds, and samples.

Regulation

Transport category:

Every UN number and all dangerous goods are assigned to transport categories 0, 1, 2, 3, or 4, as indicated in Column (15) of Table A of Chapter 3.2.

 

Empty uncleaned packagings having contained substances assigned to transport category “0” are also assigned to transport category “0”. Empty uncleaned packagings having contained substances assigned to a transport category other than”0″ are assigned to transport category “4”.

Where the quantity of dangerous goods carried on a transport unit does not exceed the values indicated in column (3) of the table 1 for a given transport category (when the dangerous goods carried in the transport unit belong to the same category) or the value calculated when the dangerous goods carried in the transport unit belongs to different transport categories, they may be carried in packages in one transport unit without application of the following provisions:

-Chapter 1.10 except for Class 1 explosives of UN Nos. 0029, 0030, 0059, 0065, 0073, 0104,0237, 0255, 0267, 0288, 0289, 0290, 0360, 0361, 0364, 0365, 0366, 0439, 0440, 0441, 0455, 0456 and 0500 and except for Class 7 excepted packages of UN Nos. 2910 and 2911 if the activity level exceeds the A2 value;

– Chapter 5.3;

– Section 5.4.3;

-Chapter 7.2, except for V5 and V8 of 7.2.4;

-CV1 of 7.5.11;

-Part 8 except for 8.1.2.1 (a),

                                 8.1.4.2 to 8.1.4.5,

                                 8.2.3,

                                 8.3.3,

                                 8.3.4,

                                 8.3.5,

                                 Chapter 8.4,

                                 S1(3) and (6),

                                 S2(1),

                                 S4; S5,

                                 S14 to S21 and

                                 S24 of Chapter 8.5;

– Part 9

So these are the provisions you don’t have to apply!!! Make sure, you have to take into account all other ADR provisions.

Let’s see what do these parts, chapters, and sections mean?

You do NOT need to apply the following ADR provisions:

–SECURITY PROVISIONS except for Class 1 explosives of UN Nos. 0029, 0030, 0059, 0065, 0073, 0104,0237, 0255, 0267, 0288, 0289, 0290, 0360, 0361, 0364, 0365, 0366, 0439, 0440, 0441, 0455, 0456 and 0500 and except for Class 7 excepted packages of UN Nos. 2910 and 2911 if the activity level exceeds the A2 value;

–PLACARDING AND MARKING OF CONTAINERS, MEGCs, MEMUs, TANK-CONTAINERS, PORTABLE TANKS AND VEHICLES

–INSTRUCTIONS IN WRITING (tremcard)

–PROVISIONS CONCERNING CARRIAGE IN PACKAGES except “Packages may not be carried in small containers” and “Provisions for substances stabilised by temperature control”.

–Loading or unloading goods in a public place in a built-up area without special permission from the competent authorities;

–Loading or unloading goods in a public place elsewhere than in a built-up area without prior notice thereof having been given to the competent authorities unless these operations are urgently necessary for reasons of safety.

-If for any reason, handling operations have to be carried out in a public place, then substances and articles of different kinds shall be separated according to the labels.

-Requirements for vehicle crews, equipment, operation and documentation except for the followings:

• The transport documents prescribed in 5.4.1, covering all the dangerous goods carried and,when appropriate, the large container or vehicle packing certificate prescribed in 5.4.2;

• fire extinguisher provisions according to ADR 8.1.4.2-8.1.4.5. ( 2kg extinguisher in the cab)

• Training according to ADR 1.3

• Prohibition on opening packages

• Portable lighting apparatus

 

• Prohibition on smoking

• Requirements concerning the supervisions of vehicles

•  Prohibition of smoking, fire and naked flame

•  Supervision of vehicles

• The load compartment of closed vehicles carrying liquids having a flash-point of not more than 60 °C or flammable substances or articles of Class 2, shall not be entered by persons carrying portable lighting apparatus other than those so designed and constructed that they cannot ignite any flammable vapours or gases which may have penetrated into the interior of the vehicle.

• Additional requirements concerning carriage under controlled temperatures

• Special provisions common to the carriage of radioactive material of Class 7 in excepted packages (UN Nos. 2908, 2909, 2910 and 2911) only

• Supervision provisions according to ADR 8.5  S14-S21 and S24

–Requirements concerning the construction and approval of vehicles

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 Thresholds

What does it mean “maximum total quantity” according to table 1 column (3)?

