By Caroline Raine, Chairman of the British Association of Dangerous Goods Professionals.
In Great Britain the legal requirements for the transport of dangerous goods are set out in the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (“CDG 2009”), SI 2009 No 1348 which came into force on 1 July 2009.
The CDG Regulations implement the European Agreement Concerning the International Carriage of Dangerous Goods by Road, otherwise known as ADR, and ADR 2019 is the current version that is in use.
ADR is split into 9 different parts;
Part 1. Aims and duties, definitions, exemptions, training.
Part 2. Classification.
Part 3. The dangerous goods list (including special provisions and exemptions related to limited quantities).
Part 4. Packing and tank provisions.
Part 5. Consignment procedures, including documentation and vehicle marking.
Part 6. Construction and testing of packagings, intermediate bulk containers (IBC), large packagings and tanks.
Part 7. Carriage, loading, unloading and handling.
Part 8. Vehicle crews, equipment, operation and documentation (including driver training).
Part 9. Construction and approval of vehicles.
The Department for Transport (DfT) is the competent authority for Great Britain and has agreed several variations from ADR which are laid out in a DfT Approved Document – Carriage of Dangerous Goods: Approved Derogations and Transitional Provisions (ADTP). In the ADTP companies may take advantage of the reduced legal requirements, saving them both time and money.
For example, Road Derogation 2 provides an exemption from the need to carry transport documents. This is only relevant when goods are being transported under the small load exemption as defined in ADR 220.127.116.11 but is nevertheless a well-used exemption saving companies considerable sums of money, and trees due to the reduction in paperwork being generated!
Within ADR there are a few relaxations and exemptions that companies can also benefit from, for example the small load exemption in ADR 18.104.22.168. There is also the option to send goods as limited quantities; if the goods meet the requirements then money is to be saved on packaging. For extremely small quantities of goods being sent there is the excepted quantities or “de minimis quantities”, and many dangerous goods have special provisions that relax the requirements.
To benefit from the reduced requirements companies should seek advice from their Dangerous Goods Safety Advisor (DGSA) who will be best placed to offer advice and assistance.
Transporting dangerous goods is a complicated affair, the regulations are complex, detailed and have so many different rules to adhere to. When transporting dangerous goods, the goods must be correctly classified, then there are the packaging, labelling, marking and documentation requirements to be considered. And that is just for packaged goods, for bulk shipments placarding also needs to be considered. Then there are the requirements for equipment and training, and already we have quite a list and I haven’t really got started yet!
Fortunately, there are lots of places to seek help and assistance. The first port of call must be the Dangerous Goods Safety Advisor (DGSA) and if your company does not already have one then one should be appointed asap as it is a legal requirement to have a DGSA under ADR 1.8.3 (there are of course some exceptions!)
The British Association of Dangerous Goods Professionals (BADGP) is a not-for-profit organisation that is there to support DGSAs and those who transport dangerous goods. BADGP produce regulatory updates and newsletters and host regular seminars and webinars on key topics. Each year they hold their annual general meeting (AGM) with topical presentations on key regulation changes or other relevant hot topics.
The Chemical Hazard Communication Society (CHCS) is another not-for-profit organisation who support those who write safety data sheets, and deal with the regulations related to the supply of chemicals, for example, Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures (CLP).
CHCS also supports its members through regulatory updates, newsletters, seminars and webinars and an AGM that follows a similar format to BADGP’s. CHCS also offer a suite of training modules to help safety data sheet authors and of interest to those who transport dangerous goods will be module 8 – classification for transport and module 10 Transport Labelling and Documentation (10.208).
Chairman of BADGP, Council member of CHCS,
Trainer on CHCS modules 8 and 10.
British Association of Dangerous Goods Professionals, BADGP
Chemical Hazard Communication Society CHCS
www.chcs.org.uk, t: + 44 (0) 333 210 2427, e: email@example.com