ADR explained
Page 30
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Iwrite regarding the article entitled "Certified Changes" ((.M 11-17 Dec 1997). I felt that the last paragraph on page 33 was perhaps a little misleading The figures you gave for what can be carried without certification are taken from the CDG (R) 1996 Regulations, schedule 1, table 2 (page 23). If we look at column 2 it says -individual package mass or volume".
It is also the size at which the consignor informs the operator. Next we look at column 3, which is concerned with how many litres or kilogrammes are to be loaded. Above the limits shown the operator applies the transport rules and "orange coloured panels" are fitted. The column 2 limits have to be exceeded before column 3 comes into operation, and then the vehicle is "under regulation."
From the above it would seem that provided the category I goods come in receptacles of less than lit/kg then any amount can be loaded up to the vehicle's legal gross weight without certification.
This must be extremely confusing for an uncertificated driver engaged in the carriage of general cargo or groupage. Sometimes he may load dangerous goods and at other times would require an ADR certificate.
There must be many drivers who are asked to load small consignments and unwittingly load something that ought to be "under regulation", and others refusing a load wrongly believing that they are not allowed to carry it.
I am sorry if I appear to he nitpicking, but having regard to the possible penalties for contravention I respectfully suggest that you might print my letter to clear up this point. By doing so I am convinced that you would have the gratitude of all the doubting uncertificated drivers. Our efforts might even save somebody from prosecution!
David Wood, Ellesmere Port, South WirraL