-For articles, gross mass in kilograms (for articles of Class 1, net mass in kilograms of the explosive substance; for dangerous goods in machinery and equipment specified in this Annex, the total quantity of dangerous goods contained therein in kilograms or litres as appropriate);

-For solids, liquefied gases, refrigerated liquefied gases and dissolved gases, net mass in kilograms;

-For liquids, the total quantity of dangerous goods contained in litres;

-For compressed gases, adsorbed gases and chemicals under pressure, the water capacity of the receptacle in litres.

 

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So these are the thresholds if you have one kind of transport category in one transport unit. 0, 20, 333, 1000, and unlimited kg or litres in each transport unit. It’s very important to clarify what “transport unit means”.

Transport unit: A motor vehicle without an attached trailer, or a combination consisting of a motor vehicle and an attached trailer;

What about if we have a different kind of transport categories in one transport unit. Let’s see.

Where dangerous goods of different transport categories are carried in the same transport unit, the sum of:

-The quantity of substances and articles of transport category 1 multiplied by “50”;

-The quantity of substances and articles of transport category 1 referred to in Note a to the table in 1.1.3.6.3 multiplied by “20”;

-The quantity of substances and articles of transport category 2 multiplied by “3”; and

-The quantity of substances and articles of transport category 3;

shall not exceed “1 000”.

Don’t worry. We going to see a sample soon to clear this.

 

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Anything to do with the paperwork? YESSS! If you notice the quantity doesn’t reach or goes below the threshold, you have to make a note on your docket, and then, you can use this exemption. What note you have to make? First of all, you have to fill your documents like normally according to ADR 5.4. But there is an extra note you have to apply if you transporting under the threshold.

“In the case of intended application of 1.1.3.6, the total quantity of dangerous goods for each transport category shall be indicated in the transport document in accordance with 1.1.3.6.3.”

My suggestion is to write the whole counting procedure to the transport docket, highlight the thresholds and show that it is under the limit. And finally, you can write a note “transporting accordance with ADR 1.1.3.6”.

Important: When you counting whether you are under or above the threshold, the dangerous goods exempted in accordance with 1.1.3.1 (a), (b) and (d) to (f), 1.1.3.2 to 1.1.3.5, 1.1.3.7, 1.1.3.9 and 1.1.3.10 (the exemptions I mentioned in my previous blog) shall not be taken into account.

Examples

1.

 

 The first one is very simple. We have 10 palettes of UN2254 matches on the lorry. The total weight is 4355 kg.

According to the table in ADR 3.2 the transport category for UN2254 is 4. Now, we take a look at Table 1 above, and you’ll see transport category 4 means unlimited. So it doesn’t matter how many palettes you transport on the lorry you can apply for the exemption according to ADR 1.1.3.6. For example, you don’t have to mark the lorry with orange plates etc.

2.

UN1950 AEROSOLS, corrosive 2 palettes total weight is 275 kg.

 

According to the table in ADR 3.2 the transport category for UN1950 is 1. Now, we take a look at Table 1 above, and you’ll see transport category 1 means 20 kg. We have 275 kg. So in this case, you can not apply for the exemption ADR 1.1.3.6.

3.

Finally, let’s see a mixed load. The load:

1 palette UN1263 PAINT (including paint, lacquer,enamel, stain, shellac, varnish, polish, liquid filler and liquid lacquer base) or PAINT RELATED MATERIAL (including paint thinning and reducing compound) (having a flash-point below 23 °C and viscous according to 2.2.3.1.4) (vapour pressure at 50 °C not more than 110 kPa) 90kg

1 palette UN1950 AEROSOLS, asphyxiant 125 kg,

1 palette UN1266 PERFUMERY PRODUCTS with flammable solvents (vapour pressure at 50 °C not more than 110 kPa) 180 kg, and

 

 

As you see we have one substance with transport category 2 and two substances with transport category 3. Let’s repeat what ADR says in this case.

-The quantity of substances and articles of transport category 1 multiplied by “50”;

-The quantity of substances and articles of transport category 1 referred to in Note a to the table in 1.1.3.6.3 multiplied by “20”;

-The quantity of substances and articles of transport category 2 multiplied by “3”; and

-The quantity of substances and articles of transport category 3;

shall not exceed “1 000”.

I made an excel to check this.