Transporting small quantities of dangerous goods
Published 10 November 2009
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Transporting dangerous goods to retailers or end usersĀ
If you transport dangerous goods, there are rules about how you must pack and label them.Ā Ā These rules do not apply if you are only transporting small amounts of dangerous goods from:Ā
- a distribution centre to a retailerĀ
- a retailer to an end user
This means that you can transport the dangerous goods:
- without their original outer packaging (for example, drum, box, shrink- or stretch-wrapped tray)
- without having to meet the marking requirements that would normally be required under ADR for single packagings
This exemption does not apply to dangerous goods of Classes 1, 4.2, 6.2 or 7.
When small numbers of a particular product are required, it may be necessary to break into limited quantity (LQ) or UN approved combination packages to select a few items to prepare an order for delivery to individual stores.
The effect of these provisions is that the inner packaging does not have to be marked with UN certification marks or the hazard symbols and does not have to be re-boxed.
The total quantity of goods on the transport unit carried under these derogations must not exceed:
- 30kg or 30 litres per type, colour, strength or inner package size of a substance or article (for example, colour or type of paint or size of tin)
- 333kg or 333 litres per transport unit
Inners from LQ packages carried ālooseā under this derogation will continue to be treated as LQs under the other provisions of ADR Chapter 3.4.
āLooseā inners from UN combination packs will still:
- count towards the overall load calculations under ADR 1.1.3.6
- be subject to all the other provisions of ADR - for example drivers must have formal awareness training and vehicles must carry a fire extinguisher of at least 2kg
Some carriers may find it appropriate to provide the driver with a retail distribution dangerous goods load card that can be shown to enforcement officers. Formal transport documents would not otherwise be required for these types of load and many transfers are done using paperless systems.
The use of such a voluntary card could avoid misunderstandings at roadside checks and the driver having to describe the journey and the load and prove that the relevant conditions are met.
This guidance provides suggested text for a retail distribution dangerous goods load card.
Use of ātoteā boxes for carriage of LQ inners
Many distributors of retail goods find it convenient to use ātoteā boxes to assemble inners to meet individual orders from stores, after split-packing from their original combination packaging. You can use such tote boxes for dangerous goods within Great Britain, provided they meet the general requirements for packaging suitability in Chapter 4.1 of the UN and ADR texts (including being securely lidded).
They will enjoy the easements afforded for limited quantities in ADR Chapter 3.4, provided that the provisions are complied with, including the:
- maximum permitted size of inners
- 30kg gross maximum mass
- compatibility of the dangerous goods with different dangerous goods or non-dangerous goods packed together
It is also agreed that the āLQā diamond mark as per ADR Chapter 3.4 may be put on the lid of the box to make logistical control easier.
ADR only allows the letters āLQā to be used if more than one UN number of dangerous goods are present as inners in the outer packaging. If all the goods are of the same UN number, then the actual UN number preceded by the letters āUNā must be used.
If UN approved inners are placed in a tote box, the box becomes an āoverpackā and must be fully labelled and marked in accordance with ADR 5.1.2.
Packing provision PP1 for paints, inks, adhesives and resin solutions
It should be noted that PP1 of Packing Instruction P001 may be utilised within the terms of PP1, including the requirement for the full marking and labelling of inner packages, driver training, fire extinguishers, etc. Such packs count towards the load calculations under ADR 1.1.3.6.
Display packs
It is possible for a ādisplay packā to be designed to meet all the marking and construction requirements set out in ADR Chapter 3.4 for limited quantities.
Alternatively, if a ādisplay packā contains shrink-wrapped trays or boxes correctly marked as LQs, then the display box is an āoverpackā and will need to be marked in accordance with ADR 3.4.7.
If the box contains UN marked packagings then again the box is an āoverpackā and will need to be correctly labelled and marked as such.
However, if the ādisplay packā does not meet any of these conditions then the display box will need to be tested as a UN packaging. For aerosols the test will not be required but no display box can exceed 50kg in fibreboard (Packing Instruction 204).
For other substances and articles, the limits of the relevant packing instruction will apply. This will lead to other implications with ADR in respect of 3.4.7 and 5.1.2 for use of overpacks for LQs and non-LQs respectively.
Sea transport (IMDG code)
It may not always be possible to take advantage of the tote box option for sea transport. This will depend upon the type of outer packaging used.
The requirements for packaging and marking for transport within UK waters are set out in Marine Guidance Note MGN 342 issued by the Maritime & Coastguard Agency.
Such limited quantity carriage by sea also requires dangerous goods documentation as per IMDG code chapter 5.4, additionally endorsed with the words āLimited Quantityā or āLTD QTYā.
If no other dangerous goods are involved, cargo transport units containing such goods need to be marked on the exterior as āLIMITED QUANTITIESā or āLTD QTYā not less than 65mm high in accordance with 5.3.2.4 of the IMDG code.
For international transport by sea, including to the Channel Islands, you must comply with the full provisions of the IMDG code.
Suggested text for a retail distribution dangerous goods load card
Retail distribution dangerous goods load card
Road Transport
Carrier name
Address
This transport unit is carrying some dangerous goods in accordance with the provisions of Derogation 4 in the āApproved Derogations and Transitional Provisionsā document published under Regulations 11(3) of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (SI 2009 No. 1348).
Certain goods have been removed from their āLimited Quantityā (LQ) packaging for distribution to retail sites or end users.
This document confirms that the permitted quantity thresholds are not exceeded. The ānon LQā load is within the thresholds specified in part 1.1.3.6 of ADR and by virtue of Derogation 2, dangerous goods documentation is not required to be carried.
For further information please contact:
Name:
Transport manager / Dangerous Goods safety adviser
Tel: