Spill Prevention

These consultations by the Environment Agency have been issued to RHA members, our RHA Recovery members will have experience of these situations at first hand, so if you feel you would like to make a point please send your comments to Nick Deal, our Manager of Logistics Development, so that he can formulate a response.

1.    More Spill Prevention – The Environment Agency has issued a consultation about a revised version the PPG currently known as ‘Dealing with spillages on highways PPG 22. The plan is to widen the scope of PPG and it would have a new title ‘Incident response – dealing with spills: PPG 22’. The consultation can be viewed from this link https://consult.environment-agency.gov.uk/portal/ho/green/ppg22  This aims to give up to date information to companies reduce the environmental impact of a polluting spill.  RHA will respond to the consultation and members wishing to contribute should send comments to n.deal@rha.uk.net by 13 September 2010.

2.    Spill Prevention – A new survey and report made available to download free, has shown that over 50% of transport, logistics and distribution operators say they have suffered a major environmentally hazardous spill. Spill Prevention for Transport, Logistics and Distribution Industries has been produced and published by the Environment Agency and Clear Path Analysis in conjunction with the British Safety Industries Federation. The report gives advice on steps to take which major companies within industry are employing and the challenges that they face.

1.1.3    Exemptions  

1.1.3.1    Exemptions related to the nature of the transport operation

    The provisions laid down in ADR do not apply to:

    (a)    The carriage of dangerous goods by private individuals where the goods in question are packaged for retail sale and are intended for their personal or domestic use or for their leisure or sporting activities provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage. When these goods are flammable liquids carried in refillable receptacles filled by, or for, a private individual, the total quantity shall not exceed 60 litres per receptacle and 240 litres per transport unit. Dangerous goods in IBCs, large packagings or tanks are not considered to be packaged for retail sale;

    (b)    The carriage of machinery or equipment not specified in this Annex and which happen to contain dangerous goods in their internal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage;

    (c)    The carriage undertaken by enterprises which is ancillary to their main activity, such as deliveries to or returns from building or civil engineering sites, or in relation to surveying, repairs and maintenance, in quantities of not more than 450 litres per packaging and within the maximum quantities specified in 1.1.3.6. Measures shall be taken to prevent any leakage of contents in normal conditions of carriage. These exemptions do not apply to Class 7.

        Carriage undertaken by such enterprises for their supply or external or internal distribution does not fall within the scope of this exemption;

    (d)    The carriage undertaken by or under the supervision of the emergency services, insofar as such carriage is necessary in relation to the emergency response, in particular carriage undertaken:

-    by breakdown vehicles carrying vehicles which have been involved in accidents or have broken down and contain dangerous goods; or

-    to contain and recover the dangerous goods involved in an incident or accident and move them to a safe place; (replace ‘a safe place’ with the nearest appropriate safe place’

    (e)    Emergency transport intended to save human lives or protect the environment provided that all measures are taken to ensure that such transport is carried out in complete safety;

    (f)    The carriage of uncleaned empty static storage vessels which have contained gases of Class 2, groups A, O or F, substances of Class 3 or Class 9 belonging to packing group II or III or pesticides of Class 6.1 belonging to packing group II or III, subject to the following conditions:

-    All openings with the exception of pressure relief devices (when fitted) are hermetically closed;

-    Measures have been taken to prevent any leakage of contents in normal conditions of carriage; and

-    The load is fixed in cradles or crates or other handling devices or to the vehicle or container in such a way that they will not become loose or shift during normal conditions of carriage.

This exemption does not apply to static storage vessels which have contained desensitized explosives or substances the carriage of which is prohibited by ADR.

    NOTE: For radioactive material, see 1.7.1.4.