Placards, tunnels and a driver at eleven hours
A Laverton depot loads a 12 t rigid tautliner for a Dandenong customer. The load is 20 × 205 L drums of UN 1263 PAINT, Class 3, PG II (4,100 L), and six 1,000 L IBCs of UN 1789 HYDROCHLORIC ACID, Class 8, PG II (6,000 L). Both lots are palletised and strapped to the body rails. The truck is normally on general freight; the only dangerous goods signage in the crib room is a magnetic 'DANGER - KEEP CLEAR' sign bought from an auto parts shop. The allocated driver holds a current dangerous goods driver licence and a heavy rigid licence, and has 11 hours on duty when the load is ready, against a 12-hour maximum. The shortest route crosses the Burnley Tunnel; the alternative adds 35 minutes through suburban arterials. The dispatcher wants the truck away immediately because the customer's dock closes at 4 pm, and suggests the driver 'just take the tunnel, it's only a placard load, they never check'.
1. What placarding is required on the vehicle for this load, and why does the magnetic 'DANGER - KEEP CLEAR' sign not meet the requirement?
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First establish whether it is a placard load. The ADG sets a threshold quantity for each class; at 4,100 L of Class 3 PG II and 6,000 L of Class 8 PG II this load is well past them. That single finding drives everything else: placards, HAZCHEM, a DG transport document, a DG-licensed driver, fire extinguishers and route restrictions.
Placards required: a Class 3 placard and a Class 8 placard, displayed on both sides and the rear of the vehicle, clearly visible and legible from the direction of approach - not hidden behind the tautliner's curtain bows. Where two or more classes are carried in a placard load, the vehicle shows the placard for each class present. Beyond the class diamonds, the vehicle must also display the UN number and HAZCHEM code for the substance carried in the largest quantity - here the acid - in the emergency information arrangement the ADG requires.
Why the magnetic sign fails: it is not the specified diamond; it carries no class number, no UN number and no HAZCHEM code; it is not displayed on all required faces; and a magnetic sign can blow off at speed. It is also a false comfort - an incorrect or non-compliant placard is worse than none, because emergency services will read it and respond to what it says. The correct placards must be fitted before the truck leaves the yard, and the dispatcher, not the driver, should be finding them.
2. The dispatcher wants the tunnel route. What is the correct decision, and what would you check before the vehicle moves?
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There are two separate problems, and both point the same way.
Route. Tunnels such as the Burnley Tunnel are subject to dangerous goods restrictions imposed by the tunnel operator and the road authority. A placard load of this size is restricted or prohibited, and the restrictions are not advisory. 'They never check' is not a risk assessment - the consequence of a Class 8 release inside a tunnel is catastrophic, and the driver is the person who will be prosecuted. Before departure, confirm the restriction on the tunnel signage, the operator's dangerous goods guidance and the state dangerous goods route map, then use the approved alternative.
Fatigue and time. At 11 hours on duty against a 12-hour maximum the driver has one hour. The alternative route adds 35 minutes, and unloading at a customer dock takes longer than the 25 minutes left. The run is over the limit before the truck is even loaded. So the answer is neither 'take the tunnel' nor 'hurry' - the run must be re-planned: a second licensed driver, a later delivery slot, or the load held overnight.
What to do: refuse to depart on the planned basis and put the reason in writing to the dispatcher. A dangerous goods driver licence does not authorise a breach of a tunnel restriction or a fatigue limit; both obligations sit on the driver personally as well as on the company.
3. What markings must be on the drums and the IBCs themselves, as distinct from the vehicle placards, and who is responsible for them?
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Vehicle placards are only the outer layer. Each package carries its own markings, and these are the consignor's and packer's job - not something the driver can repair at the depot with a marker pen.
Each 205 L paint drum: the UN number and proper shipping name (UN 1263 PAINT), the Class 3 flammable liquid label, the packing group marking, and the consignor identification required by the ADG.
Each acid IBC: the UN 1789 / HYDROCHLORIC ACID marking, the Class 8 corrosive label and the packing group, plus the IBC-specific markings - the UN packaging code showing it is an approved IBC for this duty, the manufacturer's and serial data, and the orientation arrows. Labels and markings must be on the package, durable and unobscured.
Responsibility: the consignor must ensure the goods are classified, packed and marked correctly before they are offered for transport. The packer applies the marks and labels. The loader must refuse to load packages that are unmarked, mislabelled or leaking. The driver has a final check duty before signing - but the driver cannot lawfully correct a consignor's marking.
If a drum is unmarked, or the label contradicts the paperwork, it comes off the truck and stays in the yard until the consignor fixes it.