Transport of Dangerous Goods by Road (ADR General)
What is ADR?
ADR is the acronym given to The European Agreement Concerning the International Carriage of Dangerous Goods by Road, which was made at Geneva in 1957 by United Nations Economic Commission for Europe, and amended April 1985.
The key article in the agreement is the second, which says that apart from some excessively dangerous goods, other dangerous goods may be carried internationally in road vehicles subject to compliance with:
- the conditions laid down in Annex A for the goods in question, in particular as regards their packaging and labelling; and
- the conditions laid down in Annex B, in particular as regards the construction, equipment and operation of the vehicle carrying the goods in question.
Annexes A and B have been regularly amended and updated since the entry into force of ADR. These annexes were entirely revised and restructured between 1992 and 2000, and a first version of the restructured annexes entered into force on 1 July 2001.
Ireland is a contracting party to ADR.
The most recent amendment to the annexes was on the 1 January 2017.
What provisions are detailed in the ADR 2017 Annexes?
Annex A details the general provisions and provisions concerning dangerous articles and substances which are divided into the following parts:
- Part 1 – General Provisions
- Part 2 – Classification
- Part 3 – Dangerous goods list, special provisions and exemptions related to limited and excepted quanitities
- Part 4 – Packing and tank provisions
- Part 5 – Consignment procedures
- Part 6 – Requirements for the construction and testing of packagings, intermediate bulk containers (IBCs), large packagings and tanks
- Part 7 – Provisions concerning the conditions of carriage, loading, unloading and handling
Annex B details the provisions concerning transport equipment and transport operations which are divided into two parts as follows:
- Part 8 – Requirements for vehicle crews, equipment, operation and documentation
- Part 9 – Requirements concerning the construction and approval of vehicles
What is classified as “Carriage of Dangerous Goods”?
Under the European Communities (Carriage of Dangerous Goods by Road and Use of Transportable Pressure Equipment) Regulations 2011 to 2017 “the carriage of dangerous goods by road” is defined as any road transport operation performed by a vehicle wholly or partly on public roads, including the activity of loading and unloading, packing and filling, covered by the ADR, but does not include transport wholly performed within the perimeter of an enclosed area not open to the public.
What is classified as “Dangerous Goods” for carriage by road?
The classes of dangerous goods according to ADR are the following:
|Class Number||Substance / Article Description|
|Class 1||Explosive substances and articles|
|Class 3||Flammable liquids|
|Class 4.1||Flammable solids, self-reactive substances, polymerizing substances and solid desensitised explosives|
|Class 4.2||Substances liable to spontaneous combustion|
|Class 4.3||Substances which, in contact with water, emit flammable gases|
|Class 5.1||Oxidising substances|
|Class 5.2||Organic peroxides|
|Class 6.1||Toxic substances|
|Class 6.2||Infectious substances|
|Class 7||Radioactive material|
|Class 8||Corrosive substances|
|Class 9||Miscellaneous dangerous substances and articles|
Each entry in the different classes has been assigned a unique, 4-digit UN number, which may be either specific to an individual substance or collective to a product or substance type.
The UN numbers are assigned to different transport categories from 0 to 4 and this will influence the maximum amount of the goods that can be carried at any one time.
How do I find out the requirements for particular goods or substance?
Chapter 3.2 of the ADR contains a Dangerous Goods List. This is a table which contains a list of dangerous goods by name and description, their UN numbers, classification, transport categories and all relevant requirement codes for packaging, labelling, carriage, etc. The table shows the section of the ADR that detail the requirements for each of the relevant codes.
3.2.1 of the ADR gives explanatory notes on each of the columns.
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As a chemical distributor, what other chemical legislation applies to me in addition to my responsibilities under the European Communities (Carriage of Dangerous Goods by Road and use of Transportable Pressure Equipment) Regulations 2011 and 2017?
Distributors of chemicals also have duties under EU chemical legislation including the REACH and CLP regulations.
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How is the ADR enforced in Ireland?
The European Communities (Carriage of Dangerous Goods by Road and Use of Transportable Pressure Equipment) Regulations 2011 to 2017 enforce ADR 2015 in Ireland. These regulations are based on the provisions outlined in the Annexes.
What do the regulations apply to?
