Some asbestos waste (for example thermal insulation material, asbestos insulation board) is dangerous for carriage under UN numbers 2212 (Transport category 2 - the more hazardous) or 2590 (transport category 3). It is also "special waste" for the purposes of waste disposal legislation which is enforced by the EA or SEPA as the case may be.
Accordingly it has to be properly packaged in UN certified packaging (usually double bagged in polythene bags that are tested and certificated, see approved packaging) and properly consigned as for any other dangerous substance. Carriage documentation is separate from waste disposal documentation, though some information may be shared. Note that the key information of proper shipping name, UN Number, class (in this case "9") and packing group (in this case same as transport category) preceded by the word "WASTE" must be together in the documents (ADR 5.4.1.1.3)
Asbestos cement products are covered by ADR special provision 168 and as such are not regarded as dangerous for carriage.
Articles such as lengths of pipe or ducting that have asbestos insulation inside or outside, or timber that has been used for enclosures should be treated as "manufactured articles" for the purposes of SP 168 provided that they are so wrapped in heavy gauge polythene (or similar) that asbestos fibres cannot escape. It follows that the way they are handled and transported should ensure that the integrity of the wrapping is not compromised.
ADR requires packages of asbestos to be carried in closed vehicles or containers (packing instruction P002, Special Provision PP37). The Control of Asbestos Regulations 2006 will apply. The preferred method is to use skips with lockable covers. See also note below in connection with wastes legislation.
Skips meet the definition of "container" (ADR 1.2.1) so, unless the load limit exemptions apply (threshold 333 kg for blue/brown, 1000 kg for white asbestos), they must be marked as required by ADR 5.3.1.2 (UN Class 9 hazard placards on all four sides), and the vehicle must also display plain orange plates front and rear (ADR 5.3.2.1.1) - again subject to the small load exemptions.
| Substance | Application of ADR | Carriage requirements |
|---|---|---|
| Waste thermal insulation and AIB | UN 2212 or 2590 Class 9 |
Certified packaging (usually double polythene bags). Other aspects of Carriage Regulations apply. Special waste legislation |
| Asbestos in or attached to items such as pipes or ductwork | Treated as SP 168 exempted | Must be wrapped to prevent escape of fibres |
| Asbestos cement products (new) | Does not apply by SP 168 | None |
| Asbestos cement products as waste | Does not apply by SP 168 | Special waste legislation |
| Waste rubble or soil contaminated with asbestos | UN 2212 or 2590 Class 9 |
Certified packaging (available in up to 2 tonnes capacity bags) within skip or freight container. Other aspects of Carriage Regulations apply. Special waste legislation |
Asbestos cement products are "special waste" and must be consigned under the relevant waste rules which include a "duty of care". That duty of care means, amongst other things, that dutyholders prevent escape of the waste whilst it is in their control.
The duty of care is described more fully at the DEFRA website.
Other information may be found on the EA website and HSE's asbestos website.
HSE's enforcement policy
Take care with acetylene
Fire extinguishers guidance notes
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