ADR 2009 – Instructions in Writing (IiW)
Interpretation and Guidance for national operators on the new format IiW.
In order to aid industry and answer some frequently asked questions in relation to the new IiW, the following guidance has been drawn up. Until it is clear that all Contracting parties to ADR have adopted a similar position the interpretation provided is directed at national operators only, while international operators should adopt a more restrictive interpretation.
Instructions in Writing|Type of Shovel|Escape Mask|Drain Seal|Gloves|Plastic Bags|
Can the size of the IiW be changed?
Yes. The ADR only requires that the form and content is not altered. Therefore the size may be changed. For example, to fit the new 4 page document on one double sided A4 sheet. Care must be taken to ensure legibility is maintained.
Can the IiW be produced in black and white?
No. The hazard labels must remain in colour.
Can a logo or other company information be added to the IiW?
Yes, but only on a separate sheet or so that the form and contents of the new IiW are not altered .
What type of shovel is required?
Within reason, any shovel, spade or scoop designed to perform the task of lifting solids may be used. The reason this piece of equipment is specified is to enable the driver to prevent leaked substances reaching the aquatic environment via the placement of absorbent material, sand or earth and the safe collection of same. Note that if flammable substances are present, the shovel should not present a source of ignition - e.g. metal shovels
Do I need a shovel if I only carry class 3 fuels and carry a commercial spill kit, consisting of absorbent mats, booms and plastic bags?
No. As an exception to the rule, vehicles carrying liquids which are equipped with commercial spill kits consisting of pads and booms, designed to manage liquid spills, may be exempted from carrying a shovel.
Are there acceptable alternatives to the emergency escape masks mentioned in the IiW?
Yes. The types of mask filters mentioned on the IiW are only examples that may be carried. The masks are for emergency escape purposes and you may equip a vehicle with any suitable filter/mask as determined by a risk assessment.
Is there one type of drain seal to be used?
No. While commercially available drain seals are acceptable, so too is the use of plastic bags and sand. Any method employed must be capable of preventing leaked material entering a drainage system.
Is there a particular type of protective glove that should be supplied?
No. There is no one standard glove. The carrier should carry out a risk assessment and provide gloves suitable for the substances being carried.
Will heavy duty plastic bags meet the requirement for a collecting container?
In most cases. Where there is a requirement to carry a collecting container made of plastics you may carry heavy duty plastic bags, a plastic drum or bucket etc. Any suitable plastics container may be used that is capable of carrying and retaining unused or used absorbent material (sand, earth, absorbent pads or granules). If it is the intention of an operator to remove contaminated absorbent or leaked dangerous goods in the event of a minor incident the operator must carry out a risk assessment and provide adequate instruction and training to the driver. This would cover the type of container e.g. size, sealable, rigid, flexible etc, and how it is transported.