These Regulations apply to the carriage, in tanks, in bulk and in packages, of dangerous goods by road; including the packing, loading, filling and unloading of the dangerous goods in relation to their carriage. They apply the provisions, contained in the technical Annexes to the ‘European Agreement Concerning the International Carriage of Dangerous Goods by Road' (ADR).
The Regulations impose duties on the various participants associated with the carriage of the dangerous goods. They contain requirements for the vehicles, tanks, tank containers, receptacles and packages containing the dangerous goods during their carriage. They require that the drivers and others, involved in the carriage of the dangerous goods by road (including their packing/loading/filling/transport/unloading) be adequately trained and, in the case of drivers, hold a certificate of such training. The Regulations also contain provisions on an EC harmonised approach to the road checks aspect of their enforcement.
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Who are the competent authorities for ADR in Ireland?
The following are the ‘Competent Authorities’:
- Road Safety Authority (RSA) for technical examination of vehicles and issuing of certificates of approval
- National Standards Authority of Ireland (NSAI) for testing of receptacles and tanks
- Irish National Accreditation Board (INAB) for accreditation of inspection bodies
- Minister for Justice and Equality for all matters relating to the carriage by road of explosives of the ADR Class 1
- Environmental Protection Agency (EPA) for all matters relating to the carriage by road of radioactive materials of the ADR Class 7
- National Roads Authority (NRA) for matters relating to the classification of tunnels as required
- Health and Safety Authority (HSA) for all other functions required to be performed by a competent authority under the Regulations
Can the transport document required by ADR be incorporated into another document or split between more than one document?
Yes. If all the relevant information as required by ADR 188.8.131.52.1, is situated within a document(s) which may double as an invoice or waste C1 form or another document, this is acceptable provided the ADR transport document information is clear and follows the requirements set out in ADR.
How much waste electrical goods are allowed for carriage by road without ADR applying?
Under ADR if the electrical goods, e.g. transformers or condensers etc, contain PCB’s – Polychlorinated Biphenyls (liquid or solid) or PHB’s Polyhalogenated Biphenyls (liquid or solid) with UN numbers 2315, 3151, 3152 or 3432 then all the requirements of ADR apply for any quantity transported and the driver would have to hold valid ADR Driver Training Certificate covering Class 9 as the goods would come under Transport Category 0.
It should also be noted that uncleaned empty containment vessels for such apparatus containing substances assigned to UN 2315, 3151, 3152 cannot be accepted for carriage.
However if the electrical goods do not contain dangerous substances then they are exempt from any of the requirements of ADR, the consignor has the obligation to classify the waste.
Where can I find information on the amount of other substances I can carry, by road, without ADR applying?
To find out how much of a substance can be carried you must first find out the UN number assigned to that particular substance.
184.108.40.206.3 of ADR shows a table of Transport Categories, the UN numbers that fall into those categories and the corresponding maximum total quantity per transport unit of dangerous goods that can be carried before having to apply all provisions of ADR. Note however some provisions remain and advice should be sought from a safety adviser.
220.127.116.11.4 of ADR details the provisions, which must be made if goods are to be carried together that are belonging to different Transport Categories.
Other exemptions apply and for a accurate assessment for your business you should contact a safety adviser.
Who is classified as the consignor?
Regulation 2(9) of S.I. No.349 of 2011, defines “consignor” as the person who consigns dangerous goods either on its own behalf or for a third party and shall be construed as -
(i) any person who having a place of business in the State supplies, whether as a principal or agent for another, dangerous goods for carriage by road, or
(ii) if no person satisfies the requirements of clause (i), the consignee of those goods in so far as that person has control over the carriage of those dangerous goods in the State.
Also Regulation 2(9) states if the transport operation is carried out under a contract for carriage, “consignor” means the consignor according to the contract for carriage.
What do I need to do if I want to drive a vehicle that carries dangerous goods?
If you wish to drive a vehicle for the purpose of transport of dangerous goods, you must hold a valid ADR Training Certificate. To obtain the appropriate certificate, you must first attend an approved Basic and/or Tanker Specialisation Driver Training Course and then successfully complete an exam. The management of these examinations was awarded to the Chartered Institute of Logistics, Ireland (CILT) in April 2007. For further information on applying for these exams please follow the link below;
Does the transport of asbestos material come under the ADR?
