Introduction to the carriage of dangerous goods
Carrying goods by road or rail involves the risk of traffic accidents. If the goods carried are dangerous, there is also the risk of an incident, such as spillage of the goods, leading to hazards such as fire, explosion, chemical burn or environmental damage.
Most goods are not considered sufficiently dangerous to require special precautions during carriage. Some goods, however, have properties which mean they are potentially dangerous if carried.
Dangerous goods are liquid or solid substances and articles containing them, that have been tested and assessed against internationally-agreed criteria - a process called classification - and found to be potentially dangerous (hazardous) when carried. Dangerous goods are assigned to different Classes depending on their predominant hazard.
There are regulations to deal with the carriage of dangerous goods, the purpose of which is to protect everyone either directly involved (such as consignors or carriers), or who might become involved (such as members of the emergency services and public). Regulations place duties upon everyone involved in the carriage of dangerous goods, to ensure that they know what they have to do to minimise the risk of incidents and guarantee an effective response.
Carriage of dangerous goods by road or rail is regulated internationally by agreements and European Directives, with biennial updates of the Directives take account of technological advances. New safety requirements are implemented by Member States via domestic regulations which - for GB - directly reference the technical agreements.
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG Regs) and the European agreement (“Accord européen relatif au transport international des marchandises dangereuses par route”, known as ADR) which together regulate the carriage of dangerous goods by road are highly prescriptive. The GB regulations were substantially restructured for 2009 with direct referencing to ADR for the main duties. Amending regulations were made in 2011, mainly to reflect changes to the EU Transportable Pressure Equipment Directive. This guidance does not cover carriage of radioactive substances.
Northern Ireland has equivalent regulations so much of this manual is also applicable there. Please note that although HSENI has been consulted, this guidance has been prepared by HSE for use in Great Britain.
This guidance is intended for enforcement officers, but may be helpful to others. It will guide them through the process and help them to make informed judgements about the extent of compliance. It will also guide officers when discussing compliance with duty holders and deciding when to take further action. The reader should remember that the law can only be interpreted by the Courts.
CDG Regs now cross-refer almost totally to ADR, and it is ADR that contains the detailed requirements. The regulations do allow certain exemptions that arise from the way the EU Dangerous Goods Directive is worded, and the UK has a number of derogations from that directive. These are discussed in “main exemptions”.
ADR includes security requirements. This guidance does not deal with these matters as enforcement is carried out by the Department for Transport.
The aim of regulations dealing with the carriage of dangerous goods is to protect both the carriers of the goods, the emergency services and the wider general public. Regulations place duties upon everyone involved in the carriage of dangerous goods, to ensure that they know what they have to do to minimise risks.
Structure of this guidance
ADR is highly structured and prescriptive. It follows that if care and time are taken, the answer to most problems can be found, and for that reason there is little or no need for extensive explanatory literature or guidance.
Many duty holders will need to appoint a “Dangerous Goods Safety Adviser” and thus should have access to the specialist knowledge needed to navigate the regulations and ADR.
Some background to CDG Regs is given in Regulatory Environment. The chapter Operational Strategy " Enforcement sets out HSE’s operational strategy with some enforcement guidance. ADR, CDG Regs and Dangerous Goods Safety Adviser describes the relationship between the regulations and ADR. Subsequent chapters largely follow the structure of ADR. Each chapter is set out as follows:
- Reference to the relevant regulation.
- Guidance on the requirements of ADR itself.
- Any special considerations, such as exemptions (which are also discussed more fully at Main Exemptions)
This guidance does not repeat the requirements of CDG Regs or ADR, but directs the reader to the parts of the regulations and ADR that will be of relevance. It is intended to provide a basis for a consistent approach across the three agencies that are involved in enforcement.
The guidance is structured in line with ADR, that is, it follows the logical chain of duties from classification of substances through to carriage.
There is a specific chapter about clinical waste as this has proved to be one of the main problem areas for both dutyholders and enforcement officers.
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG Regs) set the legal framework in GB, as ADR itself has no provision for enforcement. The regulations include a number of exemptions and make substantial changes to the ADR requirements for the domestic carriage of many explosives.
Dangerous goods safety adviser (DGSA)
Every Operator involved in the carriage, package, loading, filling or unloading of dangerous goods by road requires a DGSA.
ADR requires many of those involved in carriage of dangerous goods to appoint a DGSA.
It applies to carriers, packers, fillers, loaders and unloaders, subject to some exemptions discussed below. The exemptions arise from ADR 220.127.116.11 and have been implemented by CDG Regulation 3 (j). The GB exemptions do not apply to international carriage. The two exemptions are alternatives.
DfT guidance is that “final unloaders” (consignees) will not need to appoint a DGSA. Intermediate unloaders (such as freight forwarders and consolidators and operators of “in-transit” storage facilities) will need to have a DGSA.
To become a DGSA a person needs to have passed the necessary examinations to gain DGSA VTC. These qualifications are valid for 5 years from the date of issue and candidates are required to retake and pass the full DGSA examination to extend their qualification for a further five years.
Where the main or secondary activity of the duty holder is not the carriage of dangerous goods or (related activities). Various questions of interpretation arise in connection with this exemption. "Main or secondary activity" should be interpreted as the main or secondary purpose of the business. Thus companies whose business is not the transport of dangerous goods per se but whose activities involve such transport will normally not require to appoint a DGSA. Examples include
- Construction companies taking dangerous goods to and from sites would not be regarded as having transport of dangerous goods as either a main or secondary activity
- Repair organisations that occasionally recover vehicles which are still loaded with dangerous goods. For routine services, it would be expected that the vehicles would be unloaded and where applicable cleaned and purged.
Carriers (in this context synonymous with vehicle operators) delivery companies, freight forwarders etc are not within this category as carriage of dangerous goods is often their main or secondary activity.
This exemption is further qualified. The terms "occasionally engage" and "little danger or risk of pollution" pose practical difficulties of interpretation. In so far as the limited quantities exemptions apply a risk assessment approach, it could be argued that carriage above those thresholds cannot qualify. The regulation clearly envisages that there will be such cases and the following examples may help in making the judgment.
- transport of dangerous goods in transport category 4
- transport of dangerous goods in transport Category 3 but only in packages (not tanks/bulk) where the volume/mass of the load concerned does not exceed 1500 litres or kg. Goods in transport categories 0, 1 and 2 should not be treated in this way.
- transport of explosives in loads of up to 10% above the thresholds at which placarding requirements apply.
- "occasionally" should be interpreted as 1 to 2 journeys per month. If more frequent deliveries (e.g. by a contractor to a site) are required this should not be regarded as occasional. Other exemptions may allow a duty holder not to appoint a DGSA.
ADR works in such a way that classification is the precursor for everything that follows. Once a substance or article has been properly classified, table A allows every other requirement to be ascertained by working logically through the columns.
The rules for classification are in ADR at part 2. Dangerous substances (and this includes articles) are very widely defined, but some, for example most medicines and cosmetics, do not have the hazardous properties that would bring them within scope of the requirements, and those that do are usually carried in very small receptacles, allowing at least partial exemption from the requirements (either limited quantities or limited loads)
Consignors have a duty to identify the hazards of the goods they intend to transport. There are nine classes, some with divisions, as follows.
|UN Class||Dangerous Goods||Division(s)||Classification|
|1||Explosives||1.1 - 1.6||Explosive|
|2.2||Non-flammable, non-toxic gas|
|3||Flammable liquid||Flammable liquid|
|4||Flammable solids||4.1||Flammable solid|
|4.2||Spontaneously combustible substance|
|4.3||Substance which in contact with water emits flammable gas|
|5||Oxidising substances||5.1||Oxidising substance|
|6||Toxic substances||6.1||Toxic substance|
|7||Radioactive material||Radioactive material|
|8||Corrosive substances||Corrosive substance|
|9||Miscellaneous dangerous goods||Miscellaneous dangerous goods|
Part 2 of ADR works through the categories in logical sequence. It sets out descriptions and criteria in some detail. The consignor must assign a "proper shipping name" and UN Number to the substance.
All relevant hazards have to be determined. There is a hierarchy of classification and there are rules about choosing the most appropriate entry and hence UN number.
Many substances and generic groups (e.g. paints) have already been classified, so in many cases a consignor may only need to find his substance in the "dangerous goods list", which is in part 3 of ADR. The lists are by UN Number (Table A) and alphabetical (Table B) . Both lists are at the end of Volume 1 of ADR.
