ADR Specific FAQs

  • I use my car to transport semen straws (biological specimens) to farms to carry out artificial insemination. The straws are stored in flasks containing liquid nitrogen. What provisions apply under ADR?

  • 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 using haulage contractors (they do not operate their own vehicles). The haulage contractors go to Company 'B' and the drivers fill the tankers with the bitumen themselves. Company 'B' supplies the Transport Document and instructions in writing to the driver. Does Company 'A' require a DGSA?
  • 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?
  • 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 ADR 1.1.3.6 when various exemptions are available to them, or must they comply with the lesser provisions referred to in ADR 1.1.3.6 such as not display orange plates?
  • 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?
  • A business collects household appliances and some office electronic equipment, to bring to a recycling plant. However, some items may contain dangerous goods such as batteries. Is it necessary to appoint a DGSA and employ an ADR certified driver before collecting these items?
  • 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?
  • Are biofuels dangerous goods?
  • Is a Vehicle Certificate of Approval required for vehicles exclusively carrying dangerous goods by road packed as Limited Quantities?

 

I use my car to transport semen straws (biological specimens) to farms to carry out artificial insemination. The straws are stored in flasks containing liquid nitrogen. What provisions apply under ADR?

Liquid nitrogen is classified as UN No. 1977, NITROGEN, REFRIGERATED LIQUID, Class 2, Classification code 3A.

It has a special provision (SP) regarding its use for the cooling of medical or biological specimens (SP 593). Under this special provision, the requirements of ADR do not apply, except as specified in ADR 5.5.3, if the nitrogen is transported in double wall receptacles, which comply with the provisions of packing instruction P203, paragraph (6) for open cryogenic receptacles of 4.1.4.1.

 The ADR defines ‘open cryogenic receptacle’ as 'a transportable thermally insulated receptacle for refrigerated liquefied gases maintained at atmospheric pressure by continuous venting of the refrigerated liquefied gas'.

 To comply with the requirement of paragraph (6) of packing instruction P203, the receptacle should be of glass double wall construction with an outer packaging containing suitable cushioning or absorbent materials, which withstand the pressures and impacts liable to occur under normal conditions of carriage.

 We recommend that you consult with a DGSA for advice on the provisions of ADR 5.5.3, special provisions applicable to packages and vehicles and containers containing substances presenting a risk of asphyxiation when used for cooling or conditioning purposes.

See our website for further information on a DGSA and DGSA Services.


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. Section 14 of the safety data sheet should be checked to see if it is classified under ADR.

If it is, you should contact a DGSA for advice, who will advise on how much can be carried without all of the ADR provisions applying.

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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?

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 using haulage contractors (they do not operate their own vehicles). The haulage contractors go to Company 'B' and the drivers fill the tankers with the bitumen themselves. Company 'B' supplies the Transport Document and instructions in writing to the driver. Does Company 'A' require a DGSA?
No. Company 'A' is the customer (the consignee) and does not require a DGSA. Company 'B' and the haulage contractors would require their own DGSAs.

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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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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 ADR 1.1.3.6 when various exemptions are available to them, or must they comply with the lesser provisions referred to in ADR 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 ADR 1.1.3.6, however, if they do so then they must comply fully with all of the ADR provisions.

The exemptions provided for in ADR 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 ADR 1.1.3.6 if the total quantity on the transport unit exceeds the quantity limits specified in ADR 1.1.3.6.  Note that ADR 5.4.1.1.1 (f) states that 'in the case of intended application of 1.1.3.6, the total quantity and the calculated value of dangerous goods for each transport category shall be indicated in the transport document in accordance with 1.1.3.6.3 and 1.1.3.6.4'. 

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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 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 333 kg/L 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 1.1.3.1 (c).

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A business collects household appliances and some office electronic equipment to bring to a recycling plant. However, some items may contain dangerous goods such as batteries. Is it necessary to appoint a DGSA and employ an ADR certified driver before collecting these items?

PCs, monitors, printers and cables are not classified as dangerous goods under ADR and therefore there is no requirement to appoint a DGSA or to engage an ADR certified driver to transport such items.

There are two specific provisions in ADR for the carriage of appliances and equipment from private households.  ADR Chapter 3.3 special provision 670 defines 'equipment from private households' as 'equipment which comes from private households and equipment which comes from commercial, industrial and other sources which, because of its nature and quantity, is similar to that from private households.  Lithium cells and batteries installed in equipment from private households collected and handed over for carriage for depollution, dismantling, recycling or disposal are not subject to the provisions of ADR under the conditions of the special provision.  ADR 1.1.3.10 exempts lamps that are collected directly from individuals and households when carried to a collection of recycling facility provided they do not contain radioactive material or mercury in quantities of >1Kg.

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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, IBCs, containers], up to 1000L maximum total quantity per transport unit, as prescribed in 1.1.3.6 of ADR. These must be carried in compliance with ADR 4.1.4.
  • When carried in Limited Quantities in accordance with the provisions in ADR Chapter 3.4, provided general provisions in 4.1.1.1, 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. This training should include hazard awareness, appropriate handling precautions, personal protective equipment and emergency action measures.

It is advisable to consult with a DGSA who can advise on the specific aspects of the transport of diesel by road, as it relates to each specific business.

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Are biofuels dangerous goods?
Depending on various factors (e.g. the quantity of the bio element of the fuel, flash point of mixtures), biofuels may or may not be classified as dangerous goods for transport.  The consignor must classify the fuel in accordance with Part 2 of the ADR (Chapters 2.1, 2.2 and 2.3).

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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. In practice, most biodiesels have a flashpoint greater than 1000C and are thus 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 ADR Chapter 2.2.9.

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

No, a vehicle certificate of approval is not required for vehicles used exclusively to carry dangerous goods packed as limited quantities. Specific provisions still apply to packaging type and packaging marking as given in ADR Chapter 3.4.

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