ADR Specific

  • Who is responsible for the classification of ADR dangerous goods?
  • As part of my job, I am required to carry 500ml of Hypochlorite solution in my car. Does this come under the provisions of ADR?
  • For consignment of hazardous wastes can the new Waste Transfer Forms(WTF) (replacing the old C1 document) under the Waste Management Regulations be used as the ADR transport document?
  • Company 'A' purchases bitumen (UN3257) from Company 'B' (the manufacturer) and arranges to have the bitumen transported to a number of destinations in Ireland. They (Co. 'A') employ haulage contractors to carry out the transports and do not operate any of their own vehicles on this work. The haulage contractors go to Company 'B' and the drivers fill the tankers with the bitumen themselves. Company 'B' supplies the Transport Document and Tremcard to the driver. Does Company 'A' require a DGSA?
  • Under ADR or other HSA legislation if I am not carrying dangerous goods do I need a fire extinguisher on the vehicle?
  • If I am carrying flammable liquids in a curtain-sided vehicle on a national journey can I put the flammable liquid placards on both sides and rear of the vehicle as an additional warning to the emergency services in the event of an accident?
  • If a company changes it's name can it continue to use it's stock of Tremcards with the old company name crossed out and the new name written in?
  • Do consignors/carriers have the option of displaying orange plates when the vehicles are carrying packages containing quantities of dangerous goods below the threshold levels detailed in Chap. 1.1.3.6 when various exemptions are available to them, or must they comply with the lesser provisions referred to in Chap 1.1.3.6 such as not display orange plates?
  • If drivers are operating trucks that weigh less than 3.5 tonnes, but are still carrying chemicals, do the drivers still require ADR training under the current legislation?
  • Is the transport of diesel fuel in a fuel bowser regulated by ADR?
  • Does ADR cover the transport of insecticide-treated plants if the plants have been allowed to dry?
  • A cultured human cell line has been genetically modified to produce a component of an in-vitro diagnostics bioassay, i.e. it is a genetically modified organism (GMO). Because these cells only survive under strict culture conditions, a risk analysis has concluded that the possibility of altering the genetic material of animal plants or micro-organisms is remote, suggesting that the cells do not need to be transported under UN3245, based on the classification criteria.
    However, under EU directive 90/219/EEC on the use of GMO's, they are classified as Class I, which is the lowest standard of contained use. To be consistent with this classification, should the cells be transported under UN 3245?
  • At some loading bays, drivers are not allowed access to the back of the lorry when loading is taking place. In many cases, the doors are sealed and the driver is not permitted to inspect the load. As the driver has responsibility for the security and storage of the load, what is the HS A's position on this activity?
  • Community-based nurses generate clinical waste as part of their job. This waste (UN 3291, Clinical waste, unspecified, NOS, 6.1, II) is transported back to their job base in UN approved plastic rigid packaging. Is this activity exempt from the requirements of ADR?
  • Business A holds a permit to collect paper, CD's, discs, etc. Recently, there have been some requests to remove office electronic equipment, such as PCs, printers, cables and monitors, to bring to a recycling plant. However, some items may contain HCFC, batteries, etc. Is it necessary to appoint a DGSA and employ an ADR certified driver before collecting these items?
  • Who are the enforcement bodies/competent authorities for transport of dangerous goods by the various modes - road, sea and air?
  • Should Thermoplastic cold mix powder be classified as Class 9 as it is heated in a tank vehicle to 200oC for application to roads?
  • How much diesel can be carried without ADR training?
  • Does the transportation of Biodiesel fuel, made from pure plant oil (PPO) and recovered vegetable oil, come under the ADR Regulations?
  • Where can I find the appropriate labels and markings for dangerous goods under the ADR Regulations?
  • What is the position regarding the transporting of dangerous goods to and from Northern Ireland in tank vehicles?
  • Is a Vehicle Certificate of Approval required for vehicles exclusively carrying dangerous goods by road packed as Limited Quantities?

Who is responsible for the classification of ADR dangerous goods?
The consignor of the goods.

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As part of my job, I am required to carry 500ml of Hypochlorite solution in my car. Does this come under the provisions of ADR?
If you are required to carry Hypochlorite solution in your car, your employer should ensure that a full risk assessment for the activity is carried out by a competent person, including emergency action measures in the event of a spillage of the substance in the car. You should be given a copy of the Safety Data Sheet [SDS]. Check SDS Section 14. Is the substance classified as Dangerous Goods for transport by Road [for ADR purposes]?

