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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:

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:

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.

Updated 2011-06-12