Health and Safety
Executive / Commission
Carriage of dangerous goods
Exemptions arise in three ways,
1 ADR itself has exemptions set out in part 1.1.3. The main ones are:
2 This is a limited exemption permitted by ADR 1.8.3.2 which is discussed in ADR, CDG and DGSA . It has been implemented by Regulation 3(j)
3 LQ refers to small receptacles (typically of the sort that go into the retail distribution chain) which are packed in boxes or on shrink-wrapped trays.
4 The principle behind LQ is that an acceptable level of safety is assured providing the receptacles are in a box or shrink-wrapped tray. Retail distribution of LQ packages that have been "broken down" is allowed, subject to certain conditions.
5 Dangerous goods are assigned an LQ category (Column 7a of Table A in ADR). There are 29 LQ categories (table at ADR 3.4.6). Some substances are LQ 0, and in these cases there is no LQ exemption
6 The table at 3.4.6 shows, for each LQ category, the maximum receptacle size (inner packaging) and "box size" or tray size. Note that where there are gaps in columns 3 and 5 the figures are 30kg and 20 kg respectively, and that these are gross package weights (ADR 3.4.1.2)
7 For limited quantity exemptions, the general requirements for packaging (to be of good quality and suitable etc) apply, but the packaging does not have to be "UN approved". Each LQ category has some packaging constraints (ADR 3.4.3 to 3.4.5) and there are particular labelling requirements (see ADR 3.4.4(c)) which describes an “LQ” symbol . Within these constraints, ADR does not apply to "limited quantities".
8 The limited quantity symbol is:
or 
9 There is a new requirement at 3.4.8 for orientation arrows to be applied to LQ packages when the conditions described at 5.2.1.9 apply.
10 Note: changes in ADR 2009 at 3.4.9 to 3.4.13 which relate to information to carriers and to the marking of vehicles carrying dangerous goods only in “Limited Quantities” do not apply until 1 January 2011.
11 Hydrochloric acid (Strong PG II). This is LQ 22 which means that as long as the individual “bottles” are not larger than 1 litre, and the box does not weigh more than 30 kg, then, subject to the conditions outlined above, ADR does not apply.
12 The same substance more diluted (PG III) is LQ 7, and the allowed “bottle” size is 5 litres. Again the maximum box weight is 30 kg. Typical 2 ½ litre bottles, packed four to a box, are within the LQ limit. The detailed packaging requirements do not have to be met but the LQ labelling requirements apply (see above)
13 Lighter fluid (assume classified as UN 1993 Packing group I). This is LQ3. Typical 100 ml cans may be packed 10 to a box (column 3 limit being 1 litre). Subject to the box being marked as above, ADR does not apply. In this case the shrink wrapped tray option is not allowed.
14 Paint UN 1263 PG II. This is LQ6. Cans up to 5 litres may be packed in a box not exceeding a gross weight of 30kg. Cans up to 1 litre may be on shrink wrapped tray not exceeding a gross weight of 20 kg. Subject to the box or tray being marked as above ADR does not apply.
15 Aerosols UN 1950. These are commonly carried as LQ in the form of shrink wrapped trays made up on pallets. For aerosols the attributes of the packaging are more prescribed (ADR 3.4.3). The aerosol dispenser itself is regarded as the “inner packaging”.
16 There is a new requirement at 3.4.8 for orientation arrows to be applied to LQ packages when the conditions described at 5.2.1.9 apply.
17 Note: changes in ADR 2009 at 3.4.9 to 3.4.13 which relate to information to carriers and to the marking of vehicles carrying dangerous goods only in “Limited Quantities” do not apply until 1 January 2011.
18 “Excepted quantities” (EQ) is a new concept for land transport of dangerous goods. It has been commonly used in air transport and the new rules will facilitate the road (and rail) transport elements of a journey that includes air mode. It is, though, also a standalone provision, and gives consignors an alternative for many dangerous goods.
19 Like LQ it requires goods to be in combination packages (e.g. a bottle in a box)
20 A new code (E0 – E5) appears in column 7(b) of table A. This links to paragraph 3.5.1.2 where what is allowed by the codes is set out. For example code E0 means that no EQ provisions are applicable. Code E1 means that the substance may be carried in inner packagings up to 30g or 30ml in outer packagings with a maximum net contents of 1000g or 1000ml - and so on for the other codes.
21 Unlike for LQ there are more prescriptive rules about packaging testing and for documentation.
22 The packages have to be marked with the “EQ Symbol” and documents (where carried) must state “dangerous goods in excepted quantities” and indicate the number of packages.
* (first) label number of the goods
** name of the consignor or consignee if not shown elsewhere on the package
23 Small load exemptions relate to the total quantity of dangerous goods carried in packages by the "transport unit" (usually the van or lorry, but also any trailer). It is the transport category (TC) that determines the load limits (thresholds). Many substances are assigned a packing group but these are not synonymous in all cases with TC. TC is given in column 15 of Table A in ADR (Chapter 3.2). If that is not available, the table at ADR part 1.1.3.6.3 needs to be consulted. Load limits for the different transport categories are given below. For convenience this has been amended in accordance with the derogation but it needs to be used with care.
24 Small load exemptions do not apply to tankers or bulk carriage.
25 If a vehicle is carrying under the small load threshold, many of the requirements of ADR are not applicable. The table below summarises the position. Some care needs to be taken, as "what is not exempted is still required". In most cases the remaining obligations are:
26 Note that use of these exemptions is optional. For example, a carrier may choose to display the orange plates as long as the vehicle is carrying dangerous goods.
27 All vehicle marks (orange plates) must be removed when no dangerous goods are being carried.
28 An important aspect is that packaging has to comply with the relevant standards.
29 LPG. This is in transport category 2. The "small load threshold" is 333 kg and LPG is LQ0. The result is that all cylinders count towards the load limit, but if that is less than 333 kg, the "minimum" ADR requirements apply.
30 Hydrochloric acid. Depending on its strength this is in transport category 2 or 3. The "small load threshold" is 333 or 1000 litres respectively. For TC 3, one 1000 litre IBC or five 200 litre drums or forty 25 litre drums can be carried under the "minimum" ADR requirements if the carrier chooses to do so. Any packages that meet LQ criteria are not counted.
31 Methanol. This is in transport category 2. The "small load threshold" is 333 litres. Any combination of packages up to that amount can be carried under "minimum" ADR requirements if the carrier chooses to do so. Because methanol is LQ0 all packages count towards this threshold.
32 Clinical waste (UN 3291). This is in transport category 2 and LQ0. As with methanol, all packages have to be counted. It is now possible to use combination packaging consisting of an outer "flat pack" corrugated fibreboard box into which is placed a conventional clinical waste bag. Providing the outer box is properly certified this makes the carriage of small amounts of clinical waste possible as “packages”. Typical situations would be the collection of waste from GPs' surgeries or patients' homes. In this case, as long as the total load is less than 333 kg (which would normally be the case) the small load exemptions will apply." Other information concerning clinical waste is in this manual at Clinical waste
33 It can be seen that depending on the substances and the package size, there will be differences in the way the regulations are applied. In each case, if there are mixed loads the aggregation rules in ADR at 1.1.3.6.4 must be applied.
| ADR reference | Requirement that does not apply | Not exempted |
| 5.3 | Placarding and marking | |
| 5.4.3 | Instructions in writing (Emergency information) | Other documentary requirements. Consignor's duty to "furnish the carrier with information…." remains (ADR 1.4.2.1.1 (b)), but it doesn't have to be carried in GB for classes 2 to 6, 8 and 9 |
| 7.2 | The details attached to package requirements. Depends on substance - see column 16 of Table A | 7.2.4 V5 packages not to be carried in "small containers" V7 ventilation of vehicle V8 Temperature control |
| 7.5.11 CV 1 only |
Prohibition of loading/unloading in public place | When carrying explosives All other “CV” special conditions apply to small loads. Note in particular CV9, CV10, and CV36 apply to carriage of gas cylinders |
| Part 8 | Vehicle crews, equipment, documentation, operation Driver training |
8.1.2.1 (a) and (c) (documentation) but note GB exemption in Regulation 29 8.1.4.2 to 8.1.4.5 fire extinguisher for cab (but note transition period in ADR at 1.6.5.6) 8.2.3 General training as set out in Chapter 1.3 8.3.4 prohibition of certain types of lighting apparatus 8.4 Supervision of vehicles (where applicable) 8.5 The following operational notes in column 19 of Table A S1(3), S1(6), S2(1), S4, S14 to 21 (supervision details) |
| Construction and approval of vehicles |
34 Regulation 16 provides that the main parts of the regulations do not apply where carriage is “not undertaken by a vehicle”. This links to the directive’s definition of vehicle and the practical outcome is that the regulations do not apply to:
40 Movement wholly within an enclosed area is exempt from the main parts of the regulations. See Regulation 15.
41 MoD vehicles will operate in line with ADR but tankers will be placarded and plated to ADR practice rather then GB practice. Vehicles operated by commercial carriers on contract to MoD or simply delivering to MoD premises are treated conventionally. The Secretary of State for Defence may issue authorisations to allow MoD vehicles to work outside ADR but this will arise only in special cases (see regulation 12).
42 For small loads (ADR 1.1.3.6) there is no need in GB to carry the documentation except for explosives and radioactive materials.
