Propionic Acid

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I don't know if this should be in here or the tillage section, but it's a two part question so we'll chance it here.
Firstly, I've been led to believe that if you want to transport ANY amount of propionic acid by road then you now need a hazchem license. Is this true, or is there a minimum or maximum quantity you can legally transport without said qualification.
Secondly, what exactly is involved in obtaining a hazchem license, what are the costs involved and what are the insurance implications etc.
Cheers.
 
I don't know if this should be in here or the tillage section, but it's a two part question so we'll chance it here.
Firstly, I've been led to believe that if you want to transport ANY amount of propionic acid by road then you now need a hazchem license. Is this true, or is there a minimum or maximum quantity you can legally transport without said qualification.
Secondly, what exactly is involved in obtaining a hazchem license, what are the costs involved and what are the insurance implications etc.
Cheers.
Just get your supplier to drop it with you
 
From limited knowledge of transport regulations, Under the ADR Propionic Acid is classified as full haz, class 3 (8) - Flammable & Corrosive. Thus requiring full haz license for any transport. Cost for a haz license is high esp if only going to be transporting small volumes of the product in question.
 
Transport by tractor shouldn't need a hazchem as far as I know farmers have a derogation.
This is the UK site but should be similar
http://www.hse.gov.uk/cdg/manual/exemptions.htm

That's interesting, I must make enquiries in that regard.

Either:rolleyes2:

The situation is thus. I roll and treat grain on hire, the acid usually comes from a local supplier from whom my customers collect the acid themselves. The usual craic is they go and pick up an IBC which is weighed when they collect it, they bring it back when he's finished, weighed again, pays for what he uses. There was no enforced restriction on the transport of the acid until an "incident" in a different part of the country last year in which a jeep and trailer carrying an IBC crashed and the entire emergency response capabilities of the state descended on the scene. The powers that be then decided you could not transport any amount of said acid without said license. My usual supplier decided it was no longer worth the hassle and switched to 2 alternative treatments instead, both consisting mostly of propionic acid but diluted with citric acid and other substances to circumvent the regulations. Unfortunately the effectiveness of these alternative acids also seems to be diluted. I was therefore wondering what exactly is involved in transporting propionic if I were to seek an alternative supply, or perhaps supply it myself.
 
That's interesting, I must make enquiries in that regard.



The situation is thus. I roll and treat grain on hire, the acid usually comes from a local supplier from whom my customers collect the acid themselves. The usual craic is they go and pick up an IBC which is weighed when they collect it, they bring it back when he's finished, weighed again, pays for what he uses. There was no enforced restriction on the transport of the acid until an "incident" in a different part of the country last year in which a jeep and trailer carrying an IBC crashed and the entire emergency response capabilities of the state descended on the scene. The powers that be then decided you could not transport any amount of said acid without said license. My usual supplier decided it was no longer worth the hassle and switched to 2 alternative treatments instead, both consisting mostly of propionic acid but diluted with citric acid and other substances to circumvent the regulations. Unfortunately the effectiveness of these alternative acids also seems to be diluted. I was therefore wondering what exactly is involved in transporting propionic if I were to seek an alternative supply, or perhaps supply it myself.

I think I know the incident you are on about. It could have been a lot worse.
To make if easier get it dropped off by a licenced haz-chem operator especially if you are dealing with IBC's. You may have an exception if you only transport 5-10 litres at a time, definitely not for IBC's.
 
I think I know the incident you are on about. It could have been a lot worse.
To make if easier get it dropped off by a licenced haz-chem operator especially if you are dealing with IBC's. You may have an exception if you only transport 5-10 litres at a time, definitely not for IBC's.

5-10 litres at a time is a waste of time, you'd be putting it on at a rate of 8-10 litres to the tonne. Where would a lad go to get that kind of information as easily as possible?
 
A good friend of mine got the haz cem licence himself about 7 or 8 years ago as far as i can remember €1500 was mentioned. He was saying at the time it put an awful lot more responsibility on the licence holder, even more than on the employer.
 