If it is, then you will have to refer to a qualified Dangerous Goods Safety Advisor (DGSA) who will advise on how much can be carried without ADR provisions applying.

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Can the new Waste Transfer Forms(WTF) (replacing the old C1 document) under the Waste Management Regulations be used as the ADR transport document?

Yes, but as was the case with the old C1 form, all the relevant information which makes up an ADR transport document must be included on or attached to the new WTF otherwise a separate ADR transport document must be prepared. You may need advice from a DGSA to ensure compliance.

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Company 'A' purchases bitumen (UN3257) from Company 'B' (the manufacturer) and arranges to have the bitumen transported to a number of destinations in Ireland. They (Co. 'A') employ haulage contractors to carry out the transports and do not operate any of their own vehicles on this work. The haulage contractors go to Company 'B' and the drivers fill the tankers with the bitumen themselves. Company 'B' supplies the Transport Document and Tremcard to the driver. Does Company 'A' require a DGSA?
No. Company 'A' is the customer (the consignee) and does not require a Dangerous Goods Safety Adviser(DGSA). Company 'B' and the haulage contractors would require their own DGSA's. For further information on DGSA requirements see relevant guidance on the HSA website - ADR web pages.

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Under ADR or other HSA legislation if I am not carrying dangerous goods do I need a fire extinguisher on the vehicle?
No. A fire extinguisher is not mandatory under current HSA legislation but a 2Kg dry powder extinguisher on the vehicle would be recommended for dealing with small fires and this should be readily accessible and inspected annually.

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If I am carrying flammable liquids in a curtain-sided vehicle on a national journey can I put the flammable liquid placards on both sides and rear of the vehicle as an additional warning to the emergency services in the event of an accident?
No. Only blank orange plates should be fitted at the front and rear of the vehicle unless you are transporting a container in which case the diamond-shaped placards for each Class would also need to be affixed at the front, rear and both sides of the container. Placards would be required on both sides and rear of a curtain-sided vehicle if it was transporting a tank (>1000 litres) on-board, in which case numbered orange plates would also be required at front and rear of the vehicle instead of blank plates.

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If a company changes it's name can it continue to use it's stock of "Tremcards" with the old company name crossed out and the new name written in?
Yes. Although note the new ADR instructions in writing (or Tremcard) may not be altered in terms of form and contents.

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Do consignors/carriers have the option of displaying orange plates when the vehicles are carrying packages containing quantities of dangerous goods below the threshold levels detailed in Chap. 1.1.3.6 when various exemptions are available to them, or must they comply with the lesser provisions referred to in Chap 1.1.3.6 such as not display orange plates?
Yes they have the option. Consignors/carriers can opt not to avail of the exemptions provided for in Chap. 1.1.3.6, however, if they do so then they must comply fully with ADR i.e. Trained Driver, Instructions in Writing, Security, etc.

The exemptions provided for in Chap 1.1.3.6 can in practice only be availed of by a consignor who supplies a ‘Full Load or otherwise has exclusive use of the vehicle for that partially exempted journey. A carrier cannot transport packages from two or more consignors availing of exemptions under Chap. 1.1.3.6 if the total quantity on the transport unit exceeds the quantity limits specified in Chap. 1.1.3.6.

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If drivers are operating trucks that weigh less than 3.5 tonnes, but are still carrying chemicals, do the drivers still require ADR training under the current legislation?
Yes. The provisions of Chapter 8.2.1.1 of ADR were amended in 2005 to require all drivers of dangerous goods vehicles, regardless of maximum permissible gross mass of the vehicle, to hold an ADR driver training certificate, if the quantity of dangerous goods carried exceeds the thresholds set out in chap. 1.1.3.6. This provision is applicable from Jan 1, 2007, with a six month transitional period. However, under ADR, all persons involved in the transport of dangerous goods must receive training appropriate to their responsibilities. ADR driver training certificates are issued by CILT (www.cilt.ie).

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Is the transport of diesel fuel in a fuel bowser regulated by ADR?
The HSA are currently considering issuing a national exemption/approval to regulate the use of fuel bowsers for the transport of certain Dangerous Substances listed in ADR. This will include Diesel fuel UN1202. Such an exemption/approval would be conditional and time-limited.

