Health and Safety
Executive / Commission
Carriage of dangerous goods
1. This part of ADR covers most of the matters that the carrier has to deal with, and includes:
2. Regulations 63 and 64 are the basis for implementing ADR. The regulations refer directly to various sections of part 8 of ADR.
3. Regulation 63 is broken into paragraphs as follows:
4. Regulation 64 is concerned with driver training.
5. 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. Many of those duties are little changed from what was required under CDG 96 and CDG(DT) 96.
6. Some duties refer to "transport unit" and some to vehicles. The transport unit may be one vehicle or may be comprised of 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. Vehicle is defined in Article 1 and in part 9 of ADR.
7. ADR chapter 8.1 covers equipment and documentation. This is grouped in three main parts:
8. There are cross references to other parts of ADR where the details of documentation are given (ADR 5.4.1).
9. The list below summarises the main documentation requirements (see also Consignment procedures for more details):
i. “Transport documents” which should include
ii. “Instructions In Writing” (emergency information)
10. Note that the TREMCARD© (TRansport EMergency CARD) which was developed by CEFIC in the mid-1980s to comply with the emergency information requirement is only one way of doing so. As long as the Instructions in Writing contain the information that is set out in ADR at 5.4.3 and which is valid for the substance(s) being carried then the requirement is met. Although the information should include first aid advice, there is no requirement (under this legislation) for first aid equipment to be carried.
11. 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.
Enforcement would be framed around Regulation 63(7).
12. ADR para 8.1.4 concerns fire extinguishers. The new ADR 2007 provisions came into force on 1 Jan 2008. The table below sets out a summary of the current minimum requirements. Enforcement would be framed around Regulation 63(5).
| Vehicle | Minimum dry powder fire extinguisher provision |
|---|---|
| Up to 3.5 t | 2 kg for cab plus 2 kg |
| Over 3.5 t and up to 7.5 te | 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 te | 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 |
13. Para 8.1.5 refers to "miscellaneous equipment". This is a substantial difference from the 1996 regulations. 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). However, authorisation 24 permits GB registered "transport units" on domestic journeys to carry one suitable wheel chock, even if there are two vehicles forming the unit. There is no prescription as to where wheel chocks are to be carried. Information about the suitability of wheel chocks may be found on the VOSA web site at Q13. A discussion on enforcement issues is in para 8 of Annex 3.2 in Operational strategy.
14. Under this heading also come:
15. Chapter 8.2 of ADR covers driver training. ADR 2005 has changed driver training requirements. Note that the term VTC is no longer used. The term "ADR Training Certificate" fits well with the wording of ADR at 8.2.2.8 and the model certificate shown at 8.2.2.8.3.
16. The table below summarises the requirements which applied from 1 January 2007.
| Vehicle /load | Driver training | ADR Reference |
|---|---|---|
| All vehicles except those carrying packages under the load limit. | 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.) |
8.2.1 |
| Any vehicle carrying packaged dangerous goods under the “small load” limit | General training | 8.2.3 (refers to chapter 1.3) ADR 1.1.3.6 |
| Vehicle with small tank (up to 1 m3) | General training | 8.2.1.3 8.2.3 |
17. ADR chapter 1.3 gives the details of the "general training". The requirement for carriers to keep a record of training is now in ADR 1.3.3.
18. Enforcement would be framed around Regulation 63(7).
19. Drivers are required to carry their training certificates. See regulation 24(6).
20. Information on the training schemes may be found on DfT's website.
21. When checking a driver's training certificate, Inspectors should ensure that:
22. 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.
23. ADR 8.3 covers a number of simple and obvious precautions. Enforcement would be framed around regulation 63(7). These duties fall on the carrier and the crew (usually the driver, but in some cases a second person).
24. ADR 8.4 includes supervision of vehicles. This applies where special provisions S14 to S21 appear in column 19 of Table A. Again regulation 63(7) is relevant.