Common DG queries

Do exemptions apply to medicines and pharmaceutical products?

Medicines may be dangerous for carriage by road, notably cytotoxic and radioactive treatments. Some may also be flammable. With a few exceptions they are treated exactly as any other dangerous goods. Often problems encountered with the carriage of drugs are when they have been removed from their packaging and mixed. If possible treatments should remain in their original packaging.

Can private individuals carry petrol?

The Regulations completely exempt private non-work related carriage as long as some conditions are satisfied (ADR 2015 1.1.3.1(a)). The three main possibilities are where the carriage is “ancillary to main activity”, as a “small load” and where either of those is true “approved packaging” must be used.

So using petrol as an example in the case of “Ancillary” the maximum pack size under LQ is 1 litre. As a “small load” the maximum amount would be 333litres per transport unit but only if in correctly labeled UN approved packaging. The typical plastic container bought from a petrol forecourt does not meet these requirements so a contractor needing to carry fuel for “Ancillary” purposes would need UN approved metal jerry cans with Class 3 Package labels. He would also need training as per ADR 1.3 and carry in the vehicle cab a 2kgs dry powder extinguisher that must be sealed, dated, securely fixed and bearing a compliance mark.

“Who should complete and sign the CVPC at Box 15 on a DGN?”

The Container and Vehicle Packing Certificate is a declaration found at Box 15 on a Dangerous Goods Note (the mandatory transport document for moving dangerous goods by sea). Non-completion of Box 15 is a common reason for ferry operators to temporarily refuse vehicles or containers access to carriage by sea – why?

Well, the purpose of Box 15 is really to make a declaration that the goods are “fully and accurately described” on the paperwork in the way the Regulations stipulate. Ferry operators need complete and detailed information with regard to the products, their labels and markings, and their packaging methods in order to comply with the IMDG (Marine) Regulations for dangerous goods. The details enable ferry operators to load vehicles carrying dangerous goods correctly on the vessels. Without these details they are not permitted to accept the vehicles / trailers / containers for carriage. So who should sign Box 15?

It may be signed by any competent person who has witnessed the packing and loading processes and who can verify that the description of the load on the paperwork accurately matches the load itself. As such the Consignor is usually the most likely person to sign.

For direct export loads involving a sea leg, drivers should check that the CVPC Box 15 is signed before leaving the collection address, as to arrive at their port of departure with Box 15 incomplete will incur a delay until the document can be legitimately completed.

But what about in this example - a driver collects a local consignment for return to a domestic hub that is then to be consolidated for export onto another vehicle or container with other dangerous goods? Here the Carrier should then create a new DGN for the export to include a completed Box 15 on the basis of information supplied to them by the Consignors. So the driver making domestic collections need not insist that Box 15 is completed when loading from the originating Consignor.

It is not recommended that drivers sign Box 15 themselves, unless they have genuinely witnessed the packing and loading process and have received the training to enable them to verify this correctly on the documentation in the prescribed format under IMDG code. They should complete and sign the Carrier details elsewhere on the DGN though.

“We only move General Awareness consignments, do our vehicles need to carry any specialist equipment?”

For consignments below the Load Related or Small Load Exemptions values (commonly referred to as “General Awareness”) the only vehicle kit requirement is a 2kgs dry powder fire extinguisher in the vehicle’s cab. Dry powder has the blue colour coding and is suitable for all types of fires.

It should be readily accessible in the cab and secure, so in a bracket and not loose. It should display a compliance mark (CE or Kitemark), be sealed with a tag, and show either the Expiry Date or Next Inspection Due date. If it has a pressure gauge then the dial needle should show in the green section.

There is a common notion that General Awareness loads are not affected by CDG / ADR - it’s incorrect to say this. They are allowed a partial exemption from the Regulations and persons are still required to receive training in line with their duties to understand the natures of the product dangers. The current version of ADR has an apparent contradiction that could be interpreted differently, however it is believed that this will be resolved going forwards. The DfT Dangerous Goods office has clarified the position saying that General Awareness training must be received.

(Note also that General Awareness vehicles don’t require to be marked with orange plates).

How can I check I have the correct vehicle equipment and PPE?

Carriers are obliged to provide Instructions In Writing in the cab of every transport unit they operate in a language the vehicle crew can understand. The IIW (Instructions in Writing) detail all vehicle kit and PPE needs per hazard class. The most recent version can be downloaded free from the UNECE website or they are commonly available in laminated format. The requirements for vehicle kit may vary according to products carried. The following list is a comprehensive breakdown for a Packages vehicle carrying hazard classes 2,3,4,5,6,8 and 9:

• Two self standing warning signs (cones or triangles for example)
• Eye rinse liquid (in date)
• High visibility vest
• Torch (ATEX standard)
• Goggles
• Respirator (in date)
• Shovel
• Drain seal
• Collecting container
• Appropriate quantity powder extinguishers (showing dates)

“Can our drivers sleep in their vehicles overnight whilst they’re loaded with dangerous goods?”

In most cases with Hazard Classes 2, 3, 4, 5, 6, 8 and 9 the answer is yes, they can but there are a couple of examples to note:

In vehicles loaded with Class 7 Radioactive materials it is prohibited, as damage from radiation is increased through prolonged exposure to radioactive materials so to unnecessarily increase the time of exposure by sleeping in the vehicle would be highly inadvisable.

Carriers might also take a best practice view with regard to vehicles loaded with dangerous goods carrying a toxic risk, and in the gas of toxic gases in particular there is a prohibition using vehicles with a shared load space / driver’s cab atmosphere i.e. a panel van.

Can passengers be carried in vehicles loaded with Dangerous Goods?

ADR 2015 8.3.1 explains in part: “Apart from members of the vehicle crew, no passengers may be carried in transport units carrying dangerous goods”. If there are other members of the vehicle crew they must be also be trained when dangerous goods are being carried. Untrained crew members are permitted to travel in the vehicle as part of on the job training, however their actions must be under the direct supervision of a trained person and their subsequent training must be taken as soon as is practicably possible. If the transport unit is in scope of Regulations (i.e. CDG or ADR) then it is the ADR licence holder who must drive the vehicle. There is an exception to the no passenger rule where very low risk Class 7 Radioactive packages bearing I-WHITE labels are being carried.