43 The need for the consignor to provide documentation to the carrier remains (ADR 1.4.2.1.1(b) and Regulation 5.
44 Dangerous goods which have been packaged as "limited quantities" (ADR 3.4) may be removed from their outer packaging and carried from distribution depot to retail outlet (and back if needed) without the packaging having to be marked with UN certification marks or the hazard symbols. This is a derogation implemented by the document “Dangerous Goods: Approved Derogations and Transitional Provisions”
45 Typical products are paints, varnishes, adhesives, drain cleaners, and aerosols. There are conditions:
46 Such a load is no longer generally exempt from ADR. The "minimum" provisions will apply as long as the small load thresholds (ADR 1.1.3.6) are not exceeded (which will usually be the case).
47 DfT have issued Guidance Note 7 which explains this derogation in more detail.
48 This does not apply to the inners taken from non-LQ combination packages if they are too large to qualify for LQ status.
49 See also the relevant entry in the Common problems chapter.
50 A UK derogation (set out in “Dangerous Goods: Approved Derogations and Transitional Provisions” ) makes changes to transport categories and load thresholds for many explosives. In effect these changes maintain older arrangements for domestic transport only. See also amended table of transport categories
51 A UK derogation provides that, except for explosives and radioactive materials, the regulations do not apply to the following movements
52 There are related, but more restrictive exemptions for classes 1 and 7 goods. For details see “Dangerous Goods: Approved Derogations and Transitional Provisions”.
53 For a variety of reasons it has been found necessary to issue authorisations to allow certain activities to take place outside the strict scope of ADR. These are added to and deleted as the need arises or recedes. They are all time limited (though in some cases the time is substantial). The up-to-date list may be found at authorisations.
54 The authorisations are all in pdf files and can readily be downloaded. Some are somewhat esoteric, but those most likely to be encountered are:
| Transport Category (See column 15 of Table A) |
Substances or articles packing group or classification code/group or UN No. |
Maximum total quantity per transport unit Kg or litres |
Multiplier for mixed loads |
|---|---|---|---|
| 0 | Class 1: 1.1A/1.1L/1.2L/1.3L/1.4L and UN No. 0190 Class 3: UN No. 3343 Class 4.2: Substances belonging to packing group I Class 4.3: UN Nos. 1183, 1242, 1295, 1340, 1390, 1403, 1928, 2813, 2965, 2968, 2988, 3129, 3130, 3131, 3134, 3148, 3207 and 3372 Class 6.1: UN Nos. 1051, 1613, 1614 and 3294 Class 6.2: UN Nos. 2814 and 2900 (risk groups 3 and 4) Class 7: UN Nos. 2912 to 2919, 2977, 2978 and 3321 to 3333 Class 8: UN No 2215 (Molten maleic anhydride) Class 9: UN Nos. 2315, 3151, 3152 and equipment containing such substances or mixtures and empty uncleaned packagings having contained substances classified in this transport category |
0 | N/A |
| 1 | Substances and articles belonging to packing group I and not classified in transport category 0 and substances and articles of the following classes: Class 2: groups T, TC a, TO, TF, TOC and TFC aerosols: groups C, CO, FC, T, TF, TC, TO, TFC and TOC Class 4.1: UN Nos. 3221 to 3224 and 3231 to 3240 Class 5.2: UN Nos. 3101 to 3104 and 3111 to 3120 |
20 50 See note "a" below |
|
| 1A | Class1:1.1B to 1.1J/1.2B to 1.2J/1.3C/1.3G/1.3H/1.3J/1.5D Applies only to UK domestic journeys |
50 | 20 |
| 2 | Substances or articles belonging to packing group II and not classified in transport categories 0, 1 or 4 and substances of the following classes: Class 2: group F aerosols: group F Class 4.1: UN Nos. 3225 to 3230 Class 5.2: UN Nos. 3105 to 3110 Class 6.1: substances and articles belonging to packing group III Class 6.2: UN Nos. 2814 and 2900 (risk group 2) Class 9: UN No. 3245 |
333 | 3 |
| 2A | Class1: 1.4B to 1.4G and 1.6N Applies only to UK domestic journeys |
500 | 2 |
| 3 | Substances and articles belonging to packing group III and not classified in transport categories 0, 2 or 4 and substances and articles of the following classes: Class 2: groups A and O aerosols: groups A and O Class 8: UN Nos. 2794, 2795, 2800 and 3028 Class 9: UN Nos. 2990 and 3072 |
1 000 | 1 |
| 4 | Class 1: 1.4S Class 4.1: UN Nos. 1331,1345,1944,1945,2254 and 2623 Class 4.2: UN Nos. 1361 and 1362 packing group III Class 7: UN Nos. 2908 to 2911 Class 9: UN No. 3268 and empty, uncleaned packagings having contained dangerous goods, except for those classified in transport category 0 |
unlimited | |
| Note a: For UN Nos. 1005 and 1017 (anhydrous ammonia and chlorine), the total maximum quantity per transport unit shall be 50 kg | 50 | 20 | |