A one-line consignment note and two undeclared acid drums
A driver reports to a Brisbane freight terminal at 6 am to collect one pallet for Rockhampton. The paperwork is a single-page consignment note reading: '1 pallet, paint related material, 8 drums, 200 kg, DG'. There is no UN number, class, packing group, consignor address or emergency contact - only 'Dave' and a mobile number. The eight 20 L drums are each marked UN 1263, labelled Class 3, PG II. The consignor's rep says the rest of the information 'is in an email somewhere' and shows the driver a photo of the SDS on his phone. Also on the pallet, unlisted, are two 200 L steel drums with the UN 1789 label still attached; they held hydrochloric acid and were 'emptied last week' but not rinsed. The terminal is busy, the truck is already 40 minutes behind, and the rep says 'nobody else ever asks for more paperwork, just take it'.
1. List what is missing or wrong with this consignment note and state what the driver should do before the pallet is loaded.
Read the worked answer
The note does not meet the ADG requirements for a dangerous goods transport document.
Missing or wrong:
- The proper shipping name - 'paint related material' is not a proper shipping name, and it does not match the drums, which are marked UN 1263 PAINT.
- The UN number (1263), the class (3) and the packing group (II).
- The number and kind of packages and the total quantity, stated per line rather than as a single '8 drums, 200 kg'.
- The consignor's name and address - 'Dave' and a mobile number are not an address.
- The consignee's name and address, and the date.
A photo of an SDS is not a transport document. An SDS describes a product; the transport document must describe this consignment, on this vehicle, today.
What the driver should do: do not load it. Tell the loading supervisor and the consignor's rep precisely what is missing, and give them the chance to fix it - it is a five-minute job if the consignor has the information. Record the delay and the reason on the run sheet. Loading first and sorting out paperwork later is how a misdeclared load gets onto the highway, and if there is an incident the document is the first thing examined. If a compliant document cannot be produced, the freight stays behind.
2. The pallet also carries two unrinsed 200 L acid drums that are not on the note. How should they be documented and marked, and what difference does their presence make to the load?
Read the worked answer
They are dangerous goods in their own right. An uncleaned drum containing acid residue is consigned as EMPTY UNCLEANED / UN 1789 / HYDROCHLORIC ACID / 8 / PG II. They need their own line on the DG transport document, the Class 8 label must stay on the drum, and the closures must be secure.
Their presence changes the consignment in three ways.
1. The document is now wrong, not just incomplete. It must list two different UN entries with differing classes and packing groups; a 'paint only' note misdescribes what is on the vehicle.
2. Segregation becomes a live question. Class 8 with Class 3 is not an automatic prohibition, but the acid must not be stowed where a leak can run down onto the paint drums. Upright, closures up, at the outside or base of the pallet, with a physical separation from the flammables.
3. It changes the emergency picture. The driver believed he had a flammable load; he now also has a corrosive. That alters the PPE, the spill kit, the first-aid response and the information he gives emergency services.
The undeclared drums are the strongest reason to stop the load entirely. An undeclared package is exactly the failure mode that dangerous goods documentation exists to prevent.
3. Whose responsibility is the documentation, and can the driver lawfully proceed without it? How should he respond to 'the prime contractor handles all that'?
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Responsibility is layered, but it never transfers away from the driver.
- The consignor must classify the goods and provide a compliant DG transport document.
- The packer and loader must ensure packages are marked, labelled, packed and restrained consistently with that document.
- The prime contractor must not accept dangerous goods for transport unless the documents are in order, and must keep them.
- The driver must not load or carry dangerous goods unless the load is properly documented, marked and (where required) placarded. That is a personal duty, and 'the office does that' does not discharge it.
Can he proceed? Not with that note. The correct sequence is:
- Give the consignor the specific list of missing items and a chance to fix it.
- Escalate to the prime contractor's dangerous goods contact and the terminal supervisor.
- If it is still not fixed at departure time, leave the freight behind and record the decision, the time and who was told.
If dispatch instructs him to take it anyway, he is entitled - and obliged - to refuse. A written instruction to carry an undocumented dangerous goods load is no defence if something goes wrong; the driver is the last person who can stop the truck. He should keep a copy of the note, his refusal and any messages, because the paperwork trail is the only evidence that he made the right call.