Misdescribed cleaning compound and solvent consignment
A driver with a D endorsement is offered two pallets at an Auckland freight depot. Pallet A is labelled 'Cleaning compound' and the SDS supplied by the consignor shows UN 1760, Corrosive liquid, n.o.s. (Class 8, packing group II), 4 x 20 L plastic drums. Pallet B is labelled 'Solvent' and the SDS shows UN 1993, Flammable liquid, n.o.s. (Class 3, packing group II), 6 x 20 L steel drums. The delivery note describes both pallets as 'general chemicals - non-hazardous' and says 'no DG declaration required'. The depot supervisor says the driver can just load them because the quantities are small. The driver has a mixed load and a 300 km trip ahead. No emergency contact number is shown on the delivery note. The driver's vehicle has a clean dry deck and no placards.
1. How should the driver treat the delivery note, and what should the DG declaration contain for these two pallets?
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The delivery note is wrong to describe the pallets as non-hazardous. The SDS is the relevant information: Pallet A is UN 1760, Corrosive liquid, n.o.s., Class 8, PG II; Pallet B is UN 1993, Flammable liquid, n.o.s., Class 3, PG II. Because these are dangerous goods and the load may require placarding, the driver needs a DG declaration, not just a delivery note. It should list each proper shipping name, UN number, class, packing group and quantity, the total quantity, consignor and consignee, and a 24-hour emergency contact. The driver should not accept the 'non-hazardous' description or sign it as correct. If the consignor cannot provide a complete declaration, the load should not proceed.
2. Can the two pallets be carried together, and what segregation and stowage checks are needed?
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The driver cannot assume compatibility just because the quantities are small. Class 3 flammable liquid and Class 8 corrosive can react or contaminate each other if they leak, and the segregation table must be checked. If the table requires separation, the pallets must not be strapped together or placed in the same compartment without a barrier or safe distance. They should be stowed so drums cannot fall, puncture or leak onto each other, and the vehicle deck should be clean and free of incompatible residue. Placards for both Class 3 and Class 8 are needed if the load is above the placard threshold. If the driver cannot achieve the required segregation with the vehicle available, the load should be refused or split.
3. What should the driver do if the depot supervisor insists the load is 'too small' to need paperwork?
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The driver should explain that the decision is based on the hazard and the Rule, not on the supervisor's opinion, and that the SDS shows dangerous goods. The driver should ask for a written DG declaration and the emergency contact, and should not sign the delivery note as non-hazardous. If the supervisor still refuses, the driver should not move the vehicle, notify their own transport operator, and record the refusal. The driver's D endorsement carries a responsibility to prevent an unsafe or non-compliant load from going on the road.