Is this checklist mandatory?

A checklist as a document is not explicitly required by Regulation (EU) 2025/2365 — what is required is the implementation of procedures. In practice, every carrier creates its own checklist as a tool for implementing those procedures. An OCS Europe audit verifies whether such a list exists, whether drivers actually complete it, and whether the records are archived.

When do the full PPLP requirements apply to drivers?

Selected provisions apply from 16 December 2025; most of them (including the full transport procedures) apply 2 years after entry into force, i.e. ~December 2027. Nevertheless, granule shippers are already starting to require documented PPLP procedures in transport orders from 2026 — in practice, market expectations run ahead of the formal application date.

What must a silo trailer driver have on board?

Mandatory equipment under the PPLP: a shovel and broom for collecting pellets, collection bags (typically 25-50 L) for recovered pellets, a funnel for transferring them, adhesive strips for minor spills, gloves. Plus basic operational equipment: caps for the discharge valve, a spare manhole bolt, and the material SDS documents if ADR applies.

What should the driver do if pellets spill en route?

Procedure: (1) stop the silo trailer in a safe place (car park, rest area); (2) locate the source of the leak (typically a leaking valve, manhole or pipe connection); (3) if the leak is minor — collect the pellets with the on-board equipment and seal the source temporarily; (4) if the leak is major — call the dispatcher and request assistance; (5) report the incident to the dispatcher immediately — a PPLP requirement; (6) once the situation is under control — update the incident log.

Is smoking in the loading yard a problem?

Yes. Plastic pellets are flammable — smoking is strictly prohibited near the silo trailer during loading/unloading and within at least 3 m of any spilled pellets. Standard chemical-plant yard safety rules also apply. In practice: cigarettes strictly outside the operational area.

How long does the complete checklist take?

With an experienced driver and a repeatable procedure: 5-8 minutes at loading, 3-5 minutes en route (check at an intermediate point), 5-8 minutes at unloading, 3-5 minutes after the cycle (updating the log). In total ~15-20 minutes per full cycle. Additional time compared with the traditional procedure: ~5-10 minutes — a small burden compared with the consequences of neglect.

What happens to the collected pellets?

Collected pellets do not go back into the silo trailer (contamination risk). They are labelled as 'recovered pellets' and handed over for disposal (sorted for recycling if clean, disposed of as waste if contaminated). The carrier documents the quantity of recovered pellets in the incident log. The shipper may require their return and separate weighing (rarely practised, but permissible).

regulations operations 16.01.2026 PHS Magnum

Silo Trailer Driver Checklist – Pellet Loss Prevention

Loading a silo trailer with granules — PPLP-compliant procedures, PHS Magnum

Key takeaways

A practical checklist for the driver of a silo trailer transporting plastic granules (PE, PP, PET, ABS, R-PET, R-HDPE etc.) in line with Regulation (EU) 2025/2365 on preventing plastic pellet loss. The list covers the full cycle: before leaving the depot, during loading, en route, at unloading, and after the cycle. Time required: ~15-20 minutes for a full cycle. On-board equipment: shovel, bags, funnel, adhesive strips, gloves. Documentation: cycle log, incident report (if a spill occurs).

On-board equipment — this must be on every silo trailer

The PPLP obliges the carrier to have equipment for containing and cleaning up spills. The minimum:

Shovel — preferably a large metal or plastic one, for collecting spills from hard surfaces
Broom — with stiff bristles (for sweeping up pellets; not straw — it scatters pellets)
Collection bags — 25-50 L, typically 5-10 on board, labelled “recovered pellets — for disposal”
Funnel — for transferring collected pellets from the shovel/sweepings into the bag
Adhesive strips — for minor spills on uneven surfaces (e.g. asphalt, kerbs)
Work gloves — one pair on board
Bucket-type container — optional, for collecting in wet conditions

The whole kit fits in the silo trailer’s side box. Check it weekly or after every use — replace worn items, restock any shortages.

Checklist — before leaving the depot

#	Task	OK
1	Check the condition of the on-board equipment (kit complete)	[ ]
2	Check the tightness of the discharge valves (caps tightened)	[ ]
3	Check the manhole seals (visually: no cracks, elasticity retained)	[ ]
4	Check the aeration pad seals (visual inspection)	[ ]
5	Document check: CMR, material SDS (if ADR), cycle log	[ ]
6	Check the pneumatic system pressure (auxiliary supply)	[ ]
7	Cleanliness certificate for the chamber from the previous cycle — signed	[ ]

Every “yes” → next step. A “no” at any point = report to the dispatcher, repair or swap the silo trailer.

