ADR Specific

  • What ADR provisions apply to a person carrying out artificial insemination on farms, stores semen straws (biological specimens) in flasks containing liquid nitrogen to maintain the semen quality, and thus carries such flasks by road to farms?
  • 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?
  • 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 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?
  • 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?
  • 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?
  • 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?
  • Are biofuels dangerous goods?
  • Where can I find the appropriate labels and markings for dangerous goods under the ADR Regulations?
  • Is a Vehicle Certificate of Approval required for vehicles exclusively carrying dangerous goods by road packed as Limited Quantities?

 

What ADR provisions apply to a person carrying out artificial insemination on farms, stores semen straws (biological specimens) in flasks containing liquid nitrogen to maintain the semen quality, and thus carries such flasks by road to farms?

 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. 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 all of the 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 DGSAs. For further information on DGSA requirements see relevant guidance on our ADR web pages.

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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 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 all of the ADR provisions.

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.  Note that ADR 5.4.1.1.1 (f) now 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. 

The ADR is available in soft copy on the UNECE website.

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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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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?

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.

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.

The ADR is available in soft copy on the UNECE website.

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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. The cold mix powder 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 Chapter 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, as prescribed in Chapter 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 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, 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.

The ADR is available in soft copy on the UNECE website.

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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.

The ADR is available in soft copy on the UNECE website.

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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 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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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 ADR Chapter 3.4.

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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