5-10 litres at a time is a waste of time, you'd be putting it on at a rate of 8-10 litres to the tonne. Where would a lad go to get that kind of information as easily as possible?
I don't have the ADR regulations to hand but I can have a look in the morning at work to see what the restrictions on it are. We have them on hand as a lot of the material we handle and product falls under ADR, IMDG & IATA Transport regulations.
To tell you how bad things are regulations wise are. we wanted to ship 1 box 30 pouches of cleaning degreaser wipes (30 wipes per pouch) to Canada. Up to last year the chemicals involved were non-haz. This year they are now fully haz even at a reduced dosing level. It cost €460 euros in transport fee, there was 20 A4 pages of different paper work attached to the box for a product that would normally sell for €35 for 1 box. Mad.
 
I don't have the ADR regulations to hand but I can have a look in the morning at work to see what the restrictions on it are. We have them on hand as a lot of the material we handle and product falls under ADR, IMDG & IATA Transport regulations.
To tell you how bad things are regulations wise are. we wanted to ship 1 box 30 pouches of cleaning degreaser wipes (30 wipes per pouch) to Canada. Up to last year the chemicals involved were non-haz. This year they are now fully haz even at a reduced dosing level. It cost €460 euros in transport fee, there was 20 A4 pages of different paper work attached to the box for a product that would normally sell for €35 for 1 box. Mad.

If you got a chance to have a quick look whenever you get a chance I'd appreciate it :Thumbp2:
 
Looked at the HSA Hazchem guide, all it states is farmers have an exemption for "carriage of farm supplies by the farmer"
Sometimes that could also mean Agri contractors but I didn't see the law, you would need to get it confirmed.
 
You wouldnt get that carry on over here
Each farm would buy his own 40g barrel
Some contractors would supply here too. We buy our own though.
Good mate of mine goes out crushing, he discovered that the firm supplying him 'directly' was actually dearer than the local feed merchants place! For the same stuff! Told them to shove it!
 
@max reading this strikes me that you should have good knowledge on this?

You can drop mine at the back door!


I hadn't looked in here until you tagged me. It's four years since I did my last haz refresher but il take a read of the thread later and look it up, and sure of course il drop it up.
 
The basic ADR course covering packaged chemicals, eg IBCs is 3 days long and an extra 2 days to cover tankers.
 
To answer a few of the above quickly while on a coffee break
When I did my adr I paid €350 for the 3 day packages and €200 on top of that for tankers. I'd give a rough price now of €750 for the five days training. Two exams need to be sat more than a fortnight but less than 6 months later at a cost of either €125 or €150 per exam 4 years ago. Said exams are are held fortnightly in Dublin, monthly in galway and I'm not sure about cork. To carry ibcs you will get away with the packages licence even if you carry a full load of them so only one exam.

As above farm products might be exempt but tractors per say are not as I know drivers pulling diesel tanks on new road projects needed the adr, although maybe that was more hsa than adr rules but I don't know.
If transporting dangerous goods by road you need to involve a dgsa (dangerous goods safety advisor) man/woman who will, for a fee of course, provide you with safety statements and carry out site visits and inform you of all new legalisation etc.

If your looking for solid information your best bet is to contact a dgsa registered person and they will provide you with all you need.
 
I sent the HSA an email asking for direction on this issue, and I got a reply today

Dear Mr. Byrne

I hereby acknowledge receipt of your query which has been recorded and assigned the Request for Information Reference No: xxxxxxx

If you would like to enquire regarding the status of your query, please telephone 1890 289 389, email wcu@hsa.ie or write to the WCU Office at The Metropolitan Building, James Joyce Street, Dublin 1.


Please ensure you have your Reference Number available or quote it in any correspondence to assist the Workplace Contact Unit staff to deal with your request efficiently.

Yours sincerely,

The big wheels of officialdom turn very slowly.......
 
Shirley it should be the RSA you should be enquiring off as regards transporting acid . I sent in a request to them on Feb 1 for the trailer booklets and they did not arrive yet .
 
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