Yes, though there are some exemptions. A guide to the transport of Asbestos, which deals with classification, carriage in limited quantities, carriage of goods over or below the threshold quantities, packaging and labelling, vehicle equipment and marking, documentation, DGSA and relevant legislation is available from the HSA. See relevant guidance under Class 9 Dangerous Goods.
Are there specific requirements for transporting Ammonium Nitrate based fertilisers?
Yes, some Ammonium Nitrate based fertilisers are classified as “dangerous goods” and therefore the ADR and the 2011 Regulations apply in certain situations.
The driver will require a valid ADR training certificate and other ADR requirements will apply in the following situations:
- The fertiliser is classed as an oxidising substance, Class 5.1 UN 2067
- Calcium Ammonium Nitrate fertiliser that has greater than 80% Ammonium Nitrate (i.e. +>28% N)
The carriage of goods classed as UN 2071 is not subject to ADR and may be carried without restriction.
Are there any exemptions for farmers who transport Ammonium Nitrate based fertilisers by road?
Agricultural or forestry tractors or indeed any mobile machinery can draw any quantity of UN 2067 as these are not ‘Vehicles’ or ‘Transport equipment’ and are therefore exempt by definition under Regulation 2 (1) of SI 349 of 2011.
How do I know what should be contained in spill kits?
Different goods and substances will have a variety of different emergency procedures in the case of spills and leaks. A spill kit is the equipment that must be contained on the vehicle for use in an emergency situation. There is no standard spill kit. Equipment will vary dependant on the goods being carried.. The carrier of dangerous goods must issue instructions in writing/ TREM card (transport emergency card) which specifies the emergency procedures required for the dangerous substances in question as well as personal and vehicle equipment. The carrier must ensure that all equipment necessary to complete these procedures are provided on the vehicle.
What constitutes a Contract for carriage?
Regarding duties of consignors, where a contract for carriage exists, it would be expected that this document would be in the form of a written contract, agreed and duly signed by all implicated participants and would stipulate the terms of the contract of carriage. If the intention of the contract is for the original consignor to bear the duties of consignor throughout the various stages of "re-consignment" and if applicable the return of uncleaned packaging/tanks etc, the extent of that undertaking must be clear and unambiguous within the contract making appropriate reference to the ADR and national regulations as appropriate.
Having no contract for carriage in place automatically re-assigns consignor duties to those in the supply chain according to Regulation 2(9).
If there is no consignor established within the State, who is deemed the consignor?
The Consignee. See Regulation 2(9), SI 349 of 2011.
Do manufacturers who outsource their distribution of high consequence dangerous goods need to address security plan requirements?
Manufacturers who outsource their distribution must still comply with security plan provisions as they are consignors.
Is there guidance on security requirements?
The HSA has no specific guidance on security requirements other than what is stipulated in the ADR. However, there is a number of guidance documents available on the UK Dept. for Transport web site www.dft.gov.uk
The UK Draft guidance on security of dangerous goods publication is a comprehensive guide and may be used when considering specific security plans.
What are the requirements for fire extinguishers for transport units carrying dangerous goods?
Section 8.1.4 of ADR 2011 specifies fire extinguisher requirements for transport units carrying dangerous goods.
The table below outlines the various transport units and the specific fire extinguisher requirements:
- Fire Extinguisher requirements for transport units under ADR regulations
Section 8.1.4 of ADR 2011 specifies fire extinguisher requirements for transport units carrying dangerous goods
|All transport units||Minimum of a 2kg dry powder (or equivalent) extinguisher – suitable for fighting a cab or engine fire.|
|Units with max permissible mass of more than 7.5 tonnes||One or more portable fire extinguisher with minimum total capacity of 12kg dry powder (or equivalent) – at least one extinguisher being minimum of 6kg capacity|
|Units with max permissible mass of more than 3.5 tonnes up to and including 7.5 tonnes||One or more portable fire extinguisher with minimum total capacity of 8kg dry powder (or equivalent) – at least one extinguisher being minimum of 6kg capacity|
|Units with max permissible mass of up to and including 3.5 tonnes||One or more portable fire extinguisher with minimum total capacity of 4kg dry powder (or equivalent)|
|Transport Units exempted under 18.104.22.168||Minimum of a 2kg dry powder (or equivalent) extinguisher – suitable for fighting a cab or engine fire.|
What equipment must be carried on a vehicle carrying dangerous goods?
