A majority of my company’s business involves tankers travelling from the UK to Spain and back to the UK. One of the clients that we regularly deliver to in the UK is from Spain, and has offered us some work from their location in Spain to another location in the UK. It is a compatible product that has the same HIN (Hazard Identification Number) and UN Number, so we don’t need to wash the tank out.
The issue that I have is how we mark up the tank. When it will arrive on site from Spain, it will be marked up for ADR rather than UK rules. Would it be acceptable for the tank to remain marked up for ADR? As far as I am aware the only difference between the two is the HIN.
As the load from Spain to the UK involves two member states, this will be subject to ADR. As such, as you have quite rightly pointed out, this should be marked according to ADR. However, once this consignment has been offloaded, unless you were going to wash out the tank, that consignment has been completed. When you load the substance that is going to be delivered within the UK, this begins a new consignment.
As this new consignment does not involve any other member state of ADR, it will be subject to the CDG rules, which you have termed as the UK rules in your question.
A relevant part of the CDG regulations (Schedule 1, Part 1, 1) states that the Emergency Action Code must be displayed instead of the HIN, therefore, you must not use your existing ADR markings, you must change to the CDG requirements for this load.
As well as the HIN, there are a number of other differences between the two sets of regulations. For example, CDG will require you to display a telephone number, in the immediate vicinity of the emergency action codes on the tank, where specialist advice can be obtained in English at any time during carriage.
You may also notice a difference in the size of the placards. ADR requires them to have a minimum dimension of 250mm x 250mm, whereas CDG requires them to be at least 200mm x 200mm. So, your ADR ones will be acceptable for the CDG journey.