What placarding and documentation applies to a combined road and sea journey?
ADR and IMDG
Many IMDG journeys are international but some are domestic, for example to the islands of Scotland, and the Isle of Wight. Vehicles carrying packaged goods present the most common problems and the requirements are summarised in the following table
Packaged goods
Transport unit marking and documentation when a combined sea and road journey is involved
| No column header | ADR | IMDG | ||
|---|---|---|---|---|
| No column header | Vehicle | Document | Vehicle/Container | Document |
| Limited quantities ADR 3.4 and IMDG 3.4 |
Orange plates/placards not required | No | Marked as "LTD QTY" or "Limited Quantity" in letters 65mm high. | Yes* |
| 1.1.3.6.2 or lower ADR (small loads) |
No orange marks/placards needed |
No need to carry if within GB except for some Class 1 and class 7 | Placards on 3 sides for a vehicle or 4 on a container | Yes |
| Above 1.1.3.6.2 | Orange Plates front and rear. Placards for classes 1 and 7 | Yes | Placards on 3 sides for a vehicle or 4 on a container | Yes |
* MCA do not require the document on domestic short crossings for LQ destined for retail sale (MGN342)
Tanks and tank containers
Tanks and tank containers being carried as part of a journey including a sea passage will need to be marked to comply with IMDG before loading on to the vessel. In practice the necessary marking will be applied at the start of the journey. IMDG's tank labelling and placarding requirement are not identical to ADR and this also affects the use of Emergency Action Codes seen on GB vehicles.
IMDG requires
- The hazard diamonds (placards) for both primary and, where applicable, secondary class on all four sides of a tank container (same as ADR)
- The proper shipping name of the substance on at least both sides (not required by ADR)
- The UN Number of the substance either within the hazard diamond (below the pictogram) or on an adjacent orange board. Placing UN numbers within the hazard diamond is not ADR practice
ADR requires the UN Number and Hazard Identification Number (HIN - sometimes known as the "Kemler" code) on the orange plate (as illustrated in 5.3.2.2.3 of ADR) on at least two sides. IMDG does not require the HIN to be displayed
Because the requirements are different, ADR allows the IMDG method to be used as long as the transport unit is marked with plain orange plates front and back (ADR 1.1.4.2.2).
To comply with IMDG it is necessary to have IMDG compliant documentation and this is more stringent in some ways than ADR. ADR accepts IMDG documents (ADR 5.4.1.4.1).
For GB registered vehicles on GB domestic journeys the HIN as required by ADR is replaced by the hazard warning panels including the telephone number where specialist advice may be obtained.
It follows that if the HIN is not required then neither is the GB hazard warning panel. Such a case is where the journey is being carried out under IMDG terms.
To summarise, an IMDG journey, whether within GB or internationally, may be carried out with the tanks marked as for IMDG (see above) and with plain orange plates front and back on the transport unit.
All the other relevant parts of ADR apply (driver training, vehicle equipment etc.)