The 'E' tunnel that is not exempt
A truck is planned from Oslo to Bergen with three 1,000-litre IBCs, each containing 600 litres of UN 3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S., 9, PG III. The transport document shows the tunnel restriction code (E). The shortest route includes a category E tunnel; the alternative is 70 km longer and uses tunnels of category D and C. The driver says: 'E means exempt, so I can use any tunnel. Only B, C and D codes restrict me.' The vehicle is marked with orange plates and the driver has a valid ADR certificate for packages. The consignor's planner has not checked the Norwegian tunnel list and tells the driver to take the shortest route because the load is only Class 9.
1. Is the driver correct that an (E) code is an exemption? Explain how the code must be read for this load.
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No. The letter in brackets is a tunnel restriction code, not an exemption mark. ADR 8.6 uses categories A to E: A is the least restrictive, E the most restrictive. A category E tunnel is closed to dangerous goods carrying code E, apart from the small-quantity and other exemptions in ADR.
The load is in IBCs, not tanks, so the relevant letter is the one shown for the packaged transport. The document shows (E), so the category E tunnel on the shortest route is not available for this vehicle.
The fact that the goods are Class 9 does not create a blanket tunnel exemption. Class 9 can still carry a tunnel restriction code, and 1,800 litres is a significant quantity. The planner's 'only Class 9' reasoning is wrong.
2. What should the driver do about the route, and what if the transport document had no tunnel restriction code at all?
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Route action
The driver should refuse the category E tunnel. The alternative route uses category D and C tunnels. Under the ADR category system a code E load is not restricted by D or C tunnels, but the driver must still check the Norwegian tunnel list and the actual signs, because national or local restrictions can be stricter or can close a specific tunnel. The driver should record the route decision and not rely only on the planner's assurance.
Missing code
If the transport document had no tunnel restriction code, the driver could not lawfully plan the tunnel route. The consignor must supply the correct code; the driver must not guess it from the UN number. Departure should be delayed until the document is corrected. A missing code is not a minor clerical point, because it removes the basis for choosing a lawful route.