Truck and Track Winter 2023 www.truckandtrack.com 66 DANGEROUS GOODS beverages as it falls under ADR [and HMRC are involved, as potable Ethanol is dutiable]. This is especially important with class 6 [toxic], class 9 [Miscellaneous/Environmental] and 8 [corrosive]. With correct segregation, other classes may be accommodated. The UK’s Health and Safety Executive [HSE] offer the following guidelines - The restrictions on carrying foodstuffs (including animal feeds) with dangerous goods are limited and set out in ADR at 7.5.4. The principle is that foodstuffs should not be carried with toxic substances (Class 6.1 and 6.2) or with a limited range of Class 9 substances. However, it is permissible to mix these loads subject to certain precautions which are set out below Partitions at least as high as the packages containing the dangerous substances Separation by packages of substances other than class 6.1, 6.2 or the relevant class 9 substances Separation by a space of at least 0.8 metre By additional packaging or wrapping of the substances. Whilst this is not described in much detail, it would seem that the principle to be followed is that the conventional DG packaging (such as a drum, IBC or bags) should be further covered. Examples might be shrink wrapping or plastic sheeting firmly covering the package or packages. Note that this might constitute an “overpack” and require labelling in its own right (ADR 5.1.2) Containers sourced to hold foodstuffs [such as IBC’s, Drums etc] have to be approved/certified for the carriage of edible/potable material – and dedicated [to prevent cross contamination with chemicals]. They have to be marked/labelled as such, and segregated. Security When ADR incorporated security into the legislation, a term HIGH CONSEQUENCE DANGEROUS GOODS [HCDG] came into play. HCDG’s are a sub-class of dangerous goods that pose specific problems should they fall into the wrong hands. The majority of HCDG’s are Bulk products [with “Bulk” being defined as contained in receptacle size of 3,000 litres or greater]. Product Classes 1 [Explosive], Class 7 [Radioactive] both as bulk and as packages are obviously classed as HCDG. Though Product Classes 2 [Gas], 3 [Flammable Liquids], 4 [Flammable and Reactive Solids], Class 5.1 [Oxidisers], 5.2 [Organic Peroxides], 6 [Toxic] and 8 [Corrosive] are also classed as HCDG in bulk. Product Classes 2.3 [Toxic Gases], 6.1 [Toxic of Packing Group 1] and 6.2 [Biologically Infectious of CAT ‘A’] are classed as HCDG in packages. The reason why bulk is an issue is that a tanker [carrying dangerous goods] hijack or theft is a very troubling situation, though one must not overlook the products that are HCDG in packages either. Some of the key factors [but not exclusive] for Chemical Security under ADR with High Consequence Dangerous Goods [HCDG] are – ■ Ensuring your site has a written security risk assessment and reviewed regularly. Traffic office ADR awareness training TRUCK & TRAILER SOLUTIONS WELCOME TOALLPORTS GROUP allportsgroup.co.uk
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