The diversion through a category E tunnel
A driver collects six 200-litre drums of UN 1203 PETROL, 3, II from a terminal near Dublin Port for delivery to a plant north of the city. The transport document shows the tunnel restriction code "D/E" in the correct position. The planned route uses the motorway, but an overhead matrix sign warns that the northbound carriageway is closed at the next junction after an earlier collision. The signed diversion sends all traffic through a tunnel whose portal carries a prohibition sign marked "E". The alternative is a 25-minute detour on ordinary roads the driver has never used. The tachograph shows two hours of driving remaining before a break is due, and the customer has already rung twice for an ETA. A colleague tells the driver that "nobody bothers with that sign at night".
1. How is the "D/E" on the transport document used to decide whether the driver may enter the tunnel?
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The code is a cross-reference, not decoration. Column 15 of Table A assigns each substance a tunnel restriction code; the table in 8.6 then converts that code into the tunnel categories in which passage is prohibited.
- "D" means the vehicle is prohibited from tunnels of category D.
- "E" means it is prohibited from tunnels of category E.
- It is not prohibited in categories B or C, because those letters do not appear in the code.
The driver's task at the portal is therefore a two-part comparison: read the category from the sign, read the code from the document, and check whether the sign's letter appears in the code. A category E tunnel and a code containing E is a prohibition, full stop - the code is telling you this load, at this quantity, on this vehicle, may not go through.
Where the code and the sign do not overlap - for example the same petrol load arriving at a category C tunnel - the tunnel restriction does not block the journey, and the driver can proceed, subject to any other restriction on the route.
2. What should the driver do now, and what should be communicated and recorded?
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The driver must not enter the tunnel. The prohibition is absolute, it does not depend on the time of day, and a colleague's practice is not a defence - a roadside check or an incident inside the tunnel would expose the driver and carrier immediately.
The practical sequence:
- Stop in a safe place before the portal, not in the tunnel approach lane.
- Check that the detour route does not itself pass through another restricted tunnel before committing to it; diverting into a second category D or E tunnel solves nothing.
- Contact the carrier's transport manager or dangerous goods safety adviser and explain the situation, then let the customer know the delay is caused by a legal restriction, not by choice.
- If the vehicle has to wait, apply the parking and supervision rules in 8.5 for a load of this kind rather than leaving it unattended in an unsuitable place.
Record the decision and the reason. If a late delivery penalty is threatened, the record is what shows the driver applied the restriction correctly rather than simply being slow.
3. The customer suggests splitting the load so that only three drums travel at once. Does that help with the tunnel sign?
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Only if the split actually changes the rules that apply, so work it through rather than assuming.
Three 200-litre drums of Class 3 PG II is 600 L × 3 = 1,800 points - still far above the 1000-point threshold in 1.1.3.6, so the load remains fully subject to ADR, keeps its tunnel restriction code, and is still barred from the category E tunnel. Splitting has changed nothing except that two journeys are now needed.
To gain anything from splitting, the quantity per journey would have to fall below 1000 points, i.e. under about 333 litres of this petrol. At that level the small-quantity exemption applies and the tunnel restriction no longer bites. That is a legitimate outcome, but it is a decision for the consignor and carrier to plan and document, not something a driver can improvise at the portal with drums on the tail-lift.
The correct answer at the roadside is still the same: do not enter, take the detour, and let the commercial discussion happen afterwards.