Up to the present time, fuel bowsers are not defined in ADR. Debate is still ongoing at an international level to agree on whether bowsers fall into the category of tanks or packages [Intermediate Bulk Containers (IBCs)]. However, the HSA have been in discussion with our UK counterparts on this matter and support their position that certain fuel bowsers can be deemed IBCs, provided they comply with an IBC specification and certain additional requirements. The UK regulatory body (HSE) has issued an authorisation to this effect.
The HSA's approach will be similar to the one prescribed by the HSE, with a time limit. The time limit prescribed will be dependent on how likely it will be that fuel bowsers will come under the scope of the ADR in the future.

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Does ADR cover the transport of insecticide-treated plants if the plants have been allowed to dry?
Plants that have been treated with insecticide, where the insecticide has been absorbed and the plants have been allowed to dry, would not be classified as dangerous goods for transport purposes in which case ADR would not apply to the transport of the treated plants by road.

The Pesticide Control section of the Department of Agriculture should be contacted regarding specific insecticide queries.

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A cultured human cell line has been genetically modified to produce a component of an in-vitro diagnostics bioassay, i.e. it is a genetically modified organism (GMO). Because these cells only survive under strict culture conditions, a risk analysis has concluded that the possibility of altering the genetic material of animal plants or micro-organisms is remote, suggesting that the cells do not need to be transported under UN 3245, based on the classification criteria.

However, under EU directive 90/219/EEC on the use of GMO's, they are classified as Class I, which is the lowest standard of contained use. To be consistent with this classification, should the cells be transported under UN 3245?

Articles 14 to 29 of the Genetically Modified Organisms (Contained Use) Regulations (S.I 73 of 2001) do not apply to the transport of GMO's in accordance with the provisions of Article 11(2) of the regulations. Therefore, the measures for level 1 containment for a Class 1 GMO as set out in the Fourth Schedule of the regulations are not relevant.

Hence, it depends whether the assessment of the risks to human health and the environment, as required by Article 13, shows the GMO to be classifiable as a dangerous substance in accordance with ADR criteria. If this assessment shows that this particular GMO is not capable of “altering animals, plants or microbiological substances in a way not normally the result of natural reproduction”, which is the criteria specified in ADR Chapter 2.2.9.1.11, then this GMO would not be subject to ADR. However, if the risk assessment does not conclude that this is indeed the case, then it should be classified, under Class 9, UN3245.

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At some loading bays, drivers are not allowed access to the back of the lorry when loading is taking place. In many cases, the doors are sealed and the driver is not permitted to inspect the load. As the driver has responsibility for the security and storage of the load, what is the HSA's position on this activity?
In the event of an incident involving the load, in such cases, the HSA would hold the loader/consignor fully responsible for the condition of the load. The driver may be required to give a written statement on the situation for possible legal proceedings against the loader/consignor. Also, the carriage of dangerous goods regulations have an on the spot fine for the loader/consignor for failure to comply with the requirements in Chapter 7.5.7.1 and 7.5.7.2 of the ADR concerning handling and stowage of dangerous goods.

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Community-based nurses generate clinical waste as part of their job. This waste (UN 3291, Clinical waste, unspecified, NOS, 6.1, II) is transported back to their job base in UN approved plastic rigid packaging. Is this activity exempt from the requirements of ADR?
Yes. ADR 2009 Chapter 1.1.3.1 (c) states that the provisions laid down in ADR do not apply to the carriage undertaken by enterprises which is ancillary to their main activity. As UN 3291 comes under transport category 2, a maximum quantity of 333kgs/litres may be carried per packaging and per vehicle.

However, to avail of this exemption, measures must be taken to prevent any leakage of contents in normal conditions of carriage in accordance with ADR Chapter 1.1.3.1 (c).

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Business A holds a permit to collect paper, cd's, discs, etc. Recently, there have been some requests to remove office electronic equipment, such as PCs, printers, cables and monitors, to bring to a recycling plant. However, some items may contain HCFC, batteries, etc. Is it necessary to appoint a DGSA and employ an ADR certified driver before collecting these items?
There is a specific exemption in the current ADR 2009, Chapter 1.1.3.1 (b), which covers such equipment. It states that the provisions laid down in ADR do not apply to the carriage of machinery or equipment not specified in this Annex (ADR) and which happens to contain dangerous goods in their internal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage.

As PCs, monitors, printers and cables are not specified in ADR, they are not classified as dangerous goods under ADR and therefore it is not required to have a Dangerous Goods Safety Advisor (DGSA) appointed, nor is it required to engage an ADR certified driver to transport such items, and vehicles carrying those goods do not need to display an ADR orange plate at the front and rear of the vehicle.

