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What are the packaging and documentation requirements related to the carriage of asbestos and asbestos waste?

All asbestos waste is defined as ‘hazardous waste’ in England and Wales and as ‘special waste’ in Scotland when it contains more than 0.1% asbestos. The corresponding waste legislation is therefore subject to enforcement by the Environment Agency, Natural Resources Wales and the Scottish Environment Protection Agency, as the case may be.  Waste containing asbestos must be consigned under the relevant waste rules which include a "duty of care". That duty of care means, amongst other things, that duty holders prevent escape of the waste whilst it is in their control.  All movements must be accompanied by a hazardous/special waste consignment note. The Control of Asbestos Regulations 2012 (CAR2012) apply.

Under CDG, some asbestos products may be covered by ADR Special Provision 168, if they are bound in cement, plastic or another binder so that fibres cannot escape during carriage or are manufactured articles containing asbestos, (ADR 3.3.1). Examples include asbestos cement sheets, drainpipes or vinyl floor tiles. If this applies the waste is totally exempt any compliance with CDG as it  not regarded as dangerous for carriage, although the hazardous and special waste regulations and CAR2012 still apply.

All other asbestos waste is known as fibrous, or unbonded, (for example, thermal insulation material, asbestos insulation board), and is classified as dangerous for carriage.  It will be a UN Class 9 substance, and either:

UN2212, ASBESTOS, AMPHIBOLE (amosite, tremolite, actinolite, anthophyllite or crocidolite),Packing Group II. These are the most hazardous varieties, or
UN2590, ASBESTOS, CHRYSOTILE, Packing Group III.

Accordingly, this asbestos must be properly packaged in UN certified packaging (usually double bagged in red inner and clear outer polythene bags that are tested and certified, see approved packaging) and properly consigned as specified in ADR/CDG. Any items placed in packaging marked and labelled as UN Class 9, UN2212 or UN2590 have been consigned as dangerous for carriage and must comply fully with the applicable carriage regulations.

Carriage documentation is obligatory if the load exceeds the load limit exemption threshold. UN2212 is Transport Category 2, so 333kgs, UN2590 is Transport Category 3, so 1000kgs. In order to determine the threshold for mixed loads, the weight of material in Transport Category 2 should be multiplied by 3 and added to the weight of material in Transport Category 3.  If the result is over 1000, then carriage documents will be required. This information is incorporated into Section B of the Hazardous Waste Consignment Note in England and Wales but should be provided as a separate document to the special waste note in Scotland. Note that the key information of UN Number, proper shipping name preceded by the word "WASTE", UN class and packing group must be provided in the documents in exactly the format specified in ADR 5.4.1.1.3.
e.g.  UN2212, Waste Asbestos, Amphibole (Amosite), 9, PG II (E)
or     UN2590, Waste Asbestos, Chrysotile, 9, PG III (E)

Please note that the previous proper shipping names of blue asbestos, brown asbestos, and white asbestos were replaced in ADR 2015 and must no longer be used.

All asbestos waste which is not subject to Special Provision 168 must be placed in certified UN packaging.

Although manufactured articles are exempt from ADR/CDG under Special Provision 168, the H.S.E. requires that "any waste where the escape of hazardous quantities of respirable asbestos fibres can occur during carriage should be placed in UN-approved packaging” and therefore these must be classified, marked, labelled, documented, and transported as UN2212 or UN2590. Where these articles cannot be placed in normal UN packaging without further cutting and disturbance of the asbestos fibres, such as large AIB panels, they must be wrapped twice in heavy gauge polythene and taped securely so that asbestos fibres cannot escape, then labelled with the UN Class 9 hazard diamond and UN2212/2590 (usually by taping a UN bag to the wrapping).  It follows that the way they are handled and transported should ensure that the integrity of the wrapping is not compromised.

ADR requires UN bags of asbestos to be carried in closed vehicles or containers (Packing Instruction P002, Special Provision PP37).   The preferred method is to use enclosed skips with lockable covers for larger loads, or the load compartment of vans for relatively small amounts. Overpacks such as wheelie bins or large flexible bags are sometimes used in smaller vehicles.

Bulk transport is not permitted.

All vehicles carrying packaged asbestos over the load limit exemption require marking with orange plates front and rear. (ADR 5.3.2.1.1) and drivers must carry their ADR driver training certificate (“ADR licence”). In addition, all vehicle crew, anyone loading fibrous asbestos and drivers of loads under the load limit must have received dangerous goods awareness training in compliance with ADR 1.3.

Skips meet the definition of "container" (ADR 1.2.1) so, unless the load limit exemptions apply (very unusual for skips), 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).

Summary

Substance Application of ADR Carriage requirements

Fibrous asbestos  waste, e.g. thermal insulation and AIB

UN 2212 or 2590
Class 9

Certified packaging (usually double ‘red and clear’ polythene bags).
Other aspects of the CDG Regulations apply.
Hazardous/special waste legislation

Large items containing fibrous asbestos, e.g. pipes or ductwork, timber from asbestos removal enclosures

UN 2212 or 2590
Class 9

Certified packaging (usually polythene ‘pipe bags’).
Other aspects of  the CDG Regulations apply.
Hazardous/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. 
Bulk transport not allowed.
Other aspects of the CDG Regulations apply.
Hazardous/special waste legislation

Bonded cement products, e.g. asbestos cement panels, floor tiles

Does not apply by SP 168

HSE requires plain heavy duty bags  with asbestos warning label, alternatively, wrapped twice and taped  shut if large
Hazardous/special waste legislation

Other manufactured articles containing asbestos, e.g. AIB panels

Does not apply by SP 168

If fibres not bonded , HSE  requires certified packaging etc. alternatively, if large, wrapped twice and taped shut  (thus other aspects of  the CDG Regulations – including marking and labelling - will apply).
Hazardous/special waste legislation

The duty of care is described more fully at the DEFRA website .
Other information may be found on GOV.UK and HSE's asbestos website

Updated 2018-12-14