Many preparations (i.e. mixtures of substances) will not be found in table A of ADR. In those cases the rules for classification need to be followed.
An important change was made in ADR 2011 in paragraph 18.104.22.168. The effect of this is that dangerous goods should be classified and named according to the properties of the predominant substance, and in general the presence of impurities is not relevant.
Once a UN number and proper shipping name have been assigned, table A allows all the relevant parts of ADR to be accessed. Some substances with the same name will have different degrees of danger (for example flash point). This is reflected in the “packing group” (PG), which is found in column 4 of table A. The head of column 4 in turn directs you to the relevant part of ADR. Where a substance has been classified from “first principles”, its PG will be determined by its properties (for example ADR 22.214.171.124.3 shows how flammable liquids are assigned a PG)
Some substances are not assigned a PG (notably gases and explosives), but they do have a transport category, the relevance of which will be discussed elsewhere in relation to limited load exemptions. In certain special circumstances it may not be practicable to classify the goods fully before carriage, for example when sending samples for analysis. In such cases it is acceptable to "over-classify" the goods on the basis of the information which is already available.
Proper shipping names may also be qualified by the addition of the terms such as 'SOLUTION'; 'LIQUID'; 'SOLID'; 'MOLTEN', 'STABILIZED'.
ADR has changed in respect of classification for environmental hazards. There are links to the “supply” classifications implemented in GB by the CHIP regulations and to the GHS system of classification. This means that all dangerous goods, not just those directly assigned UN 3077 (solids) or UN 3082 (liquids), meeting the relevant criteria will be regarded as environmentally hazardous substances and required to show the “dead fish and tree” mark. The requirements for the mark mirror the provisions for labels and placards.
With the exception of clinical waste, wastes are classified in the same way as other substances. The rules at ADR 126.96.36.199 mean that where generic or “NOS” names are chosen, the substance or substances giving rise to the hazards may have to be named. See Special Provision 274 where it appears in column 6 of Table A. The word “WASTE” should qualify other descriptions where applicable, and should appear before the “Proper Shipping Name”.
Vehicles and Drivers
All containers, tanks and vehicles must be suitable for the journey to be undertaken and the hazardous properties of the goods to be carried.
Vehicle tanks and tank containers must:
- Be of certified design confirming with construction and equipment requirements;
- Be suitable for the purpose;
- Have been examined and tested and been issued a signed certificate to this effect by the competent authority.
Drivers must not:
- Carry passengers on vehicles carrying dangerous goods;
- Open any packages containing dangerous goods unless authorised to do so;
- Carry matches (or lights) on vehicles carrying explosives, inflammable liquids or flammable gases.
Carriage, loading, unloading and handling
This comparatively short part of ADR (part 7) covers the transport chain from loading the vehicle to unloading it.
It includes references to particular provisions for the three basic modes (packages, bulk and tanks)
There are some very basic requirements in part 1.4 of ADR. In particular, 188.8.131.52 concerns immediate risk to public safety. Paragraph 184.108.40.206.4 requires the journey to be stopped if there is an infringement which could jeopardise the safety of the operation.
Equipment required on an ADR vehicle
Every vehicle transporting dangerous goods subject to the Regulations should be equipped with the following items:
1. Wheel chock;
2. Two self standing warning signs;
3. Suitable warning vest for each member of crew;
4. Pocket lamp for each member of crew;
5. Pair of protective gloves for each member of crew;
6. Eye protection for each member of crew;
7. Fire extinguishers;
8. Respiratory protect device.
Regulation 5 is the basis for implementing ADR, where the key obligations are set out in 1.4
The relevant part of ADR is part 7. For the most part this is straightforward. The following should help to navigate the main requirements
Chapter 7.2 contains the special provisions in relation to packages which are set out in column 16 of table A. These are all prefixed "V"
Chapter 7.3 contains the special provisions in relation to carriage in bulk which are set out in column 17 of table A. These are all prefixed "VV"
Chapter 7.4 contains the special provisions in relation to carriage in tanks which can only be done if allowed by reference in columns 10 or 12 of table A. It is possible for a competent authority to grant approval for exception to this rule. The designation codes for vehicle types are also set out (see column 14 of table A)
Chapter 7.5 sets out
- at 7.5.2 the rules on mixed loading (not to be confused with "mixed packing" – see ADR at 4.1.10). There is special detail for explosives. The matrix enables one to see where mixed loading is prohibited, allowed without qualification or allowed under certain circumstances. Note that where there are prohibitions, these apply to loading within the same vehicle or container. For example the towing unit and trailer of a draw bar combination are separate vehicles.
- at 7.5.4 some rules about precautions with respect to foodstuffs etc.
- at 7.5.4 some rules about quantity limitations (mainly explosives and organic peroxides)
- at 7.5.7 are the rules about handling and stowage. The most obvious is that relating to proper loading (stowing) and securing of the load to prevent accidents arising from the load shifting. This sets a high standard and supplements the more general laws concerning load safety on goods vehicles.
- 7.5.8 requires the carrier to clean the vehicle if packaged loads have leaked
- 7.5.9 prohibits smoking during handling operations in or around vehicles
- 7.5.10 requires precautions against electrostatic discharges when carrying substances with flash point 61° C or lower.
- 7.5.11 Special provisions "CV" where specified in column 18 of table A. Some of these are very detailed and specific to particular substances or groups of substances.
Crew and vehicle
Part 8 of ADR covers most of the matters that the carrier has to deal with, and includes
- Driver training
- Equipment to be carried, including fire extinguishers, wheel chocks, pocket lamp, warning signs, warning vest
Regulation 5 is the basis for implementing ADR's requirements in this matter. Regulation 6 requires GB vehicles on national journeys to use Emergency action codes rather than Hazard Identification numbers when carrying in tanks or bulk. For tank carriage there is also the requirement to display a telephone number. Details are in Sch 1 of CDG Regs.
The relevant part of ADR is part 8. In principle, this is not complicated, but there are some intricacies which this manual discusses. Virtually all of the carrier's duties are set out in this part of ADR.
Some duties refer to "transport unit" and some to vehicles. The transport unit may be one vehicle or may comprise a tractor unit and semi- trailer (articulated lorry) or a rigid lorry and trailer (drawbar combination). A vehicle most obviously is a lorry or van but it also includes a trailer. Accordingly, an articulated lorry or drawbar combination is two vehicles, but one transport unit. Vehicle is defined in Article 1 and in part 9 of ADR
Equipment and documentation
ADR chapter 8.1 covers equipment and documentation. This is grouped in three main parts
- Documents (8.1.2)
- Placarding and marking (8.1.3)
- Fire fighting equipment (8.1.4)
- Miscellaneous equipment (8.1.5)
Vehicles carrying dangerous goods should have a Transport Document which give the details of the goods carried and a set of instructions, in writing, setting, out the basic hazard details, and giving some guidance as to what to do in an emergency and the equipment carried.
There are cross references to other parts of ADR where the details of documentation are given (ADR 5.4.1).
The vehicle should be carrying
- “Transport documents”, details of which may be found in “Consignment procedures”
- “Instructions In Writing” (IiW) , which contain basic information for use in an emergency.
There is now a standard format for IiW which is not affected by the goods carried. It is the carrier’s duty to ensure the driver has the IiW in a language he/she understands.
Instructions in writing which meet the requirements of ADR 5.4.3 up to December 2014 may continue to be used until 30th June 2017.
The IiW specify equipment to be carried and some of this is determined by the nature of the goods carried. A summary of the requirements is included in the tabular enforcement guide in "operational strategy and enforcement"
Placarding and marking
ADR para 8.1.3 refers to ADR Chapter 5.3 in respect of placarding and marking. More details may be found in Consignment procedures.
