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Carriage of Dangerous Goods by Road (ADR)
Vehicle and Premises Inspections –What to expect during an inspection.
Stephen McGarry
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Carriage of Dangerous Goods by Road - ADR
Road side vehicle inspections
• An Garda Siochana
• Directive 95/50/EC as amended
• Uniform checks in Member States
• Dangerous goods vehicles and spot check on unmarked vehicles
• 2018
247 dangerous goods vehicles inspected
147 non-dangerous goods vehicles
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Vehicle Inspections
• Vehicle stopped by Gardaí or HSA Inspector in the presence of the Gardaí
• Inspector I.D. & purpose of inspection explained to driver
• Duration – approximately 20 minutes
• Driver required to provide information :
- Documentation
- Transport operation
- Safety equipment on vehicle
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Vehicle Inspection
Documentation
• ADR Driver Training Certificate
• *Transport Document
• Instructions In Writing
• Certificate of Approval for the Vehicle
• Relevant authorisations e.g. No.2/2017
Common Problems
• Document(s) not carried
• Out of date
• Incomplete or incorrect information
*Transport document must specify:
- UN number, proper shipping name, class, packing group, (tunnel code).
- Number and description of packages.
- Total quantity of each different UN number
- Consignor and consignee
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Vehicle Inspection
Transport Operation
Driver may be asked to open the cargo holding area (vans, curtain-sided, freight containers)Inspection of:• Load security,• UN packaging, • Marking, labelling, over-packing
provisions,• Packaging in test-date (IBCs)• Damaged or leaking packaging• Dangerous goods carried in line with
documentation
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Vehicle Marking and labelling
• Vehicle orange plate marking
• Vehicle placarding
• Tank test data plate
Occasional problems:
- One or both orange plates not displayed
- Placards/plates faded or damaged
- Damage to tank shell
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Vehicle inspection
Equipment and PPE to be carried:
• Wheel chock
• Self standing warning signs (x2)
• Eye wash (2 x 500ml)
• High visibility vest
• Torch
• Suitable Gloves
• Safety glasses
• For certain hazard classes (3, 4.1, 4.3, 8 and 9) “spill kit” – shovel, drain seal, collecting container
• Emergency escape mask (toxic substance/gas)
• Fire extinguishers (minimum x2)
Common problems:
- Missing items….
- Batteries flat
(torch /flashing warning
signs )
- Out of date eye wash or
when carried, out of date
filters for escape mask
- Extinguishers out of date
(to be marked with next inspection due date).
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Completion of vehicle inspection
Driver handed inspection checklist, detailing;
• location, date, time, carrier, consignor and load
• the items inspected and infringements identified
• Remarks if necessary and signed by the inspector
- Follow- up action may include contacting the carrier and other participants
- Enforcement action – written advice, Fixed Payment Notice, Contravention or Prohibition Notice….. Prosecution.
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Premises Inspection
Who?....Dangerous goods consignors, carriers, packers, (un) loaders, fillers, vehicle, tank, tank container or portable tank operators and dangerous goods waste producers.
• Inspections unannounced
• Senior manager/health and safety manager/DGSA
• Duration 1 and 2 hours….
• Compliance - Visual inspection of plant and process, dangerous goods prepared for dispatch and any hazardous waste, supporting documents and training records.
• 2018 – 210 dangerous goods premises inspections
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Premises Inspection
• Inspection may include the following:- Appointment of a Dangerous Goods
Safety Adviser (DGSA),- Dangerous goods – produced, carried,
used and hazardous waste products,- Packaging (specification and use),- Training / training records,- Documented procedures,- Tank files (tank history: vehicle approval
certification and tank test records/ repair for each tank),
- Exemptions ? (LQ, small load),- Accident reports,- DGSA annual report.
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Premises Inspections
Fundamental to all inspections -Is a DGSA appointed?
Mandatory for many organisations, but not all.
Dependant on the activity involving dangerous goods; quantity, shipment frequency and tanks (tank vehicles/ containers/ portable) are used.
If so, the DGSA annual report will be asked for.
If not, a DGSA may still be required on an ad-hoc basis.
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Premises Inspection
• Premises inspection while checking for compliance is primarily advisory (report of inspection).
• Ensure to ask the inspector if clarification is necessary.
• Infringements must be addressed - follow-up action via a written report of inspection.
• Further enforcement action, where necessary, may include the issue of a Fixed Payment Notice, Contravention Notice or Prohibition Notice.
• Confirmation of compliance / action taken will be sought.
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Vehicle and Premises Inspections
Summary
• Vehicle road side inspections are very prescriptive (uniform Checklist), report provided to driver, relatively short in duration – significant problems will lead to significant delays and further enforcement action.
• Premises inspections afford a greater level of interaction between the participant and the inspector – take the opportunity to ask questions.
• Majority of enforcement is advisory, primarily written (verbal direction may be given) and is legally binding on the participant.
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Guidance available www.hsa.ie
• Consolidated legislation S.I. 349, 2011 to 2017
• ADR Guide for Business
• Guidance on the appointment of a DGSA
• Guidance on the duties of a DGSA
• ….. Many more