The drum that doesn't match its paperwork
At a distribution depot on the north side of Dublin, a driver is collecting one pallet for a customer in Galway. The transport document handed over reads: "UN 1789, HYDROCHLORIC ACID, 8, II, 1 drum, 250 litres". The drum itself carries a Class 8 corrosive label and the number 1789, but it is a plain blue plastic drum with no UN packaging mark moulded into the body or base. A copy of the consignor's dangerous goods note, lying on the counter, shows Packing Group III for the same consignment. When the driver queries the difference, the loader says the acid is "only dilute, so it's fine", and that the vehicle must leave within twenty minutes or the customer's line will stop. The drum has been hand-tightened, and there is a ring of dried white residue around the bung. The driver has not yet signed the collection sheet.
1. Should the driver sign for and carry this drum? Set out the checks that matter and say who is responsible for what.
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The driver should not sign. There are three separate faults, and any one of them is enough to stop the collection.
- The packing group conflict is the consignor's to resolve. Classification, packing and documentation belong to the consignor (ADR 1.4.2.1). Packing Group II and Packing Group III give different packing instructions, different 1.1.3.6 point values and potentially a different tunnel code. A driver cannot pick one version and carry on; the paperwork must be corrected at source.
- No UN mark. Packaging for a PG II acid must be UN-certified and marked accordingly (Part 4). A plain plastic drum cannot be assumed to meet the packing instruction simply because it looks sturdy.
- Residue at the bung. Packagings must be closed so that nothing can escape in normal carriage conditions. Dried product around a hand-tight bung is evidence that the closure has been weeping.
"It's dilute" is not a classification the driver can rely on, and speed of departure does not transfer the risk. The driver's own obligation (1.4.2.2) is to check that documents and load are in order before accepting, and to refuse and escalate where they are not. A verbal reassurance is not a correction.
2. The consignor re-issues the document as Packing Group II and confirms the drum is UN-marked 1H1. What changes for the journey, and what does not change?
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With a corrected document and a UN-marked drum the load is in order, but the correction shifts several things:
- The packing instruction and the label are now those for PG II; the Class 8 label and UN 1789 stay as they are.
- The 1.1.3.6 calculation uses the transport category for Class 8 PG II, which is category 2 with a multiplier of 3: 250 L × 3 = 750 points. That is below 1000, so the load stays inside the small-quantity exemption.
- Because the exemption applies, orange plates are not needed and a full ADR transport document is not required. If a document travels with the load for other reasons it should still be accurate, and the driver should be able to explain the calculation if stopped.
What does not change: the packaging must still be UN-certified and leak-tight, the Class 8 label must still be on the drum, the drum must be secured, and the driver must still know what is on board and what to do if it leaks. The exemption reduces marking and paperwork, not basic safety. A driver who treats "exempt" as "no rules" has misunderstood the calculation.