Last reviewed 26 February 2016
In the article, Caroline Raine discusses the actions that should be taken in the event of a spillage on the road.
Introduction and training
Before even starting to think about transporting dangerous goods, it is important — in fact, a legal requirement — to ensure that all those who are dealing with the dangerous goods have received function-specific training to the role that they are undertaking. This requires all personnel involved in the carriage of hazardous goods at any stage in the process (from packing the goods for carriage, consigning the goods, loading, carriage and unloading) to be suitably trained in order to carry out their duties safely.
Chapter 1.3 of the International Carriage of Dangerous Goods by Road (ADR) outlines the requirements for training of persons involved in the carriage of dangerous goods.
For drivers transporting dangerous goods, there are further training requirements as outlined in Chapter 8.2 of the ADR concerning the training of the vehicle crew. Drivers of hazardous goods vehicles must attend and pass a formally recognised and approved training course every five years. This training is known as an ADR training certificate or licence. The drivers of all vehicles (including those with a gross vehicle weight of 3.5t or less) carrying dangerous goods must have an ADR training certificate. There are exemptions for drivers carrying small loads below the threshold limits, drivers carrying dangerous goods packed in limited quantities, and drivers carrying dangerous goods packed in excepted quantities.
The ADR driving training covers all of the specific subjects listed in ADR Chapter 18.104.22.168.2, and gives drivers the knowledge to understand what dangerous goods they are carrying and their associated hazards, and how to mark, label and placard. Information is also given on what to do in the event of an accident.
Some haulage companies go one step further than the basic legal requirements and offer specific chemical first aid training and spill response training. Both enable the driver to know what to do in the event of a spillage, protecting both the driver and any injured parties as well as the environment.
The ADR also specifies equipment that should be carried on board a vehicle carrying dangerous goods. Chapter 8.1 outlines general requirements concerning transport units and equipment on board, and the Instructions in Writing (IiW) in Chapter 5.4 list the equipment needed. The list includes:
a wheel chock
two self-standing warning signs
eye rinsing liquid.
For each crew member:
a warning vest
Also, required for certain classes:
an emergency escape mask (for each crew member)
a drain seal
a collecting container.
Chapter 8.1 also specifies the requirement to carry fire extinguishers, the number and size of which is dependent on the transport unit size.
There is a legal requirement to carry both a transport document and IiW. The transport document is specific to the load being carried and should contain:
the name and address of consignor
the name and address of consignee
a dangerous goods description for each dangerous substance
the number and description of the type of packages for each dangerous substance
material or article in the consignment
the total quantity of each type of dangerous goods with a different UN number, proper shipping name or packing group.
For each dangerous substance, material or article in the consignment, a dangerous goods description must be provided. This consists of a number of pieces of information, which must be listed in the Dangerous Goods Note (DGN) in the correct order.
UN number — preceded by the letters “UN”.
Proper shipping name — including the technical name (if applicable).
The label numbers, as listed in column 5 of the dangerous goods list in the ADR. Note that it is the label numbers that are required, not the class number listed in column 2 — the primary hazard class should be listed first, followed by any applicable secondary hazard classes in brackets.
Packing group (if applicable) — in Roman numerals. May be preceded by the initials “PG” or the equivalent initials in the language that the DGN is being prepared in.
Tunnel restriction code, as listed in column 15 of the dangerous goods list in the ADR. This should be listed in capital letters and within brackets. The tunnel code can be omitted if it is known that the consignment will not have to pass through any tunnels.
The IiW is a generic document that can be found in Chapter 5.4 of the ADR. It is a four-page document that can be used as an aid in the event of an emergency situation. The document must be carried in the vehicle crew’s cab and must be readily available.
Now that we have considered training, equipment and documentation, let us now consider what to do in the event of a spillage.
The first and most critical objective is for the driver to stay safe. He or she should never attempt to clean up a spill if he or she does not feel comfortable doing so. Many haulage companies have their own internal procedures on what to do in the event of an emergency, and there is likely to be an emergency response phone number either on the transport documentation or on the orange placards on the vehicle. Use them and call for advice. If there is no emergency number and no procedure in place and you do not feel comfortable dealing with the spillage, call the fire service.
The next course of action will very much depend upon the size of the spill. Small spills are much easier to deal with, and the equipment carried on board is often sufficient to get the job done, but larger spills may require additional resources.
Always carry out a risk assessment before you get started, consider the hazards of the dangerous goods spilled and act accordingly. Use the IiW to help you ascertain the hazard characteristics and any additional guidance. Managers must make sure that they protect people, the environment and property — in that order.
Consider the wind direction and stay upwind of any spillages, evacuate any personnel and set up a cordon. Identify the required and suitable personal protective equipment (PPE) for the dangerous goods spilled.
If the substance spilled is flammable, do not use any ignition sources — so no smoking, mobile phones and sparking tools. Protect any local watercourses (ie any rivers, streams or ponds); entry can be prevented by sealing drains, which can be done using drain seals, but a plastic bag and bricks or soil to weigh the bag down will also suffice.
If possible absorb the material spilt (if liquid), or sweep if solid and transfer into a labelled container, wash the remaining residue and remember to collect those washings. Dispose of as hazardous waste. Finally, if they have not already been notified, inform the Environment Agency.
Once the spillage has been dealt with, it is important to notify the company’s Dangerous Goods Safety Advisor as the incident may be reportable. An investigation should be carried out and actions identified to prevent reoccurrence.