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Main exemptions

Introduction

Exemptions arise in three ways,

ADR exemptions

1. ADR itself has exemptions set out in part 1.1.3. The main ones are:

Exemption from duty to appoint a DGSA

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)

Limited quantity (LQ) exemptions (ADR 3.4)

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. Subject to those conditions being met, no other requirements of ADR apply. Note however that from 1 January 2011 there are requirements to mark certain transport units when carrying more than 8 tonnes of LQ packages. See ADR 3.4.10

5. Dangerous goods are assigned an LQ “maximum receptacle size” category (Column 7a of Table A in ADR). For some substances this figure is 0, and in these cases there is no LQ exemption.

6. 3.4.2 and 3.4.3 specify the maximum gross mass of the package into which the inner receptacle is placed. This is 30kg  except for shrink wrapped trays  where the limit is 20 kg)

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.3.4.4 has a particular requirement for certain Class 8 (corrosive) goods.  There are particular LQ marking requirements (see ADR 3.4.7 and 3.4.8. Subject to those conditions, ADR does not apply to "limited quantities".

8. From 2011. The limited quantity mark is:

UN Number within diamond

or if an air mode journey is involved

UN Number within diamond

Mark has to be minimum 100 mm x 100 mm unless package is too small. In that case the minimum is 50 mm x 50 mm

9. The “old” system of LQ marking may continue to be used until June 2015, e.g.

Several UN numbers in diamondLQ in diamond

NB This “old” system is not acceptable for any journey involving a sea or air journey.

10. There is now a requirement, under certain circumstances, for the marking of a transport unit which is carrying dangerous goods in "Limited Quantities". See ADR 2011 paragraphs 3.4.11 to 3.4.15.

Examples of limited quantity application

11. Hydrochloric acid, UN 1789,(Strong PG II). From column 7a of Table A the maximum receptacle (inner packaging) size is 1 litre. 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) has a maximum  “bottle” size of 5 litres. Again the maximum box weight is 30 kg.For example, 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 marking requirements apply (see above)

13. Solid caustic soda drain cleaner (UN 1823) has a maximum inner receptacle size of 1 kg.  Again the maximum gross overall package is 30 kg.

14. 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.

15. 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.

16. Orientation arrows have be applied to LQ packages when the conditions described at 5.2.1.9 apply.

17. ADR at 3.4.12 t requires information to be given to carriers in relation to consignments of “Limited Quantity (LQ) packages”.  In certain circumstances (ADR 3.4.13), the vehicle has to be marked if carrying at least 8 tonnes of LQ packages.

18. 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.

Excepted quantity exemptions (ADR 3.5)

19. "Excepted quantities" (EQ) is a relatively 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.

20. Like LQ it requires goods to be in combination packages (e.g. a bottle in a box)

21. 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.

22. Unlike for LQ there are more prescriptive rules about packaging testing and for documentation.

23. 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.

Red E in circle in broken rectangle



*  (first) label number of the goods

 **  name of the consignor or consignee if not shown elsewhere on the package

Small load exemptions (ADR 1.1.3.6)

24. 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.

25. Small load exemptions do not apply to tankers or bulk carriage.

26. 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:

27. 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.

28. All vehicle marks (orange plates) must be removed when no dangerous goods are being carried.

Examples of small load application

29. LPG. This is in transport category 2. The "small load threshold" is 333 kg and there is no LQ provision.. 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. 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.

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 has all packages count towards this threshold.

32. Clinical waste (UN 3291). This is in transport category 2 and there is no LQ provision. Thus 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”. Sharps containers may also come into this category. Typical situations would be the collection of waste from GPs' surgeries or patients' homes. In these cases, as long as the total load is less than 333 kg (which would normally be the case) the small load exemptions will apply. . Bulk carriage of clinical waste (typical yellow bags loosely loaded into a vehicle) cannot be carried under the small load provisions.  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.

Exemptions allowed by small load threshold

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

Exemptions arising from the Dangerous Goods Directive

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:

Movements within premises

35. Movement wholly within an enclosed area is exempt from the main parts of the regulations. See Regulation 15.

MoD vehicles

36. 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).

Documentation

37. For small loads (ADR 1.1.3.6) there is no need in GB to carry the documentation except for explosives and radioactive materials.

38. The need for the consignor to provide documentation to the carrier remains (ADR 1.4.2.1.1(b) and Regulation 5.

Retail distribution of LQ packages and combination packages (See also the relevant entry: Are there any exemptions from the regulations for retails distribution of goods?

Explosives

39  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 

Crossing public roads

40 A UK derogation provides that, except for explosives and radioactive materials, the regulations do not apply to the following movements

41  There are related, but more restrictive exemptions for classes 1 and 7 goods. For details see “Dangerous Goods: Approved Derogations and Transitional Provisions”.

Exemptions by "authorisation"

42  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.

43  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 categories as amended in GB

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
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
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 9: UN No. 3245
333 3
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. 0081, 0082, 0084, 0241, 0331, 0332, 0482, 1005 and 1017 (anhydrous ammonia and chlorine), the total maximum quantity per transport unit shall be 50 kg 50 20

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Updated 2013-11-20