Truck and Track Winter 2023 www.truckandtrack.com 62 DANGEROUS GOODS gathered is recorded on the National 10/500 form, which is the mandatory reference and reporting document. “These organised days give officers the chance to learn on their feet and help to provide a consistent approach to enforcement across the country.” As the sun was going down, the last vehicle arrived. It had a trailer full of large sacks containing a Class 5.1 (Oxidizer). The sacks were not secured, even though the company had invested in specialist equipment specifically for this task. 48% Non-Compliance All the vehicles were pulled in at random, without any prior intelligence. In all, 21 vehicles were checked during the day, 10 of which were not in order. These were the primary infringements: 3 x Insecure loads 1 x Emergency contact number obscured 3 x Orange boards displayed when the vehicle was not in scope of ADR 1 x UN numbers missing from overpacks 1 x No shovel 1 x Missing Fire extinguisher When it comes to enforcing the regulations, the Police try to take a pragmatic view and take appropriate action to prevent a recurrence. For example, four of the above situations were managed by engaging with the driver, explaining the noncompliance, giving words of advice, and contacting the company concerned and/or its DGSA. There were, however, three traffic offence reports issued and three prohibition notices. These statistics highlight the very worryingly high rate of non-compliance and, unfortunately, similar results are not uncommon whenever these operations are conducted. Consequently, the frequency of ADR checks is increasing across the country and all Police Forces are scaling up their resources and capability in this area. The enforcement officers who inspect the vehicles are highly trained, usually qualified Dangerous Goods Safety Advisors (DGSAs), and are members of the national CDG Practitioners Forum (CDGPF). Under the UK’s CDG Regulations, they have special enforcement powers and can: ■ process the offence for prosecution by the courts. ■ issue a Prohibition Notice (PN) – these can be deferred, for example, to give time for the driver to replace a non-compliant fire extinguisher. PN’s are listed on the enforcement pages of the HSE website. ■ refer the offence to the Traffic Commissioner (TC), who can revoke the vocational licence of the driver and/or the operating licence of the company. The TC also has the authority to initiate a Public Inquiry. For lesser offences, formal contact with the driver and the Transport Manager at the Company may be deemed sufficient. CDGPF Meeting Terry Harvey and Jason Dearsley are, respectively, the Chair and Vice-Chair of the national CDGPF and, the day after the vehicle check, they ran the November meeting of the forum in the conference room at the Chemical Business Association (CBA) in Crewe. Terry highlighted a complex incident that he recently dealt with in Suffolk involving a tanker towing a gas tank. It raised the importance of using all the contacts and resources available to officers. Jason then covered the activity of the previous day’s policing and summarised the findings. He emphasised that some of the failings are often down to the culture in a company, but the drivers have the ultimate responsibility: “From an enforcement perspective, the most frustrating aspect of the breaches we came across yesterday is that every one of them could have been avoided if the driver had done their obligatory walkaround check thoroughly before driving off.” He added “With such a high rate of non-compliance, the CDGPF will continue to educate and enforce in this highly specialised area of roads policing. We will encourage forces to upskill and work in collaboration so we may support industry and our economy whilst keeping our communities safe.” Digital Formats Recent guidance from DfT gives the driver up to 2 minutes to produce the appropriate Instructions in Writing, so it is important that the document is easily to hand – and not tucked away in the ADR kit as has been known! Terry spoke about the use of digital DG documentation, The nationally-used 10/500 Dangerous Goods Checklist
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