ADR para 8.1.4 concerns fire extinguishers. The table below sets out a summary of the minimum requirements. Note that dry powder extinguishers are specified because it is known that they are suitable for tackling fires of class A (solids such as wood, paper etc), class B (fires involving liquids) and class C (fires involving gases).
|Vehicle (max permissible mass)||Minimum dry powder fire extinguisher provision|
|Up to 3.5 tonne||2kg for cab
plus 2 kg
|over 3.5 t and up to 7.5 tonne||2 kg for cab
Total 8 kg (usually one 6 kg but other provision is acceptable as long as there is one 6 kg)
|Over 7.5 tonne||2 kg for cab
Total 12 kg (including at least one 6 kg)
|Any vehicle carrying dangerous goods under the" small load" limit or carrying only infectious substances||One 2 kg only|
Para 8.1.5 refers to "miscellaneous equipment". The most common problem is in the wording of subparagraph (a) about wheel chocks. Under ADR, the transport unit has to carry at least one suitable chock for each vehicle (which means at least two chocks for articulated lorries and drawbar combinations). There is no prescription as to where wheel chocks are to be carried. A discussion on enforcement issues is in para 8 of Annex 3.2 in Operational Strategy.
Note: Authorisation 24 which permitted GB registered "transport units" on domestic journeys to carry one suitable wheel chock has now been withdrawn.
Under this heading also come:
- Two self standing warning signs
- A suitable warning vest or warning clothing for each member of the crew
- A pocket lamp for each member of the crew. Note that special provision S2 (Table A column 19) means that the "pocket lamp" has to be suitable for use in a flammable atmosphere in certain circumstances.
- The equipment that is needed according to the load carried, summarised below
|Nature of load (by danger label)||Equipment|
|Labels 3 - 9||Eye rinsing liquid|
|Labels 2.3 and 6.1||Emergency escape mask|
|Labels 3, 4.1, 4.3, 8, 9||Drain seal
Plastic collecting container
ADR Driver Training
ADR Driver Training can include many different modules depending on the class of goods to be carried and what the goods are contained in. To begin with though, a driver would require a basic course followed by their required hazard class, and also knowledge of what the goods are carried in.
Chapter 8.2 of ADR covers driver training. The table below summarises the requirements.
|Vehicle /load||Driver training||ADR Reference|
|All vehicles except those carrying packages under the small load threshold.||General training plus ADR Training certificate
The certificate may be endorsed for different classes of dangerous goods or different modes (in tanks or other than tanks.)
|Any vehicle carrying packaged dangerous goods under the small load threshold.||General training||8.2.3 (refers to chapter 1.3)
|Vehicle with small tank (up to 1 m3)||General training||220.127.116.11
ADR chapter 1.3 gives the details of the “general training”. The requirement for carriers to keep a record of training is in ADR 1.3.3. ADR 2011 clarified the requirement that training should be carried out before a person assumes responsibilities in relation to dangerous goods. Otherwise duties should be carried out only under the direct supervision of a trained person (see 1.3.1).
Drivers are required to carry their training certificates by ADR 18.104.22.168. From 2011 the training certificates followed a standard “credit card” format as shown in ADR 22.214.171.124.5. It includes security features (126.96.36.199.3) and a photo of the holder.
Information on the training schemes may be found on DfT's website
When checking a driver's training certificate, Inspectors should ensure that:
- it is in the same name as the driving licence
- the expiry date has not passed;
- the certificate is valid for the class of dangerous goods being carried, and for the mode of carriage - i.e. "in tanks" or "other than in tanks";
- the certificate number matches that on the holder's driving licence, where possible.
Inspectors considering a prosecution for an apparent breach involving a training certificate will need to check whether a certificate has been issued to the driver concerned. This will need to be done through the DVLA as with other licence matters.
ADR 8.3 covers a number of simple and obvious precautions. These duties fall on the carrier and the crew (usually the driver, but in some cases a second person).
ADR 8.4 includes supervision of vehicles. This applies where special provisions S14 to S21 appear in column 19 of Table A.
Packaging requirements are at part 4 of ADR (in volume 2 of the "orange books"). The logical sequence is followed, with chapter 4.1 covering the use of packagings, intermediate bulk containers and large packagings. Each of these terms is defined in ADR at chapter 1.2. Chapters 4.2 to 4.5 cover various sorts of tanks.
Part 6 of ADR is complementary in that it sets out detailed requirements for the construction, and testing of packagings and tanks.
The initial parts of Chapter 4.1 cover all the general requirements with more detail following (the pattern throughout in ADR).
Once dangerous goods have been classified correctly, table A allows all the details of permitted packaging to be accessed. Columns 8 to 14 show what sort of packaging is allowed and directs you to the details.
- UN No 1263 Paint product in PG I (first entry)
- Column 8 shows that it may be packed according to the instruction P001
- In turn, top of column 8 directs you to para 4.1.4, which gives the details of what P001 allows. A wide range of packaging types is given.
It can also be seen that different requirements apply according to Packing group (PG). In this example, if drums are chosen as the (single) packaging, there are ten types available, all limited to 250 litres.
Similarly reading from columns 10 to 14 shows what tank methods are available and by reference to the relevant parts of ADR, complete details may be found.
That process may be adopted for all substances, care being taken to check any detailed provisions shown in other columns. In the example of the paint, there are mixed packing provisions. These take you to paragraph 4.1.10. Whilst these provisions are detailed, they do allow the packer to see exactly what is and what is not permitted. The DGSA should advise the packer in this matter.
In most cases (the main exemption being limited quantities) packaging has to be certified to UN standards. The international agreements for the carriage of dangerous goods require packaging to be of a design-type certified by a national competent authority. This involves testing the packaging to ensure its suitability for the carriage of certain dangerous goods. Such packagings are often referred to as "type-approved" or "UN certified". Such packaging is marked in particular ways, prefixed by the UN logo and followed by codes, the details of which may be found in part 6 of ADR.
For the example given above, P001 shows that a "steel non-removable head drum" (a conventional drum with small openings) is coded "1A1". Its marking might be
This is interpreted as follows (see ADR 188.8.131.52)
- 1A1 steel non-removable head drum
- Y for PG II, III
- 1.6 maximum relative density (formerly specific gravity) of contents. Not needed if 1.2 or less
- 270 Test pressure of drum in kPa
- ** last two digits of year of manufacture
- GB country of certification
- abcd represents the number of the certificate (in GB this is all figures)
If a PG II substance is used as the example (say UN 1193) it can be seen (column 8) that an IBC option is available (IBC 02), as well as "light gauge metal packaging" (code R001). By following the relevant "packing instruction" in part 184.108.40.206 the permissible types of IBC can be found.
The same process can be followed for any other type of packaging, with details to be found as follows
|Chapter 6.2||pressure receptacles (inc aerosols)|
|Chapter 6.3||class 6.2 substances (infectious substances)|
|Chapter 6.4||Class 7 (radioactive substances)|
|Chapter 6.5||Intermediate bulk containers (IBCs)|
|Chapter 6.6||Large packagings|
|Chapter 6.7||Portable tanks, multi element gas containers|
|Chapter 6.8||Fixed tanks etc|
|Chapter 6.9||Fibre reinforced tanks etc|
|Chapter 6.10||Vacuum operated waste tanks|
In every case all the necessary, highly prescriptive, details are to be found.
There are analogous processes for reconditioned packaging (e.g. there are specialist drum reconditioning firms). Drums are sometimes used on a "one trip" basis, but they may be re-used.
IBCs are intended for years of service and there are rules for their inspection (ADR 220.127.116.11). IBCs will also be marked with their inspection record (ADR 18.104.22.168.1). Plastics packaging (including plastic inners of composite IBCs) is normally limited to a life of 5 years (ADR 22.214.171.124). Some grades of nitric acid and hydrofluoric acid further limit the life of plastics packaging (see special packaging provision PP81 appended to packing instruction P001 and B15 appended to packing instruction IBC02))
IBCs are not always maintained well. Clues such as distorted fittings, inner receptacles (bottles) that don’t seem to fit properly inside the outer (cage), or missing corner pieces indicate that there might be problems that are worth following up. It is the packer’s responsibility to ensure that packaging is compliant.
From 1 January 2011 IBCs will have to carry a new symbol that shows stacking capacity more clearly. See ADR 126.96.36.199.2. IBCs made before that date may continue to be used unless remanufactured or repaired in which case the new symbol will have to applied.
In the UK the competent authority for the certification of packaging is the Department of Transport. The testing certification scheme is operated on their behalf by their agents VCA Dangerous Goods Office, Cleeve Road, Leatherhead, Surrey, KT22 7RU. Their web site contains the details of all UK certified packaging. Similar arrangements exist in many other countries.