Checklist — during loading at the shipper

#	Task	OK
1	Report to the loading operator — present the cleanliness certificate	[ ]
2	Check the loading pipe connection (clamp, gasket)	[ ]
3	Monitor the area under the silo trailer during loading (any dripping?)	[ ]
4	Check valve tightness after loading	[ ]
5	Visual check of the area after disconnecting the pipe — pellets on the ground?	[ ]
6	If pellets are on the ground → collect them before departing	[ ]
7	Sign the CMR with a photograph of the cargo (e-CMR)	[ ]
8	Collect the material certificate (batch number, density, food-grade if applicable)	[ ]

Checklist — en route

Checkpoint every 200-300 km or after every break:

#	Task	OK
1	Visual check of the silo trailer from outside — no spills	[ ]
2	Check the discharge valves — no play, no leakage	[ ]
3	Check flange connections (if visible)	[ ]
4	Check aeration pads (if visually accessible)	[ ]
5	Check the parking area on departure — no pellets left behind	[ ]

If a spill is detected → response procedure (section below).

Checklist — at unloading at the consignee

#	Task	OK
1	Report to the unloading operator, agree the procedure	[ ]
2	Check the unloading pipe connection	[ ]
3	Open the valve in the presence of the consignee’s operator	[ ]
4	Monitor the pneumatic system operation (pressure, flow)	[ ]
5	Monitor the area under the silo trailer during unloading	[ ]
6	After emptying — check that nothing remains in the chamber	[ ]
7	Close the valves, stow the pipe	[ ]
8	Visual check of the area after disconnecting the pipe	[ ]
9	Collect any spilled pellets (if present)	[ ]
10	Have the consignee sign the CMR, make an entry in the cycle log	[ ]

Checklist — after the cycle (before the next load)

#	Task	OK
1	Entry in the cycle log (date, material, loading/unloading location, signature)	[ ]
2	Blow out the chamber with dry compressed air (if changing material)	[ ]
3	Wet washing (only if changing category — e.g. food → non-food)	[ ]
4	Visual check of the chamber at the manhole	[ ]
5	Issue a cleanliness certificate for the next cycle	[ ]
6	Incident report (if spills occurred) to the dispatcher	[ ]
7	Restock the on-board equipment (bags, strips, gloves)	[ ]

Pellet spill response procedure

Step 1: stop Stop the silo trailer in a safe place. Do not continue driving — pellets on the outside may keep spilling.

Step 2: locate the source Check the typical leak points:

Discharge valves (loose, damaged gasket)
Manhole (loose bolts, cracked gasket)
Flange connections (cracks, corrosion)
Aeration pads (cracked)

Step 3: temporary sealing If the leak is a loose valve or bolts — tighten them. If a gasket is cracked — wrap it with sealing tape or replace it with a spare (if carried on board).

Step 4: collect the spilled pellets Use the on-board equipment. Collected pellets → the bag labelled “recovered pellets — for disposal”.

Step 5: contact the dispatcher Report the incident immediately. The dispatcher decides whether to:

Continue the route (minor incident, effective repair)
Call for assistance (larger incident requiring a mobile workshop)
Order mobile truck service en route (larger repair)

Step 6: documentation Once the situation is under control:

Entry in the incident log (date, place, description, actions, quantity of recovered pellets)
Photograph of the leak source
Photograph of the site after clean-up
E-mail report to the safety coordinator at the depot

Step 7: after returning to the depot

Silo trailer service — repair of the leak source
Incident analysis — did the procedure work, are corrections needed
Recovered pellets — disposal according to procedure (recycling if clean, waste if contaminated)

Most common mistakes

No check between cycles — the driver takes the next load without checking chamber cleanliness. Consequence: batch contamination, rejection at the consignee, a cost running into tens of thousands of euros per batch.

Skipping the cleanliness certificate — the carrier fails to issue the document, the shipper protests. Consequence: lost orders, damaged reputation.

Missing on-board equipment — the driver travels without a shovel/bags. Consequence: non-compliance with the PPLP, no spill response capability, administrative penalties from ~2027.

Not reporting spills — the driver cleans up and does not report. Consequence: no data for systemic analysis, repeat incidents from the same cause.

EU 2025/2365 — Pellet Loss Prevention. What the regulation changes for granule shippers
Operation Clean Sweep (OCS) — certification of a silo trailer carrier
Silo trailer cleaning — procedure
Silo trailer breakdown en route — what to do

About the author

This content was prepared by the PHS Magnum team in cooperation with Aleksy Pasternak — the company’s Managing Partner and an expert in bulk material transport with 35 years of experience in trading plastic granules, recyclates and industrial minerals across the EU. Aleksy publishes industry analyses on the expert portal pasternak.me, where you will find further studies on regulatory topics (PPLP, PPWR, OCS), technical topics (silo trailers, TDT) and operational topics (big-bag transloading, contract packing).