The 1,000-point multi-drop that grows at the third stop
A driver of a 3.5 t panel van loads at a Dublin warehouse for four drops around Leinster. The picking list shows four 20-litre jerricans of UN 1203 PETROL, 3, II; six 25 kg sacks of UN 3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., 9, III; and three 25-litre drums of UN 3264 CORROSIVE LIQUID, ACIDIC, INORGANIC, N.O.S., 8, III. The van carries no orange plates, and the only paperwork is the picking list - no transport document has been prepared. At the third drop the customer asks the driver to take on two extra 200-litre drums of UN 1263 PAINT, 3, II "as a favour" for a site a few kilometres away, and hands him a handwritten note with the UN number and quantities. The van's permissible maximum mass is 3.5 t and it is already carrying about 400 kg of other freight. The driver's ADR certificate covers carriage in packages and is in date.
1. Is the original three-line load exempt under 1.1.3.6? Show the calculation and state what the exemption actually removes.
Read the worked answer
Work through 1.1.3.6 line by line, using the transport category from column 15 of Table A and the multiplier in 1.1.3.6.2:
- Petrol, Class 3 PG II → transport category 2, multiplier 3. 80 L × 3 = 240.
- UN 3077, Class 9 PG III → transport category 3, multiplier 1. 150 kg × 1 = 150.
- UN 3264, Class 8 PG III → transport category 3, multiplier 1. 75 L × 1 = 75.
Total = 465 points, comfortably below the 1000 threshold. The load is exempt.
What that removes: orange plates and the full ADR transport document. What it does not remove: the packages must still be UN-certified and labelled for their class, the load must still be secured (7.5.7), and the driver must still know what is on board. The exemption is a quantity calculation, not a licence to improvise. Note also that the picking list is not a substitute for a document if one is ever required - the driver should be able to reproduce this arithmetic on the roadside, because that is exactly the question a checkpoint asks.
2. Should the driver accept the two 200-litre drums of paint? What would be the consequences of accepting them?
Read the worked answer
No. UN 1263 Paint, Class 3 PG II, is transport category 2 with multiplier 3. Two 200-litre drums = 400 L × 3 = 1,200 points on their own. Added to the existing 465, the vehicle would be at 1,665 points - over the threshold, so the small-quantity exemption collapses for the whole load.
At that point the full weight of ADR applies: orange plates front and rear (5.3.1), a proper transport document for every line (5.4.1), written emergency information the driver can read (5.4.3), fire extinguishers and the miscellaneous equipment in 8.1.4/8.1.5, and a driver holding a valid ADR certificate on board (8.2). The van has none of this fitted and no document has been prepared.
There is also a paperwork point: a handwritten note from a customer is not a transport document, and the customer at the third drop is not the consignor of the original load. The driver cannot authorise a collection on his own account - it must go back to the carrier, who must issue documents and, if necessary, send a compliant vehicle. Accepting "as a favour" would put an undocumented, unplated vehicle over the threshold, which is precisely the offence a checkpoint is looking for.
3. Would the answer change if the extra collection had been one 20-litre jerrican of the same paint?
Read the worked answer
Yes - and the arithmetic is the whole point. One 20-litre jerrican of Class 3 PG II is 20 L × 3 = 60 points, bringing the total to 465 + 60 = 525, still well under 1000. The load would remain exempt, no orange plates would be needed and no transport document would be required.
Two cautions before the driver treats that as a green light:
- The exemption is assessed on the actual total carried at any one time, so it must be re-run at every collection point, not assumed from the original manifest.
- Exemption does not override mass limits. The van is 3.5 t permissible maximum mass with about 400 kg of other freight already aboard; even exempt dangerous goods still count towards payload and axle limits, and overloading is a separate offence enforced on its own.
The discipline being tested is the same in both cases: recalculate before loading, and let the number decide, not the customer's convenience or the size of the package.