Re-use of packagings
ADR contains no specific ban on the re-use of packagings. Drums are commonly re-used, but the packer or consignor needs to be sure that the drum is in a fit state and that it can be used in accordance with the conditions set out in its certificate of packaging performance. This might include reference to the type of closure. It is common for packaging as a whole (including caps and sealing elements) to be certified. Accordingly the packer should have access to the certificate and work within its limitations. Due diligence would require such a course.
Where drums are returned to the original packer for re-use, it would be expected that all the necessary conditions for adequate packing could be met, but other users will have more difficulty.
There is no objection (under this legislation) to packagings being used for substances that are not dangerous for carriage. Similarly, packagings could be used for on-site storage subject to risk assessment and requirements of other legislation.
Although most packaging needs to be tested and certified there are some exemptions, in particular for certain dangerous goods when carried in limited quantities.
Large packagings are defined in ADR 1.2.1. Although not a common packaging option across the chemical industry, the Healthcare sector uses this form of packaging on a large scale for clinical waste in the form of a “wheelie bin”, and now trolleys for the carriage of contaminated medical instruments have been certified as Large Packaging. They consist of outer packaging designed to contain inner packages or articles and which are designed for mechanical handling and to contain a net mass of 400kg or more, or are more than 450 litres in capacity. In the case of clinical waste the inner package is the familiar “yellow bag”.
Large Packaging specifications and testing are detailed in chapter 6.6. Details of certification are contained in 6.6.3.
There are several GB certifications for this type of packaging and they are used for the consignment and carriage of UN3291 Clinical Waste. The large package instruction is LP 621. This also requires that they should be leakproof.
The package must bear the certification mark as with other UN approved packages. Unusually the test standards for the plastic large packaging does not have the normal 5 year life span associated with most other plastics packages. Although not required to be re-tested the consignor needs to demonstrate that this form of packaging meets the UN test standard at all times. Plastics large packaging over 5 years old which has been stored outside in sunlight and subjected to regular sterilisation may not meet the UN test standard due to plastics degradation.
Packages of this type that do not bear the UN mark are in circulation. These do not comply with the regulations and should be taken out of use for UN 3291 dangerous goods.
Tanks of various sorts are commonly used to carry bulk supplies of dangerous goods. They are widely traded internationally and for that reason the construction and inspection standards are very prescriptive.
Accordingly ADR has four lengthy chapters, 6.7 to 6.10 that deal with various systems as follows:
- ADR 6.7 Portable tanks and UN certified "multiple element gas containers" (MEGC- an assembly of gas cylinders manifolded together and in a frame that is handled as one item)
- ADR 6.8 Metallic fixed tanks (tank vehicles), demountable tanks, tank containers and tank swap bodies and battery vehicles (commonly known in Britain as tube trailers and often seen with red cylinders of hydrogen) and MEGCs.
- ADR 6.9 Fibre reinforced plastics fixed tanks (tank vehicles), demountable tanks, tank containers and tank swap bodies.
- ADR 6.10 Vacuum operated waste tanks
Each of the terms is defined in ADR 1.2.1. Note the difference between "portable tank" and "tank container".
In each case there are prescriptive details of constructional standards and associated marking and certification schemes. These are operated by states' competent authorities or agencies acting on their behalf.
An example of how this system works is set out in Annex 6.1 below for the common case of a fixed tank (e.g. one carrying fuel on a semi trailer).
Because this equipment is intended to be used for many years, items may have been constructed to older standards. There are arrangements for allowing such equipment to continue in use subject to proper inspection and maintenance. In addition GB law has not always matched ADR. Accordingly "old tanks" are the subject of part of the document referred to in regulation 11(3) - "Dangerous Goods: Approved Derogations and Transitional Provisions"
The systems for other equipment follow similar patterns.
On the road inspection of tanks
In most cases it will not be possible for an enforcement officer to check full compliance with the requirements, but there are simple checks that can be made. In practice, most owners/operators of tanks that are in regular use have them properly inspected and maintained.
The following checks can be carried out.
- Visual condition. Do the tank and its fittings appear in good order? Is there evidence of leakage? Are outlets closed with caps or blanking plates? Is the protection for tank and fittings in good order? Do temperature and pressure gauges appear to be in good order?
- Tank markings. There should be plates fitted which give information such as tank maker, serial number, year of manufacture, and original test data such as test pressure, working pressure, temperature limits and so on. In addition there should be a plate giving inspection and test history with dates and a mark identifying the inspection /test authority. These plates are not always easy to find and can be confused with other plates relating to the roadworthiness requirements.
- If there is doubt this should be recorded on the UMP form or other report given to the driver. It will be followed up by HID CI 4 on receipt of the report.
Annex 6.1 - Example of how ADR works for the inspection and tests of a fixed tank
ADR 6.8 deals with a range of cases and for this reason is rather intricately set out. Parts of the script are in two columns. The left column deals with fixed tanks, demountable tanks and battery vehicles. The right column deals with tank containers, tank swap bodies and multi-element gas containers (MEGC - see example in annex 6.3 below). Otherwise the text is applied to all cases.
ADR 188.8.131.52 to 184.108.40.206 covers construction standards and related maters. This manual is not the place to look at this in detail. It is not likely that constructional standards or type approvals will be an issue in most routine inspection or related contacts. If the matter does arise specialist assistance is likely to be needed.
ADR 220.127.116.11 covers inspections and tests of newly constructed equipment. Follow up inspections are also covered at 18.104.22.168.2. A certificate showing the results of the tests, inspections or checks should be issued (ADR 22.214.171.124.5).
ADR 126.96.36.199 details how the equipment should be marked. This data should be found somewhere on the tank or its frame. In the case of trailers it may often be found on the trailer chassis, but care should be taken to distinguish this data from that related to road safety approvals.
There are some special requirements relating to tanks not made to recognised standards (ADR 188.8.131.52) though this is likely to be unusual.
ADR 6.8.3 sets out other requirements for class 2 substances (gases).
Inspection regimes are more likely to be an issue, though much of the sector operates satisfactorily. The requirements for routine inspections during the life of the tank are in ADR 184.108.40.206.2 to 220.127.116.11.5. For tanks the maximum interval for inspection is six years (this will usually include a hydraulic test). In addition a "leakproofness" test is needed every three years. There are slightly different requirements for tanks certain class 2 goods. More frequent inspections may be seen as the ADR figures are maximum time intervals.
The details of the tests should be marked on the tank or frame as para 4 above Accordingly it should be possible to follow the inspection history of a tank from its construction to the present by reference to the data fixed to it. For each inspection or test there should be a unique mark to identify the "expert" who carried out the tests and inspections. This will often be the mark of an insurance company.
Annex 6.2 - Example of requirements for "old tanks"
Instead of ADR’s requirements, “old tanks” are the subject of a regime that largely carries on the arrangements in the older regulations. The details are in part 3 of the document “Dangerous Goods: Approved Derogations and Transitional Provisions”
It remains necessary to
- ensure that the tank is suitable in every respect for its intended use
- maintain the tank and its fittings to prevent its contents escaping
Tanks are subject to a written scheme of examination"(WSE) drawn up by a competent person (analogous to that required for pressure plant). The scheme will not usually be available at the roadside, so it will not be easy to check, by reference to the marks, whether the WSE has been implemented.
Most written schemes will give inspection frequencies at least matching those required by ADR. Accordingly if evidence cannot be found of an inspection or test within the last three years some follow up with the owner should be made. Care should be taken as is it is not always easy to find the marks, especially if the vehicle is wet or dirty.
There should be a written report of the inspection and/or test . This is analogous to the certificate required under ADR 18.104.22.168.5.
The Energy Institute has published a model written scheme and information about training of technicians to carry out the work. CI 4B has a copy of the model WSE which HSE inspectors may consult.
Annex 6.3 - Some containment systems
IBCs vary in size, shape and material of construction. All are intended for mechanical handling (usually fork lift truck). Unless specifically designed for the purpose, lifting from the top is not permissible.
There are different variations but all are assemblies that can be moved as one piece on to and off vehicles
Often known as a tube trailer
This is the one of the commonest way of carrying liquids, gases and some solids (powders, granules etc).
Used very widely for international trading of many dangerous substances.
Regulation 5 is the basis for implementing the requirements of part 5 of ADR.
Depending on the case, these duties could fall on the packer, loader, consignor and/or carrier. The decision to be taken in the case of enforcement is "who was best placed to ensure compliance with the relevant provision". The effect of CDG Regs is that all participants have responsibilities. For example, even though it is the consignor's obligation to provide the carrier with documentation, the carrier commits a prima facie offence by travelling with non-compliant documentation. In practice the carrier can often only discharge his duty through the driver. A properly trained driver will recognise non-compliant documents but may be under pressure to accept them.
