Transporting fuel as parcelled goods

Only IBC packagings or tank containers approved in accordance with the transport regulations pertaining to the transport of dangerous goods or actual tanks meant for the transport of dangerous goods may be used for transporting fuels by road. For the transport of smaller quantities of fuel, different packagings from canisters to IBC packagings may be used depending on the quantity.

IBC packaging approved for transport by road

IBC packaging, IBC or Intermediate Bulk Container refers to a transportable packaging, which may have the appearance of a tank but which is classified as parcelled goods for transport purposes. The IBC requirements differ from the requirements pertaining to tanks, both in terms of structure, approval and usage. In the case of fuel, the maximum IBC volume is 3,000 litres.

For transporting fuels, such as fuel oil, diesel or petrol, the IBC must be approved in accordance with the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road. There must always be a sign indicating the approval on the side of the container.

Limited quantity (LQ) exemption

So-called limited quantity exemptions relate to shipments where the quantity of the transported dangerous goods is below the limit indicated in the so-called LQ exemption table in Appendix A, section 1.1.3.6, of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road. The table is not applicable to mixed loads, where the LQ exemption level must be calculated. In the transport of dangerous goods, LQ exemptions are specific to each transported good. In other words, there is no universal limited quantity exemption for all goods. Instead, the transported good must be known in order to determine the quantity limit.

When you are transporting a dangerous good within the limits of the LQ exemption, some of the TDG regulations do not apply. The driver is not required to have an ADR licence. However, so-called awareness training is mandatory. The transport unit must be equipped with a 2-kg extinguisher and the waybill, for example.

If you are transporting fuel in an IBC, it is always a case of transporting parcelled goods, which means that the driver is not required to possess an ADR licence. The vehicle marking is not required in the case of LQ exemption shipments.

If you are transporting fuel in an IBC and the quantity exceeds the LQ exemption limit, the driver is required to have the basic ADR licence for the transport of parcelled goods. In this case, the vehicle transporting IBC packagings must be equipped with a blank orange sign at the front and back.

LQ exemption limits for dangerous goods

If you are using the transport unit to transport dangerous goods belonging to the same transport category, you can view the maximum allowed total quantity per transport unit in the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road, Appendix, section 1.1.3.6.3. For example, according to the LQ exemption table, the LQ limit for diesel, UN 1202, is 1,000 litres. For petrol, UN 1203, the corresponding limit is 333 litres. When transporting goods belonging to different transport categories, you will need to find out the calculated LQ exemption limit. See the example below.

Examples of applying the LQ exemption limits to the transport of fuels

Below are examples of transporting fuels as parcelled goods. Although the examples do not provide a comprehensive guide to transport, they do illustrate the effect of the transported quantity on the requirements.

Transporting diesel or fuel oil

0–1,000 litres:

  • So-called LQ exemption
  • UN-certified packaging or IBC packaging required
  • The fuel tank of the vehicle or work machine is not included in the quantity
  • The driver is not required to have an ADR licence; awareness training must be completed
  • The vehicle does not need to be marked
  • The packaging must be marked with ‘UN’ and the UN number of the good (UN 1202) as well as the warning labels applicable to the transport class
  • Waybill and a 2-kg extinguisher are required
  • The IBC packaging must be subject to a periodic inspection every 2.5 and 5 years by a TDG inspection body or a periodic TDG inspection body

1,000–3,000 litres:

  • UN-certified IBC packaging required
  • Parcelled goods transport, i.e. the driver is required to have a basic ADR licence
  • A blank orange sign at the front and back of the vehicle
  • The IBC packaging must be marked with ‘UN’ and the UN number of the good (UN 1202) as well as the warning labels applicable to the transport class
  • All of the required equipment of the vehicle must be present, including the waybill, safety instruction card and extinguisher.
  • The IBC packaging must be subject to a periodic inspection every 2.5 and 5 years by a TDG inspection body or a periodic TDG inspection body

Transporting petrol

0–333 litres:

  • So-called LQ exemption
  • UN-certified packaging required
  • The fuel tank of the vehicle or work machine is not included in the quantity
  • The driver is not required to have an ADR licence; awareness training must be completed
  • The vehicle does not need to be marked
  • The packaging must be marked with ‘UN’ and the UN number of the good (UN 1203) as well as the warning labels applicable to the transport class
  • Waybill and a 2-kg extinguisher are required
  • The IBC packaging must be subject to a periodic inspection every 2.5 and 5 years by a TDG inspection body or a periodic TDG inspection body

333–3,000 litres:

  • UN-certified IBC packaging required
  • Parcelled goods transport, i.e. the driver is required to have a basic ADR licence
  • A blank orange sign at the front and back of the vehicle
  • The IBC packaging must be marked with ‘UN’ and the UN number of the good (UN 1203) as well as the warning labels applicable to the transport class
  • All of the required equipment of the vehicle must be present, including the waybill, safety instruction card and extinguisher.
  • The IBC packaging must be subject to a periodic inspection every 2.5 and 5 years by a TDG inspection body or a periodic TDG inspection body

When transporting diesel and petrol in the same load

If you are transporting dangerous goods belonging to several transport categories, such as diesel and petrol, in the same transport unit, the LQ exemption limit is the calculated value. The calculated value of “1,000” may not be exceeded. The value is calculated in the following way:

Transport category Multiplier
Transport category 1 goods, items and equipment 50

Section 1.1.3.6.3 LQ exemption table, footnote
a) goods, items and equipment

 20
Transport category 2 goods, items and equipment 3
Transport category 3 goods, items and equipment 1

 

Example of calculating the LQ exemption limit for a mixed load

The LQ exemption limit for diesel (UN1202) is 1,000 litres when present alone in the load. For petrol (UN 1203), the corresponding limit is 333 litres. However, if both a present in the load, the calculated value must be used.

Below is an example calculation of a combo load comprising:

  • 200 L of diesel (UN 1202)
  • 300 L of petrol (UN 1203)

Multipliers

  • The diesel transport category is 3 -> multiplier of 1
  • The petrol transport category is 2 -> multiplier of 3

Calculated value

  • 200 x 1 + 300 x 3 = 1100

→ The calculated value of the load is greater than “1,000”, which means that the load exceeds the LQ exemption limit even though the quantity is only 500 litres. In other words, the quantity limits in the LQ exemption table do not apply to loads comprising several different goods; for such loads, the LQ exemption limit is calculated.