In future, if it is decided to transport articles or substances which come under Class 9, e.g. UN3090 lithium batteries, packing group II, transport category 2, up to 333kgs may be transported without requiring the services of a DGSA or engaging an ADR certified driver to transport such quantities.
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Who are the enforcement bodies/competent authorities for transport of dangerous goods by the various modes - road, sea and air?

  • Transport by Road - HSA
  • Transport by Sea - Dept. of Transport, Marine Survey Office
  • Transport by Air - Irish Aviation Authority

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Should Thermoplastic cold mix powder be classified as Class 9 as it is heated in a tank vehicle to 200oC for application to roads?


No. Examination of the material safety data sheet for thermoplastic cold mix powder reveals that this substance is classified as non-hazardous for transport purposes. It is noted that this solid substance is heated on location in order to apply it to the road as a line marker as the vehicle moves slowly along the road (extrusion temperature 200oC). This is viewed as being heated for use rather than for transport and are of the opinion that it should not be classified as Class 9 as the substance is a solid which is not carried or handed over for carriage at or above 240oC. (Ref. ADR 2009 Chap. 2.2.9.1.13)

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How much diesel can be carried without ADR training?


Diesel, UN 1202, ADR Class 3 can be carried without full provisions of ADR applying in the following circumstances:

  • when carried in ADR packagings [UN approved drums, IBC's, containers], up to 1000L maximum total quantity per transport unit can be carried, as prescribed in Chapter 1.1.3.6 of ADR. These must be carried in line with packing instruction laid down in 4.1.4 of ADR.
  • when carried in Limited Quantities in accordance with provisions in ADR 3.4.3 to 3.4.6, up to 5L per packaging can be carried without full provisions of ADR applying. provided general provisions in 4.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 are complied with.

Staff engaged in the transport of dangerous substances must, however, receive appropriate training commensurate with their specific job, and training records kept, as required under the Safety Health and Welfare at Work Act 2005. This training should include hazard awareness, appropriate handling precautions, personal protective equipment and emergency action measures.

It is advisable to consult with a competent Dangerous Goods Safety Adviser who can advise on the specific aspects of the transport of Diesel by road, as it relates to each specific business.

Details of the 2009 ADR can be found online at www.unece.org.

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Does the transportation of Biodiesel fuel, made from pure plant oil (PPO) and recovered vegetable oil, come under the ADR Regulations?
Biodiesel classification for ADR purposes is based primarily on the flashpoint of the liquid and conditions of carriage. As it has a flashpoint above 600C and is carried at ambient temperature, it is not a substance of ADR Class 3 is not classified as hazardous for transport.

However, as this is an oil, environmental implications will also have to be taken into account, in particular the potential as an aquatic pollutant. Criteria in this regards can be found in Chapter 2.2.9 of 2009 ADR. Text of ADR can be found at www.unece.org.

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Where can I find the appropriate labels and markings for dangerous goods under the ADR Regulations?
Chapters 5.2 and 5.3 of the 2009 ADR show model labels for Class 1 to Class 9 dangerous goods and also other marks required for transport by road. Commercial providers of labels and marks may be found by entering "ADR labels" in to a search line on the internet.

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What is the position regarding the transporting of dangerous goods to and from Northern Ireland in tank vehicles?

Tankers operating between the Republic of Ireland and Northern Ireland must obtain an annual international ADR vehicle certificate of approval. This certificate is only available to vehicles designed and constructed to ADR standards. All tank vehicles constructed post July 2003 must meet this requirement as well as some older vehicles that typically operate internationally. Older existing vehicles, pre July 2003, not meeting ADR standards are restricted to national use only.

However, it is recognised that due to current legislative problems, vehicles constructed after July 2003 may experience difficulties in obtaining an annual international ADR approval certificate. Until these issues are resolved, it has been agreed by the Road Safety Authority that these vehicles may be provided with national vehicle certificates of approval and may, by agreement with the relevant authorities in Northern Ireland, operate between the Republic of Ireland and Northern Ireland.

The Road Safety Authority is the competent authority in Ireland for the issue of ADR vehicle certificates of approval. For further information on ADR vehicle certificates of approval, contact the Road Safety Authority, www.rsa.ie

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Is a Vehicle Certificate of Approval required for vehicles exclusively carrying dangerous goods by road packed as Limited Quantities?

Limited Quantities provisions are found in Chapter 3.4 of the 2009 ADR agreement.

A vehicle certificate of approval is not required for vehicles only used to exclusively carry dangerous goods packed as limited quantities. Specific provisions still apply to packaging type and packaging marking as given in Chapter 3.4.

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