The relevant part of ADR is part 5. Obligations are set out in part 1.4 as follows. Note that unloader’s obligations are new for ADR 2011.
|Role||Obligations in ADR|
There are linked requirements in part 8, but they make it the carrier's duty to ensure that the "transport unit" carries the documents, placards etc. that are required by Part 5.
Chapter 5.1 contains the general provisions and covers
- overpacks (see definition at 1.2.1)
- empty uncleaned packagings, tanks, vehicles and containers for carriage in bulk
- mixed packing
- approval and notification (uncommon)
- certificates (mostly radioactives)
Marking and labelling of packages (ADR 5.2)
These words mean something different, but in both cases refer to packages.
- Marking is described in 5.2.1 and comprises the UN Number and other information for certain classes (1, 2 and 7). Marking is also used to describe the UN package certification details (ADR 6.1.3 and in Packaging)
- Labelling is described in 5.2.2 and comprises "hazard diamond(s)" with the Class number (e.g. "3" for flammable liquids) and subsidiary hazard where specified. Details in column 5 of Table A. Specimen labels are shown in 22.214.171.124.2.
The details are to be found in the various sub-paragraphs within 5.2.1 and 5.2.2 respectively. This is highly prescriptive and includes special requirements for certain substances.
Size requirements are in 126.96.36.199.1.1. ADR permits some flexibility in labelling of refrigerated liquid gases (188.8.131.52.1.1), and also allows changes to the background colour of flammable gas labels for UN1011, 1075, 1965, and 1978 (184.108.40.206.1.6 (c))
There is an additional requirement to display an orientation label for certain packages (220.127.116.11).
Working logically through the sections enables the requirements to be precisely determined.
There are rules in CHIP for combined supply and carriage labelling. In any event the carriage labelling has to be applied.
Placarding and marking of vehicles etc. (ADR 5.3)
As with marking and labelling these words mean different things, and apply to vehicles and containers, MEGCs (multi element gas container - defined in ADR 1.2.1), tank containers, and portable tanks.
- Placarding is described in 5.3.1 and refers to the "hazard diamonds" that are required for tanks, bulk and vehicles carrying class 1 or class 7 goods in packages.
- Marking is described in 5.3.2 and refers to the plain orange plates carried at the front of vehicles (and on the back of vehicles carrying packages) and to the other marks on the sides and backs of vehicles.
Placarding is the process of placing on the tank, container etc. the hazard diamonds referred to in column 5 of table A (analogous to labelling of packages). The precise details of sizes and so on are at 18.104.22.168. For small tanks or containers smaller placards can be used (22.214.171.124.3 - allows "package labels" to be used).
Placards have to be displayed as indicated in 126.96.36.199 to 188.8.131.52 according to the type of load.
Marking is the process of placing on the vehicle and the tank, container etc, the orange plates. Marking now also includes the EHS mark. where appropriate.
ADR allows the familiar plain orange plate to be divided by a horizontal black line (184.108.40.206.1).
Vehicles carrying packages
In all cases the plain orange plates for vehicles carrying packages are as described in ADR at 220.127.116.11.1. A plain orange plate is fixed at front and back of the "transport unit". Note the extra requirement for vehicles carrying class 1 (explosives) and class 7 ((radio-active substances) to display placards (hazard diamonds) on both sides and the rear of the vehicle.
Carrying packages in freight containers
This is similar to the above but in this case the freight container should display relevant placards (hazard diamonds) on all four sides of the container.
ADR includes Special Provision CV 36. This requires vehicles carrying packages of gases which could vitiate the atmosphere to be carried in open or ventilated vehicles/containers or if that is not feasible the cargo doors have to carry a suitable warning.
Tanks, tank containers etc
Different requirements apply to GB domestic journeys and international journeys. CDG Regs (at regulation 6 ) implements a national derogation that requires GB registered vehicles on GB domestic journeys to be marked with the familiar “Emergency Action Codes” (sometimes called “Hazchem codes”), and to include a telephone number for advice in the event of an emergency the requirement to display the plain orange plate at the front of the vehicle is the same as for packaged goods vehicles . Note that paragraph ) of schedule 1 allows the orange plate not to be fire resisting for tanks made before 1 January 2005. The same arrangements apply in Northern Ireland by virtue of their regulations.
GB registered vehicle on GB domestic journey
Plus EHS mark where appropriate on both sides and rear
Vehicles on international journeys
Vehicles with tanks etc on international journeys carry the HIN (hazard identification number – sometimes called the Kemler code) in the pattern shown at ADR para 18.104.22.168.3.
These are in addition to the placards (hazard warning diamonds) described at para 12 above.
Plates should be displayed at the rear and both sides, with a plain orange plate at the front. Where one substance only is carried it is permissible to display plates at front and rear only provided the front plate also carries the HIN code and UN Number. There is no requirement to display a telephone number. An international journey is described at ADR 22.214.171.124.
Chapter 5.4 of ADR covers this in the usual detail. The key requirements are that the documentation contains the following information (126.96.36.199):
- The UN Number
- Proper shipping name
- Class (with subsidiary hazard, if any, in brackets)
- Packing group (where assigned)
- Number and description of packages
- Total quantity of each item of different UN Number
- name/address of consignor
- name /address of consignee(s). Where there are multiple consignees not known at the start of the journey, the words "Delivery Sale" may be used.
- Declaration relating to any special agreement, where applicable (uncommon)
- Where assigned, the tunnel code, except where it is known that the journey will not involve passing through a relevant tunnel.
There is extra information required for Class 1 goods (explosives) (see ADR 188.8.131.52.1(e)), and for fireworks (UN numbers 0333, 0334, 0335, 0336, and 0337) information about the classification by the relevant competent authority (ADR 184.108.40.206.1 (g))
There are other rules for class 1 (explosives) class 2 (gases), class 4.1 (flammable solids etc.), class 5.2 (organic peroxides), class 6.2 (infectious substances) class 7 (radioactives). These are in ADR 220.127.116.11. The most likely to be met are those relating to gas mixtures where the composition of the mixture should be given (18.104.22.168.2(a).
The last part of ADR 22.214.171.124.1 prescribes the order in which this information is shown.
There is no requirement for all information to be on one document. Where a vehicle has picked up loads from more than one consignor this would clearly not be possible.
There are special rules for wastes, salvage packagings, and empty uncleaned packaging etc (126.96.36.199.3 to 188.8.131.52.6).
For empty tanks and bulk there are other rules about documentation in 184.108.40.206.6.
Where loads are being carried on domestic journeys under the limited load threshold (ADR 220.127.116.11 - more details in Main Exemptions) the requirement to carry documentation is disapplied (except for explosives and radioactives). Details in the document “Dangerous Goods: Approved Derogations and Transitional Provisions”. The requirement to furnish the carrier with documentation still applies.
Other special rules cover
- Loads in a transport chain that includes air or sea (18.104.22.168.7)
- Carriage in “date expired” IBCs (22.214.171.124.11 - details in 126.96.36.199)
- Multi compartment tanks or transport units with more than one tank (188.8.131.52.13)
- Elevated temperature substances (184.108.40.206.14)
- Substances stabilised by temperature control (220.127.116.11.15)
Language and format
The language should be that of the forwarding country and one of English, French or German if not already on the document (18.104.22.168.1). This means that, especially for international journeys, the documents may not be in English and that is one reason why the layout of the information referred to in 22.214.171.124.1 is important.
As a signatory to the European agreement concerning the International Carriage of Dangerous Goods by Road (ADR), and a member state of the EU, the UK is committed to harmonisation of national and international regulations, as far as possible. Therefore, in order to align with the ADR and RID Directives, governing the carriage of dangerous goods by road and rail respectively, a consolidating set of regulations came into force on 10 May 2004. These were substantially restructured in 2007 to include all classes of dangerous goods for both road and rail transport.
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG Regs) have been restructured to create the majority of duties by direct reference to ADR. They were amended in 2011, mainly to take account of changes to the Transportable Pressure Equipment Directive.
The prescriptive nature of the regulatory package arises from the need to align domestic legislative arrangements with the ADR and RID codes for the carriage of dangerous goods on international journeys.
