Changes to the Rule for Training of Drivers of Vehicles carrying Dangerous Goods
Currently drivers of vehicles with a permissible maximum mass exceeding 3.5 tonnes have to posses an ADR training certificate.
From 1st January 2007 the exemption for drivers of vehicles less than 3.5 tonnes expires. From that date drivers of all vehicles that carry dangerous goods will be required to hold a vocational training certificate (ADR).
General Training Requirements
Since 1999 all persons (not only drivers) such as consignors, carriers, packers and container operators, whose duties concern the carriage of dangerous goods require some form of training. They have to receive training appropriate to their responsibilities and duties. This training is usually an awareness course.
The awareness course must cover the following subjects:
General Awareness Training
Function-specific Training &
Safety Training
Driver Training from 1st Jan 2007
When would a driver require an ADR certificate?
There will be some exemptions that can still be claimed for the driver to have an ADR. These can be found in section 1.1.3.1 – 1.1.3.6.4 of ADR. Some examples are:
1) If the vehicle is being used for private use
2) Carriage of machinery or equipment
3) If package meet the requirement of Limited Quantities
There is an additional exemption where the quantity of dangerous goods carried does not exceed the values set out in table 1.1.3.6. of ADR. To know if this exemption can be claimed, you first need to establish what transport category the goods belong to. This information should be available from the consignor. The second piece of information required would be the quantity of dangerous goods on the vehicle.
If the quantity of dangerous goods carried does not exceed the value indicated for the given transport category the carrier can then claim exemption for the requirement of the driver for having an ADR certificate.
For example:
For Transport Category 0 there are no exemptions
For Transport Category 1. The exemption applies until the quantity carried exceeds 20 (kilograms or litres)
For Transport Category 2. The exemption applies until the quantity transported exceeds 333 (kilograms or litres)
For Transport Category 3. The exemption applies until the quantity transported exceeds 1,000 (kilograms or litres)
Although the driver is exempt from an ADR certificate he would still be required to have awareness training. Where these values (or values for mixed loading in 1.1.3.6.4) are exceeded then the driver would be required to have an ADR.
How the changes came about
August 2002
The Government of Liechtenstein proposed mandatory training for drivers carrying dangerous goods regardless of the permissible maximum weight of their vehicle.
November 2002
Opinions at the United Nations Economic Commission for Europe were divided on the proposal. Some delegates noted that these vehicles were regularly able to carry goods in quantities greater than the exemption limits of 1.1.3.6 and those vehicles were increasingly being used to carry dangerous goods since they were subject neither to the same speed limits as heavy vehicles nor to weekend travel restrictions (for certain countries).
Others considered that in view of the number of drivers concerned, a measure of this nature would have considerable economic consequences and that the cost for carriers should be carefully evaluated with a view to the benefits in terms of safety, which needed to be supported by accident statistics. It was also noted that the drivers of these vehicles were in any case subject to the general company training requirements of Chapter 1.3.
The representative of Liechtenstein was asked to submit a new proposal for the next session, which would take into account the necessary consequential amendments.
May 2003
Liechtenstein resubmits it proposal but this time with support from other countries: Austria, Norway, Poland and most notably Germany
Some delegations said that the proposed obligation concerning the training of drivers of vehicles with a permissible maximum mass not exceeding 3.5 tonnes would involve a very large number of drivers and would therefore have considerable economic repercussions.
Other delegations stressed that training requirements had caused a significant increase in the production cost of the transport of dangerous goods, and that in order to avoid it, the industry was more and more resorting to using vehicles not exceeding 3.5 tonnes, which were increasingly effective in power and speed but fell short of numerous safety requirements.
The representative of Italy proposed that the decision on this proposal should be deferred, so as to give Governments time to collect accident statistics and assess safety advantages in relation to cost. After a vote resulting in equal numbers for and against, the proposal was not accepted.
The Working Party finally decided to adopt the proposal by Liechtenstein to the effect that all drivers of vehicles carrying dangerous goods, irrespective of the permissible maximum mass of the vehicle, subject to the exemptions set out in 1.1.3, must be trained in accordance with 8.2.1. This measure would take effect on 1 January 2007 at the latest (see annex).
So industry has not only had the usual six month introductory period but it has had over 2 years to get ready.
It is unlikely that there will be any extension or exemption as the view is that industry has already had two years to adapt. If they have not adapted by now then they have only themselves to blame.
Although spot checks will not be carried out on January1st 2007, I have been assured that enforcement will be taking place as of the 2nd of January.
Are you ready?
www.ritchiestraining.com
Further information on the exemptions that can be made can be found in the following Microsoft Publisher file:
Exemption Book A4 Size (PDF 296KB)
