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 be in a box or shrink-wrapped tray. Retail distribution of LQ packages that have been “broken down” is allowed, subject to certain conditions (see Transport Documents page within this section). 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”.
The limited quantity mark is:
or if an air mode journey is involved
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 30kg. 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 5.2.1.10 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 3.5.1.2 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 packaging up to 30g or 30ml in outer packaging with 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.
* – (first) label number of the goods
** – name of the consignor or consignee if not shown elsewhere on the package
Small load exemptions (ADR 1.1.3.6)
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 1.1.3.6.3 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:
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 1.1.3.6.4 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 1.4.2.1.1 (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 |
| 7.5.11 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 Driver training | 8.1.2.1 (a) and (c) (documentation) but note GB exemption in Regulation 29 8.1.4.2 to 8.1.4.5 fire extinguisher for cab (but note transition period in ADR at 1.6.5.6) 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 |
Source – Health and Safety Executive
