Transport Documentation

For small loads (ADR 1.1.3.6), there is no need in GB to carry the transport documentation except for explosives and radioactive materials. See also limited quantities page within this section 

The need for the consignor to provide transport documentation to the carrier remains (ADR 1.4.2.1.1(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 (eg 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.

Source – HSE

Instructions in Writing

The carrier has to provide ADR instructions in writing to the driver. This means that the full 4-page document, regardless of how many classes you carry, must be provided, as it is a single entity.

You may add an additional page if you wish to do so, but it must not be inserted into the body of the 4-page document. Any further information that you wish to provide to the driver must be provided on a separate page.

To view the ADR instructions in writing, please use the link below.

ADR instructions in writing – GOV.UK (www.gov.uk)

If you employ non-English speaking drivers, you have to provide the instructions in writing in a language that they will understand. You can download other versions in different languages from the UNECE website.

Amending ADR instructions in writing

You cannot amend the instructions in writing as the statements have been agreed and translated into other languages.

You cannot replace the dashes with numbers as this could imply there is a mandatory sequence of actions. Some of these actions may not be required on every occasion.

You can add your company or trade association logo and it will be accepted in Great Britain as long as the logo does not obscure the text or make it smaller. However, we do not know how other countries’ enforcement authorities will treat such changes. If you operate internationally, we suggest you do not add logos as you could run the risk of attracting fines.

Reproducing ADR instructions in writing

You do not have to reproduce the instructions on 4 pieces of paper. The instructions can either be printed on 4 pieces of paper or on 2 pieces front and back.

EU countries are reproducing theirs in exactly the same format as that in ADR, so to mitigate the risk of attracting fines when on an international journey, we recommend you play safe and stick to 4 pages as per ADR.

The ADR regulations state that the instructions in writing must be able to be read and understood by the vehicle crew but it does not prescribe the paper size to use. British enforcement authorities as a minimum will accept all four pages printed on two sides of A4 as long as the required text and symbols are legible.

Displaying ADR instructions in writing

If you are not carrying dangerous goods, your vehicle should not be displaying placards or placards should be covered up.

To avoid any risk of confusion in the event of a road traffic accident, we suggest you put the instructions in writing in the glove box or out of sight.

If you take them out the vehicle, remember to give them back to the driver the next time you use the vehicle to move dangerous goods.

Equipment

The list of equipment states that a drain seal is required if carrying goods with danger labels 3, 4.1, 4.3, 8 and 9. ADR does not specify what a drain seal is. We suggest the following options:

• strong plastic sheeting, held in place by sand, sand bags or by using a shovel to put soil or similar over the sheet
• specially made drain seals which are available commercially

British enforcement authorities will accept a “sausage” of absorbent material, which is sufficient in size to place round a drain opening to absorb/divert any spillage. Commercially available “spill kits” often include such items.

The list of equipment states that a collecting container is required if carrying goods with danger labels 3, 4.1, 4.3, 8 and 9. The container does not need to be UN approved. The container can range from a bag to a bucket so long as it is capable of dealing with a spillage. The container should not soften or be damaged by the substance to be carried in it.

The equipment required for certain classes state that a shovel is required for goods with danger labels 3, 4.1, 4.3, 8 and 9. ADR does not specify any requirements for a shovel but it should ideally be made of plastic and have upturned sides.

The additional guidance table shows that divisions 6.1 and 6.2 have the hazard characteristics “risk to the aquatic environment and the sewerage system”.

There is no requirement to carry a drain seal and bucket for divisions 6.1 and 6.2 substances as well as to prevent leaking substances from getting into the aquatic environment or sewerage system.

Whilst the list of equipment to be carried on page 4 of the instructions in writing is mandatory, pages 2 and 3 are guidance. This guidance serves as a reminder to the driver. It is not intended to correlate with the list of equipment to be carried.

Additional equipment

You may provide additional equipment on your vehicles if you wish, but you should be aware that drivers are not expected to act as quasi-emergency responders and that if extra equipment is provided, drivers should be fully aware of what you expect them to do with it and be provided with full training in its use.

If the training that the driver has received means that, where safe and appropriate to do so, they are able to prevent leakages getting into the aquatic environment or sewerage system and contain leaks of substances in division 6.1 and 6.2 by using a collecting container and or a drain seal, that is laudable.

You should be aware, however, of potential new hazards that may arise. For example, there might be more danger in a driver trying to deal with the leak of a toxic substance or some substances may react dangerously with the material used for the container.

There is no rule about where on the vehicle equipment is kept. You should keep the bucket and other equipment wherever it is convenient and easy for the driver to access. Pre-journey checks should ensure that the right equipment is on the vehicle.

Legal information

This information is based upon the interpretation of the GB competent authority. This guidance note should not be taken as a complete or definitive statement of the law. It is not intended as a substitute for detailed legal or other professional advice based on specific circumstances. The Department for Transport accepts no liability for any loss or damage caused by reliance on the contents of this guidance note.

In international carriage, competent authorities of other states may have a different interpretation of dangerous goods regulations.

Source – Dept. for Transport