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Staying out of danger
Page 42
Page 43
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In 2009 a new set of ADR regs come into force in more than 40 countries in Europe and beyond, with two immediate and important changes in procedure for British operators to implement.
Words: Dave Young
ADR leg isLatio n is amended every two years, with the latest changes coming into effect on 1 January this year. The new rules then become statutorily enforceable as part of UK domestic carriage of dangerous goods (CDG) regulations on 1 July —providing a window for operators to ensure compliance.
A number of official agencies consult with operators and are involved in the enforcement of ADR rules, including the Department for Transport (DfT), DVLA, VOSA, Driving Standards Agency (DSA). police, and the Maritime and Coastguard Agency.
The Health & Safety Executive (HSE) takes the lead role in co-ordination and implementation. In addition, bodies such as the Road Haulage Association (RI-IA) — representing hauliers — and the National Dangerous Goods Training Consortium (NDGTC) — representing more than half of the approved ADR trainers — are involved in discussions with the HSE and other government departments.
"ADR legislation is prescriptive, but based on international recognition of training standards," explains Clive Dennis, the HSE's inspector of safety responsible for ADR.
The HSE works with a number of UK agencies in order to formulate implementation policy and this, reveals Dennis, "is determined by an assessment of risk and proportionate enforcement':
Instructions in writing
The 'instructions in writing' rules concern Tremcards', and consignment documents meeting the requirements of ADR regulations, They must be carried by the driver to provide essential product information to emergency services in the event of an accident.
The 2009 revision of ADR statutes introduces changes to the instructions in writing, both in terms of the content and who is responsible for supplying them.
"Currently, it is the consignor who is responsible for the content of these instructions.For At) R2009, this becomes the responsibility of the carrier, who must ensure the vehicle crew understand and are capable of carrying out the instructions properly," says Nick Deal, manager logistics development and secretary to the RHA Tanker Group.
These new documents must not only be carried, but also be produced in colour and to a new four-page 'model' format. Despite the law requiring all CDG firms to use the services of a dangerous goods safety adviser. Deal says there are still gaps in knowledge. When recently informing members of the changes to the 'instructions in writing' rules, the RHA was contacted by 60 firms that it wasn't aware were carrying dangerous goods.
ADR training and the Driver CPC
The initial basic ADR course can now be approved as an integral component of periodic CPC training up to a maximum of 21 hours (out of the 35 hours required in total). Seven hours of the core module refresher course are also approved, but, at present, specialist ADR modules will not be counted. This is a cause of some disappointment. Both the RHA and NDGTC are lobbying to change the situation, arguing that courses approved by one part of government shouldn't need further ratification.
The issue is further complicated by the DtT having recently ceded responsibility for ADR training to the DSA.
Future changes to ADR regs
• Amendments to tunnel codes. Al present, each tunnel operator decides who or what can traverse the tunnel. For example, Dartford allows petrol tankers only with an escort. Deal says: "New rules will hopefully make the planning of movements easier as each tunnel, instead of effectively having its own set of rules, must adopt a [ubiquitous] tunnel code from January 2010."
• New markings for vehicles carrying environmental pollutants are being prepared.
• Directive 2008/68/EC of the European Parliament brings together the current provisions on the transport of dangerous goods by road and rail — which implement ADR (road) and RID (rail) into national legislation — into a single directive, together with provisions on transport by inland waterways (ADN). •