Equipment requirements for vehicles carrying dangerous goods can be found in the instructions in writing (Tremcard) of ADR, refer to the appropriate link on the HSA ADR web pages -
Outlined below is a list of the 2011 ADR equipment requirements.
2011ADR Miscellaneous Equipment
22.214.171.124 Each transport unit carrying dangerous goods shall be provided with items of equipment for general and personal protection in accordance with 126.96.36.199. The items of equipment shall be selected in accordance with the danger label number of the goods loaded. The label numbers can be identified through the transport document.
188.8.131.52 The following equipment shall be carried on board the transport unit for all danger label numbers:
For each vehicle;
- a wheel chock of a size suited to the maximum mass of the vehicle and to the diameter of the wheel
- Two self-standing warning signs
- Eye rinsing liquid;
and for each member of the vehicle crew;
- A warning vest (e.g. as described in the EN 471 standard)
- Portable lighting apparatus conforming to the provisions of 8.3.4
- A pair of protective gloves; and
- Eye protection (e.g. protective goggles).
184.108.40.206 Additional equipment required for certain classes:
- An emergency escape mask(3) for each member of the vehicle crew shall be carried on board the vehicle for danger label numbers 2.3 or 6.1;
- A shovel(4);
- A drain seal(4);
- A collecting container made of plastics (4).
2 Not required for danger label numbers 1, 1.4, 1.5, 1.6, 2.1, 2.2 and 2.3.
3 For example an emergency escape mask with a combined gas/dust filter of the
A1B1E1K1-P1 or A2B2E2K2-P2 type which is similar to that described in the EN 141 standard.
4 Only required for danger label numbers 3, 4.1, 4.3, 8 and 9.
For fire extinguisher requirements see ADR 8.1.4
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Where can I obtain more information about ADR Examinations?
The organisation dealing with ADR Driver and DGSA Exams is the Chartered Institute of Logistics and Transport (CILT) in Dublin Tel: 1890 252599 or 01-6763188 www.cilt.ie
In what countries can I undertake the ADR driver training?
ADR driver training may be done in the country of any Contracting Party to the ADR agreement, although you must also sit the local exams in which ever country you have attended the training and the resulting (if successful) driver training certificate is valid in any of those countries. There are now 40+ Contracting Parties which includes Ireland and the UK.
Further details can be found on www.unece.org
When do I need ADR driver training or when must I use a trained ADR driver?
You must be or you must use a suitably trained driver certified to drive vehicles carrying dangerous goods subject to national legislation/ADR. As there are exemptions to the rule you must seek expert advice to establish whether formal certification is necessary in your circumstance.
In general all tank vehicle activity requires a driver certified in tanks and in the good being carried. For packaged goods there are thresholds under which a certified driver may not be necessary – this quantity varies depending on the dangerous goods to be carried and expert advice must be sought from a DGSA or from the HSA.
Note it is a legal duty for consignors of dangerous goods to inform the carrier of the nature and quantity of the dangerous goods to be carried.
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What is a DGSA?
A Dangerous Goods Safety Advisor is a person appointed to provide advice, monitor compliance with legal requirements and ensure the preparation of an annual report. The role of a DGSA for carriage by road is specified in ADR 1.8.3
Who needs to appoint a DGSA?
As an undertaking involved in the carriage of dangerous goods by road, whose activities include the carriage, or the related packing, loading, filling or unloading, of dangerous goods by road, subject to some limited exemptions, must appoint a vocationally qualified safety adviser or advisers. Their function is to advise you on health, safety and environmental matters in connection with the carriage of dangerous goods.
The undertakings affected are those:
1. who consign dangerous goods for carriage and who are involved in loading the means of transport;
2. who are operators of road vehicles;
3. who load or unload dangerous goods while they are in transit to their final destination, such as freight forwarders or warehouses. This category also covers undertakings at ports and airports that load/unload dangerous goods onto/off road vehicles, but does not include consignees who only unload at the final destination (e.g. petrol station operators or supermarkets).
What exemptions exist from the requirement to appoint a DGSA?
There are some exemptions from the obligation to appoint a Dangerous Goods Safety Adviser - for full detail refer to Guidance on the appointment of a DGSA.
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