With the firework season nearly upon us there’s an enormous demand from the firework distributors for large numbers of hauliers and same-day couriers to carry out their deliveries over a very short period.
Considering the obvious hazards of firework transportation, and indeed every aspect of the manufacture, storage and transportation of fireworks, it might be expected that firework manufacturers and distributors would be more careful than most in checking the qualifications and experience of the transport companies they use for their deliveries.
I would expect a responsible firework distributor to fully vet their transport suppliers to ensure that they fully understand their responsibilities under ADR and have access to a competent Dangerous Goods Safety Advisor, to offer their own advice to the transport company on the safe transport of their goods if necessary, and above all to ensure that the transport company is fully aware of the training that their staff and subcontractors are required to undertake before transporting fireworks.
I was surprised then to read a message posted on one of the leading courier industry websites looking for 70 vans to do 172 journeys over a 3 day period delivering fireworks. There’s nothing particularly wrong with that, although I didn’t think that the company were likely to find 70 suitably qualified drivers on the website in question. I was slightly concerned at this stage that although the company had mentioned the need for various items of safety equipment, they hadn’t mentioned any need for training.
The next day the company followed up their posting with the information “You do not need ADR because the NEC (explosive content) doesn’t exceed 50kg per 3.5 tonne vehicle”. I’m not a DGSA, or even ADR qualified, but this had me very worried on two counts. Firstly, the large multishot fireworks that can be bought from any supermarket typically have an NEQ of over 1kg. Only 50 of these fireworks would exceed the stated 50kg limit, yet the courier company are looking for vans capable of carrying the equivalent of several hundred times that amount. Secondly, and more worryingly, the company were still giving the impression that no training was necessary to carry these goods.
Although they have correctly stated that full ADR isn’t needed as long as the load is below the ‘small load’ threshold, and even identified that safety equipment is still needed, they seem to have completely overlooked the general training (’awareness’) requirements of 8.2.3 of ADR. Of course it’s always possible that they’re planning to put all the drivers through an awareness training session before they’re allowed to collect the goods, but due to the company’s silence when this subject was brought up I suspect that they had no such plans.
This isn’t the first time I’ve seen this sort of thing happen – I wrote about an incident a few days ago – but this is the first time I’ve seen a reputable company advertise this type of work to unqualified personnel in such a blatant manner.
There’s still a lot of misunderstanding of the ‘small load’ and ‘limited quantity’ exemptions to ADR, although I’ve written about them in the past and the HSE have a very useful information page explaining the issues.
The golden rule is: IF YOU’RE IN ANY DOUBT AT ALL WHETHER YOU’RE QUALIFIED TO CARRY DANGEROUS GOODS THEN YOU’RE NOT QUALIFIED ENOUGH TO MAKE THE DECISION.
Packages marked with white LQ diamonds can be carried without special training. FIREWORKS CAN NEVER BE CARRIED UNDER AN LQ EXEMPTION.
Loads under the small loads thresholds can be carried with ‘general training’, also known as ‘awareness training’. You’ll still need safety equipment etc, but if you’ve had the awareness training you’ll know that.
There are no fireworks that can be carried by road for hire and reward without the driver and all members of the vehicle’s crew having had a minimum of ‘awareness’ training. For large loads, and even small loads of fireworks in Transport Category 1, full ADR training will be required. Don’t let anyone tell you otherwise.
Posted under Hazardous Goods - ADR
Posted by alec at 1:16 pm, October 4, 2008
I totally share your opinion. I work in the Fireworks industry and can assure you that any reputable retailer/wholesaler will definitely expect the couriers to be fully ADR licenced. I NEVER transport fireworks and yet I have taken the ADR training at the behest of my employer to address any queries which may arise. It is very irreponsible for any courier not to take this into consideration when you consider that there is a 25 metre safety distance with ALL 1.3g fireworks – I dont know many vans that are over 25 metres long!!