Drammen terminal: paint load with a thin paper trail
It is 06:40 at a container terminal in Drammen. A driver is booked to take a rigid truck and trailer to Kristiansand with 24 drums of UN 1263 PAINT, 3, PG II, each 205 litres, and 8 boxes of UN 3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., 9, PG III, 25 kg each. The transport document gives the UN numbers, proper shipping names, classes, packing groups and total quantities, but it has no tunnel restriction code. The instructions in writing are a 2017 English-only photocopy. The driver's ADR certificate is valid for packages, not tanks, and the driver speaks Norwegian with basic English. The consignor says the load is 'under 5,000 litres, so tunnel rules do not apply'. The dispatcher wants the vehicle to leave in 15 minutes.
1. Which documentary defects must be corrected before departure, and which of the consignor's assumptions is wrong?
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Defects to correct
- Missing tunnel restriction code. ADR 5.4.1.1.1.6 requires the transport document to show the tunnel restriction code where one is assigned. UN 1263 Paint, PG II, has an assigned code. The consignor must supply it; the driver must not invent one.
- Outdated instructions in writing. ADR 5.4.3 requires the current version appropriate to the load. A 2017 photocopy is not evidence of the current ADR text and may omit emergency information. Replace it.
- Language. The instructions must be in a language each crew member can read and understand. English-only may be acceptable if the driver genuinely understands it, but 'basic English' is weak for emergency instructions. Provide a Norwegian version or verify comprehension.
Wrong assumption
The 'under 5,000 litres' argument confuses a random figure with the ADR 1.1.3.6 small-quantity thresholds. For Class 3 PG II the threshold is far lower than 4,920 litres. The paint load therefore exceeds the exemption and full ADR applies. The 200 kg of Class 9 does not rescue the position.
Certificate point
The packages-only ADR certificate is not a bar: the load is in drums and boxes, not tanks. A tank certificate is not needed for this journey.
2. If the paperwork is corrected, what vehicle marking and equipment should be checked because the load is fully regulated?
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Because the Class 3 PG II quantity exceeds the 1.1.3.6 threshold, the vehicle must be treated as a full ADR transport unit. Check:
- Orange plates front and rear, clean and visible, under ADR 5.3.2.
- Fire extinguishers to ADR 8.1.4 for the vehicle's permissible maximum mass, with at least the cab/engine extinguisher and the additional capacity required.
- Instructions in writing matching the load and in a language the driver understands.
- Transport document complete, including the tunnel restriction code.
- Load securing so drums cannot shift or be damaged in transit.
The dispatcher's 15-minute deadline does not override these checks. The driver should refuse to leave until the documents are corrected.