What are the common problems associated with documentation for empty tanks and bulk containers?

ADR at 5.4.1.1.6 sets out the rules for documentation of empty tanks, bulk vehicles etc. This seems simple enough but there can be problems for:

• multi-drops
• gases, where "empty" is not a clear concept.
• nominally empty packages (returned drums or IBCs). The 1.1.3.6.3 (small load) thresholds would usually mean that a load consisting of nominally empty packages would not need documentation (Carriage Regulations at 3(7)(a) dis-apply the ADR requirement in GB, other than for explosives and radioactive materials).

In some cases drivers leave all documentation at the delivery point. This would not be acceptable for tanks and bulk.

The driver may carry a document marked as shown in 5.4.1.1.6 in a secure compartment until it is valid. Documents could be endorsed by rubber stamp or sticky label, and there may be other ways of achieving the required outcome. There is no need for the "empty load document" to be dated. It needs only to comply with ADR at 5.4.1.1.6.2 and to be valid.

There are obvious potential problems but the purpose is to ensure that in an emergency the "blue light services" have information that enables them to take proportionate action.

It is for the carrier (in liaison with the consignor) to comply with 5.4.1.1.6 and how he does so is up to him.

The following pragmatic guidance may be helpful:

• Multi-drops. ADR does not make a special case for part loads. The "starting" documentation would comply. When the tank or bulk container is nominally empty the driver should bring out his "empty document", in whatever form that takes.
• Gases. As for multi loads, but use "empty document" or endorse original when vehicle is nominally empty and returning to base.
• MEMUs: ADR 6.12 is new. These vehicles (which are usually  used for carrying ammonium nitrate and fuel oils in separate compartments for mixing on-site) may go to several sites in one journey and return to base with some  load remaining. For the final return journey to base the document should contain the best estimate of the remaining load but otherwise comply with 5.4.1.1.1.  Sub para (h) almost describes the situation so it is not necessary to have details of each "delivery" address.
• If all documents are left at delivery, then use an "empty document" from that point. Where this is the practice, a pre-prepared document may be the simplest answer.

If the choice is to use a pre-prepared "empty document" it will be important to train the driver in its use and provide a secure compartment for keeping it until it is needed.