Does Limited Quantities provide cover for limited compliance?

Last week I received an important order to get me through the summer months; a box containing two jerricans of specialist lawnmower fuel. For those still nursing their petrol lawnmowers rather than moving onto arguably more reliable (but also dangerous goods powered) lithium battery mowers, using specialist lawnmower fuel is a game changer to the running of your machine.

I’ve gone from filling a jerrican at the petrol pumps (then driving home using ADR 1.1.3.1 (a)) to ordering a fuel delivery to my house. However, I’m yet to receive an order packed in compliance with the dangerous goods regulations.

You might say two jerricans of five litres each is a small amount, and shouldn’t we be worrying about compliance of bigger things? You could also argue under road derogation 4, if the supplier delivered my fuel directly from their own warehouse, they wouldn’t need to comply with marking requirements, so even if it’s going through multiple transport hubs, I’m making a fuss about nothing.

However, these goods were dispatched from a central location and according to the carrier tracking they went through several transport hubs before reaching my doorstep – so they should have been properly marked in line with the ADR regulations.

The two five litre jerricans turned up with a limited quantities mark on the box, albeit in the wrong orientation. However, what really piqued my concern was the actual box; there was a large hole in the top, and it clearly wasn’t a good quality package able to withstand ‘shocks and loadings normally encountered during carriage’ (ADR 4.1.1.1). Then, when I opened it from what I thought was the top, the jerricans were upside down. The box was missing orientation arrows, and in turn the address label had been put on the box in the opposite orientation to the contents, meaning the fuel had been transported upside down throughout journey.

When you consider the hole and loose fitting box as well – it wouldn’t have taken much of an impact to damage the jerrican lids and cause a leak of petrol. This brings about the question – why are shippers of limited quantities able to be less compliant than those moving fully regulated dangerous goods?

This reinforces the view at Peter East that some of our biggest opportunities for future work are with organisations that don’t know they need our help and training. Moving limited quantities is easy to understand once you’ve had some training, but training is still a mandatory requirement.

We have a specialist Excepted and Limited Quantities by Air, Road & Sea training course, and can deliver more focused training in-house for example focusing solely on limited quantities by road, or excepted quantities by air. More details here.

Do get in touch if you think we can help your organisation, or if you have any questions about limited quantities transport.

By Sam Mohr DGSA