HSE is one of the enforcement authorities for many aspects of CDG Regs (but note that DfT is the “competent authority” for most purposes – see Regulation 25).
Regulation 32 allows suitably qualified and appointed police officers and Driver and Vehicle Standards Agency (DVSA) officers to enforce the regulations “on the road” (see Operational Strategy & Enforcement). That chapter also includes enforcement guidance.
International standards on the transport of dangerous goods by road are derived from the recommendations of the UN Committee of Experts. These recommendations are contained in the so-called "orange book", and form the basis of a series of codes covering the classification, packaging and labelling of dangerous goods for transport by road, rail, sea and air.
HSE is mostly involved with the codes for the carriage of dangerous goods by road (ADR). The IMDG code and the technical instructions issued by the International Civil Aviation Organisation (ICAO) deal with the carriage of dangerous goods by sea and air respectively.
The ADR and RID Directives required EU Member States to incorporate the codes into national legislation by 1 January 1997, thereby applying them to domestic as well as international carriage.
The international working party on the transport of dangerous goods (WP15), normally meets twice a year to review the conditions governing the international transport of dangerous goods between European countries by road and rail, with the aim of aligning ADR and RID with the UN recommendations. Decisions taken by WP15, when subsequently approved, are included in the latest edition of ADR for implementation. ADR is updated every 2 years.
The ADR agreement allows dangerous goods travelling by road through more than one country to be exempt from the domestic legislation in force in those countries, as long as the requirements of ADR are met in full. However, ADR contains no provisions for enforcement and therefore, where a vehicle travelling under ADR does not comply in full, the vehicle becomes subject to all domestic requirements. As such any enforcement action would be framed in terms of the relevant domestic regulations.
In addition, vehicles registered outside the UK may also travel under ADR while carrying dangerous goods on journeys confined to the UK, i.e. on non-international journeys. This procedure allows for "cabotage", whereby 'foreign' vehicles may carry dangerous goods on domestic journeys without having to conform to domestic legislation. For example, a Dutch vehicle travelling under ADR on an international journey involving the consignment of dangerous goods from Rotterdam for delivery in Glasgow may pick up another load of dangerous goods in Glasgow for delivery in Hull. Although the Glasgow-Hull journey is not international the vehicle may still travel under ADR. Since GB domestic regulations now largely refer to ADR this distinction is of less importance than formerly.
The IMDG code contains internationally agreed guidance on the safe transport of dangerous goods by sea, and most commonly relates to the carriage of dangerous goods in freight containers and tank containers. Primarily it is used by shipping operators but it is also relevant to those transporting dangerous goods on journeys involving a sea crossing. In the UK many operators do not undertake complete international journeys but only visit a port to deliver or collect trailers, freight containers or tank containers which have been placarded with IMDG labels for sea journeys. Where there is full compliance with the IMDG Code, vehicles are exempted from the placarding requirements of ADR. The plain orange plates (front and back) should be displayed on the transport unit. If the load is a tank which is displaying the plate with the HIN and UN No., the rear plain orange plate will not be needed. However, all other relevant matters including training, information in writing, provision of fire-fighting equipment etc, apply as under the regulations. For the exemptions on placarding to apply, the journey must involve dangerous goods being carried to a port for carriage by sea, or from a port having been carried by sea.
Individual countries are responsible for implementing the Code under their own legislation and in the UK this is done through The Merchant Shipping (Dangerous Goods and Marine Pollutant) Regulations 1990, which are enforced by the Department of Transport, and through The Dangerous Substances in Harbour Areas Regulations 1987, as enforced by HSE.
ICAO technical instructions
There are analogous provisions in respect of goods packaged and consigned for air transport. Enforcement is by the Civil Aviation Authority (CAA ). In this case, ICAO "technical instructions" set the relevant standards. Details are obviously different but principles are similar. Airlines generally work to IATA rules which are based on the ICAO technical instructions.
Department for Transport (DfT)
DfT is the lead government department on all aspects of transport, in whatever mode. Consequently it is the Secretary of State for Transport who responds to Parliament on transport matters.
DfT also represents the UK on the various bodies responsible for producing international agreements and standards covering the transport of dangerous substances, i.e. ADR for road, RID for rail and IMDG for marine.
Regulations on the transport of dangerous substances are made under Health and Safety at Work etc Act 1974 and are prepared by DfT.
DfT takes a close interest in the number of vehicle checks carried out and level of enforcement. HSE, DVSA and Police forces provide DfT with details of the number of vehicle checks carried out and the extent of enforcement action taken. DfT collates information from the checklists completed under the terms of the Uniform Monitoring Procedures Directive, and submits an annual report to the EC on levels of enforcement activity within the UK.
DfT is the UK competent authority for the certification of packaging. The testing and certification scheme is operated on their behalf by their agents, the Vehicle Certification Agency.
Organisations providing vocational training for drivers of dangerous goods vehicles must be approved by DFT. Information about approved training providers may be found on DfT’s website.
The Office for Nuclear Regulation (ONR) enforce the legislation dealing with the carriage of radioactive materials by road.
Liaison between DfT, HSE, the Police, DVSA and other government departments takes place at the "Enforcement Liaison Committee", which meets twice yearly. HID is represented on the Committee by CEMHD Unit 4 and CEMHD Unit 7 (Explosives Inspectorate) and ND. The committee covers all dangerous goods including radioactive materials and explosives. The transport of radioactive materials is also the subject of a Memorandum of Understanding between DsT ONR. CEMHD Unit 4 also represents HSE in DfT and stakeholder liaison meetings.
Police, DVSA, DfT and HSE (CEMHD Unit 4) hold a “practitioners’ forum” where operational problems are discussed. This meets 2 – 3 times per year. CEMHD Unit 4 prepares enforcement guidance in consultation with the practitioners’ forum.
The main exemptions are:
- Private use of vehicles. There are now limits on the total quantity that may be carried under this exemption.
- Carriage of machinery which happens to contain dangerous goods.
- Carriage that is “ancillary” to main activity.
- Carriage by, or under, the supervision of the emergency services.
- Emergency transport intended to save life or protect the environment.
- Uncleaned empty static storage vessels that have contained certain gases, class 3 (flammable liquids – PG II and III only) or class 9 (miscellaneous).
- Some carriage of gases.
- Some carriage of liquid fuels
- Some empty uncleaned packaging .
Exemptions arise in three ways,
- ADR itself,
- from the "Dangerous Goods Directive" (DGD), as implemented by CDG Regs. There are direct exemptions and derogations
ADR itself has exemptions set out in part 1.1.3. The main ones are:
- Private use of vehicles. There are now limits on the total quantity that may be carried under this exemption. Note that other legislation may limit carriage of petrol etc. The CDG Regulations introduce limits for private carriage of Class 1 goods (explosives). See Regulation 9.
- Carriage of machinery which happens to contain dangerous goods
- Carriage that is "ancillary" to main activity. Note the second part of this exemption which limits its scope. This is not easy to define. For the present the following guidance is offered.
- A driver taking dangerous goods with him for use with some machine or process that will be operated on arrival will be exempt.
- A journey taking dangerous goods to "re-supply" the above example will not be covered by this exemption (but other exemptions may apply).
- Carriage by or under the supervision of the emergency services. This is intended to allow the necessary emergency response to be completed, and not for wider purposes.
- Emergency transport intended to save life or protect the environment.
- Uncleaned empty static storage vessels that have contained certain gases, class 3 (flammable liquids – PG II and III only) or class 9 (miscellaneous). In this context "static" means not designed for transport of dangerous goods. For LPG there is an industry Code of Practice (LPGA COP 26) dealing with their safe removal and carriage
- Some carriage of gases. (ADR 126.96.36.199).
- Some carriage of liquid fuels (ADR 188.8.131.52)
- Empty uncleaned packaging (ADR 184.108.40.206). This is not a clear exemption and not everything is exempt. Note that there are documentary requirements at ADR part 220.127.116.11.6.
Exemption from duty to appoint a DGSA
This is a limited exemption permitted by ADR 18.104.22.168 which is discussed in ADR, CDG and DGSA . It has been implemented by Regulation 3(j)
Limited quantity (LQ) exemptions (ADR 3.4)
LQ refers to small receptacles (typically of the sort that go into the retail distribution chain) which are packed in boxes or on shrink-wrapped trays.
The principle behind LQ is that an acceptable level of safety is assured providing the receptacles are in a box or shrink-wrapped tray. Retail distribution of LQ packages that have been "broken down" is allowed, subject to certain conditions. Subject to those conditions being met, no other requirements of ADR apply. Note however that from 1 January 2011 there are requirements to mark certain transport units when carrying more than 8 tonnes of LQ packages. See ADR 3.4.10
Dangerous goods are assigned an LQ "maximum quantity per inner packaging" (Column 7a of Table A in ADR). For some substances this figure is 0, and in these cases there is no LQ exemption.
3.4.2 and 3.4.3 specify the maximum gross mass of the package into which the inner receptacle is placed. This is 30kg except for shrink wrapped trays where the limit is 20 kg)
For limited quantity exemptions, the general requirements for packaging (to be of good quality and suitable etc) apply, but the packaging does not have to be "UN approved.3.4.4 has a particular requirement for certain Class 8 (corrosive) goods. There are particular LQ marking requirements (see ADR 3.4.7 and 3.4.8. Subject to those conditions, ADR does not apply to "limited quantities".
Mark has to be minimum 100 mm x 100 mm unless package is too small. In that case the minimum is 50 mm x 50 mm
There is a requirement, under certain circumstances, for the marking of a transport unit which is carrying dangerous goods in "Limited Quantities". See ADR 2015 paragraphs 3.4.11 to 3.4.15.
Examples of limited quantity application
Hydrochloric acid, UN 1789,(Strong PG II). From column 7a of Table A the maximum receptacle (inner packaging) size is 1 litre. which means that as long as the individual “bottles” are not larger than 1 litre, and the box does not weigh more than 30 kg, then, subject to the conditions outlined above, ADR does not apply.
The same substance more diluted (PG III) has a maximum “bottle” size of 5 litres. Again the maximum box weight is 30 kg.For example, typical 2 ½ litre bottles, packed four to a box, are within the LQ limit. The detailed packaging requirements do not have to be met but the LQ marking requirements apply (see above)
Solid caustic soda drain cleaner (UN 1823) has a maximum inner receptacle size of 1 kg. Again the maximum gross overall package is 30 kg.
Paint UN 1263 PG II. Cans up to 5 litres may be packed in a box not exceeding a gross weight of 30kg. Cans up to 1 litre may be on a shrink wrapped tray not exceeding a gross weight of 20 kg. Subject to the box or tray being marked as above ADR does not apply.
Orientation arrows have be applied to LQ packages when the conditions described at 22.214.171.124 apply.
ADR at 3.4.12 t requires information to be given to carriers in relation to consignments of “Limited Quantity (LQ) packages”. In certain circumstances (ADR 3.4.13), the vehicle has to be marked if carrying at least 8 tonnes of LQ packages.
Excepted quantity exemptions (ADR 3.5)
"Excepted quantities" (EQ) is a relatively new concept for land transport of dangerous goods. It has been commonly used in air transport and the new rules will facilitate the road (and rail) transport elements of a journey that includes air mode. It is, though, also a standalone provision, and gives consignors an alternative for many dangerous goods.
Like LQ it requires goods to be in combination packages (e.g. a bottle in a box)
A new code (E0 – E5) appears in column 7(b) of table A. This links to paragraph 126.96.36.199 where what is allowed by the codes is set out. For example code E0 means that no EQ provisions are applicable. Code E1 means that the substance may be carried in inner packagings up to 30g or 30ml in outer packagings with a maximum net contents of 1000g or 1000ml - and so on for the other codes.
Unlike for LQ there are more prescriptive rules about packaging testing and for documentation.
The packages have to be marked with the "EQ Symbol" and documents (where carried) must state "dangerous goods in excepted quantities" and indicate the number of packages.
Small load exemptions (ADR 188.8.131.52)
Small load exemptions relate to the total quantity of dangerous goods carried in packages by the "transport unit" (usually the van or lorry, but also any trailer). It is the transport category (TC) that determines the load limits (thresholds). Many substances are assigned a packing group but these are not synonymous in all cases with TC. TC is given in column 15 of Table A in ADR (Chapter 3.2). If that is not available, the table at ADR part 184.108.40.206.3 needs to be consulted. Load limits for the different transport categories are given below. For convenience this has been amended in accordance with the derogation but it needs to be used with care.
Small load exemptions do not apply to tankers or bulk carriage.
If a vehicle is carrying under the small load threshold, many of the requirements of ADR are not applicable. The table below summarises the position. Some care needs to be taken, as "what is not exempted is still required". In most cases the remaining obligations are:
- General training for driver (ADR 1.3.2). A record should be kept (ADR 1.3.3)
- Carry one 2 kg dry powder fire extinguisher or equivalent (ADR 220.127.116.11)
- Stow the dangerous goods properly (ADR 7.5.7)
Note that use of these exemptions is optional. For example, a carrier may choose to display the orange plates as long as the vehicle is carrying dangerous goods.
All vehicle marks (orange plates) must be removed when no dangerous goods are being carried.
Examples of small load application
LPG. This is in transport category 2. The "small load threshold" is 333 kg and there is no LQ provision.. The result is that all cylinders count towards the load limit, but if that is less than 333 kg, the "minimum" ADR requirements apply.
Hydrochloric acid. Depending on its strength this is in transport category 2 or 3. The "small load threshold" is 333 or 1000 litres respectively. For TC 3, one 1000 litre IBC or five 200 litre drums or forty 25 litre drums can be carried under the "minimum" ADR requirements if the carrier chooses to do so. Any packages that meet LQ criteria are not counted.
Methanol. This is in transport category 2. The "small load threshold" is 333 litres. Any combination of packages up to that amount can be carried under "minimum" ADR requirements if the carrier chooses to do so. Because methanol has all packages count towards this threshold.
Clinical waste (UN 3291). This is in transport category 2 and there is no LQ provision. Thus all packages have to be counted. It is now possible to use combination packaging consisting of an outer "flat pack" corrugated fibreboard box into which is placed a conventional clinical waste bag. Providing the outer box is properly certified this makes the carriage of small amounts of clinical waste possible as “packages”. Sharps containers may also come into this category. Typical situations would be the collection of waste from GPs' surgeries or patients' homes. In these cases, as long as the total load is less than 333 kg (which would normally be the case) the small load exemptions will apply. . Bulk carriage of clinical waste (typical yellow bags loosely loaded into a vehicle) cannot be carried under the small load provisions.
It can be seen that depending on the substances and the package size, there will be differences in the way the regulations are applied. In each case, if there are mixed loads the aggregation rules in ADR at 18.104.22.168.4 must be applied.
Exemptions allowed by small load threshold
|ADR reference||Requirement that does not apply||Not exempted|
|5.3||Placarding and marking|
|5.4.3||Instructions in writing (Emergency information)||Other documentary requirements.
Consignor's duty to "furnish the carrier with information…." remains (ADR 22.214.171.124.1 (b)), but it doesn't have to be carried in GB for classes 2 to 6, 8 and 9
|7.2||The details attached to package requirements. Depends on substance - see column 16 of Table A||7.2.4
V5 packages not to be carried in "small containers"
V7 ventilation of vehicle
V8 Temperature control
CV 1 only
|Prohibition of loading/unloading in public place||When carrying explosives
All other "CV" special conditions apply to small loads. Note in particular CV9, CV10, and CV36 apply to carriage of gas cylinders
|Part 8||Vehicle crews, equipment, documentation, operation
|126.96.36.199 (a) and (c) (documentation) but note GB exemption in Regulation 29
188.8.131.52 to 184.108.40.206 fire extinguisher for cab (but note transition period in ADR at 220.127.116.11)
8.2.3 General training as set out in Chapter 1.3
8.3.4 prohibition of certain types of lighting apparatus
8.4 Supervision of vehicles (where applicable)
8.5 The following operational notes in column 19 of Table A
S1(3), S1(6), S2(1), S4,
S14 to 21 (supervision details)
|Construction and approval of vehicles|
Exemptions arising from the Dangerous Goods Directive
Regulation 16 provides that the main parts of the regulations do not apply where carriage is “not undertaken by a vehicle”. This links to the directive’s definition of vehicle and the practical outcome is that the regulations do not apply to:
- Vehicles with a maximum design speed of 25 km/hour or less
- Vehicles that run on rails
- Mobile machinery (not defined). This could include vehicles specially equipped for road construction purposes, such as white lining vehicles.
- Agricultural or forestry tractors that do not travel at a speed exceeding 40 km/h when transporting dangerous goods; or any trailer being towed by such a vehicle. There is no definition of “agricultural or forestry tractor”. Cases will have to be judged on their merits. There are certain tests that can be applied, including taxation class, legal use of “red diesel”, and fittings common to tractors such as PTOs and three point linkages for attachment of agricultural implements. Subject to any Court decision, vehicles, such as Land-Rovers, Range Rovers and other 4x4 road vehicles are not regarded as agricultural or forestry tractors.
Vehicles with fewer than four wheels
Vehicles with fewer than four wheels were previously exempted from ADR under the definition of a vehicle in the Dangerous Goods Directive. However, motorcycles are increasingly used to carry dangerous goods in GB, especially for time-critical consignments such as diagnostic specimens where the speed of delivery is vital for the diagnosis and ultimately the treatment of patients. In order to ensure that such consignments continue to be safely transported, GB has decided to extend the scope of the regulations to include motorcycles.
Movements within premises
Movement wholly within an enclosed area is exempt from the main parts of the regulations. See Regulation 15.
MoD vehicles will operate in line with ADR but tankers will be placarded and plated to ADR practice rather then GB practice. Vehicles operated by commercial carriers on contract to MoD or simply delivering to MoD premises are treated conventionally. The Secretary of State for Defence may issue authorisations to allow MoD vehicles to work outside ADR but this will arise only in special cases (see regulation 12).
For small loads (ADR 18.104.22.168) there is no need in GB to carry the documentation except for explosives and radioactive materials.
The need for the consignor to provide documentation to the carrier remains (ADR 22.214.171.124.1(b) and Regulation 5.
Retail distribution of LQ packages and combination packages (See also the relevant entry: Are there any exemptions from the regulations for retails distribution of goods?
- The UK has a “derogation” which relaxes the package labelling and marking requirements for the final stages of carriage in retail distribution.
- Some dangerous goods which have been packaged as "limited quantities" (ADR 3.4) or in “combination packaging (e.g. a bottle in a box) may be removed from their outer packaging and carried from distribution depot to retail outlet (and back if needed) without the packaging having to be marked with UN certification marks or the hazard symbols.
- Typical products are paints, varnishes, adhesives, drain cleaners, and aerosols. The derogation does not apply to:
- Class 1 (explosives), Class 4.2 (substances liable to spontaneous combustion )
- Class 6.2 (Infectious substances)
- Class 7 (radioactive substances)
- There are conditions:
- The journey must be part of the final distribution stages from depot to retailer or end user, or an equivalent return journey.
- No type, colour, strength or inner package size of a substance or article (sometimes called "stock keeping unit") may be more than 30 litres (or kg) and the total of such goods may not be more than 333 litres (or kg).
- The details are in UK Road Derogation No 4 which may be found in the document “Carriage of Dangerous Goods: Approved Derogations and Transitional Provisions.” DfT have issued Guidance Note 7 which explains this derogation in more detail.
A UK derogation (set out in “Dangerous Goods: Approved Derogations and Transitional Provisions”) makes changes to transport categories and load thresholds for many explosives. In effect these changes maintain older arrangements for domestic transport only. See also amended table of transport categories
Crossing public roads
A UK derogation provides that, except for explosives and radioactive materials, the regulations do not apply to the following movements
- Between private premises and a vehicle in the immediate vicinity (for example loading a vehicle just outside the premises)
- Between private premises (in the immediate vicinity) occupied by the same person, including where separated by a road.
- "Immediate vicinity" is not defined and there is scope for abuse. Subject to any Court decision, in the first case a journey of more than about 100 metres on the highway, and in the second case more than about 400 metres, should be regarded as not in the "immediate vicinity".
There are related, but more restrictive exemptions for classes 1 and 7 goods. For details see “Dangerous Goods: Approved Derogations and Transitional Provisions”.
Exemptions by "authorisation"
For a variety of reasons it has been found necessary to issue authorisations to allow certain activities to take place outside the strict scope of ADR. These are added to and deleted as the need arises or recedes. They are all time limited (though in some cases the time is substantial). The up-to-date list may be found at authorisations.
The authorisations are all in pdf files and can readily be downloaded. Some are somewhat esoteric, but those most likely to be encountered are:
- No. 1 - bowsers used for diesel
Transport categories as amended in GB
(See column 15 of Table A)
|Substances or articles
packing group or classification code/group or UN No.
|Maximum total quantity per transport unit
Kg or litres
|Multiplier for mixed loads|
|0||Class 1: 1.1A/1.1L/1.2L/1.3L/1.4L and UN No. 0190
Class 3: UN No. 3343
Class 4.2: Substances belonging to packing group I
Class 4.3: UN Nos. 1183, 1242, 1295, 1340, 1390, 1403, 1928, 2813, 2965, 2968, 2988, 3129, 3130, 3131, 3134, 3148, 3207 and 3372
Class 6.1: UN Nos. 1051, 1613, 1614 and 3294
Class 6.2: UN Nos. 2814 and 2900
Class 7: UN Nos. 2912 to 2919, 2977, 2978 and 3321 to 3333
Class 8: UN No 2215 (Molten maleic anhydride)
Class 9: UN Nos. 2315, 3151, 3152 and equipment containing such substances or mixtures and empty uncleaned
packagings having contained substances classified in this transport category
|1||Substances and articles belonging to packing group I and not classified in transport category 0
and substances and articles of the following classes:
Class 2: groups T, TC a, TO, TF, TOC and TFC
aerosols: groups C, CO, FC, T, TF, TC, TO, TFC and TOC
Class 4.1: UN Nos. 3221 to 3224 and 3231 to 3240
Class 5.2: UN Nos. 3101 to 3104 and 3111 to 3120
|20||50 See note "a" below|
|2||Substances or articles belonging to packing group II and not classified in transport categories 0, 1 or 4 and substances of the following classes:
Class 2: group F
aerosols: group F
Class 4.1: UN Nos. 3225 to 3230
Class 5.2: UN Nos. 3105 to 3110
Class 6.1: substances and articles belonging to packing group III
Class 9: UN No. 3245
|3||Substances and articles belonging to packing group III and not classified in transport categories 0, 2 or 4
and substances and articles of the following classes:
Class 2: groups A and O
aerosols: groups A and O
Class 8: UN Nos. 2794, 2795, 2800 and 3028
Class 9: UN Nos. 2990 and 3072
|4||Class 1: 1.4S
Class 4.1: UN Nos. 1331,1345,1944,1945,2254 and 2623
Class 4.2: UN Nos. 1361 and 1362 packing group III
Class 7: UN Nos. 2908 to 2911
Class 9: UN No. 3268
and empty, uncleaned packagings having contained dangerous goods, except for those classified in transport category 0
|Note a: For UN Nos. 0081, 0082, 0084, 0241, 0331, 0332, 0482, 1005 and 1017 (anhydrous ammonia and chlorine), the total maximum quantity per transport unit shall be 50 kg||50||20|
Carriage of Dangerous Goods - Resources
Carriage of Dangerous Goods Manual
The Carriage of Dangerous Goods manual is not intended to make enforcement officers experts, but to guide them through the process and enable them to make informed judgements about the extent of compliance. It will also guide officers when discussing compliance with duty holders and deciding when to take further action.
Guidance on the carriage of dangerous goods
The Department for Transport has published a range of specialist guidance on transporting dangerous goods.
A simple overview of how to ship, package and label dangerous goods is available on GOV.UK.
The following guidance supports the regulations for the carriage of dangerous goods:
- Security requirements for moving dangerous goods by road and rail , guidance published on 18 October 2012
- Driving dangerous goods and special loads , detailed guide published on 21 October 2013 -
- Moving dangerous goods , detailed guide published on 4 September 2012 -
- Carriage of dangerous goods other than Class 7: guidelines published on 30 July 2015 - guidance
- Dangerous goods: ADR instructions in writing and UK tunnel codes published on 1 January 2010 - guidance
Class 7 Radioactive Material, guidance on the carriage of radioactive material (Class 7) has been published by ONR. The guidance is aimed at consignors and carriers of Class 7 dangerous goods who wish to transport such goods into and within Great Britain by road and rail. It is provided to assist consignors and carriers of Class 7 dangerous goods to understand and meet their responsibilities to comply with CDG within GB.