In this article Desmond Waight describes the relaxations that are available when only a “small load” of “fully regulated dangerous goods” is carried on vehicles.
Relaxations, ie ADR exemptions from certain provisions, are provided when only a small load of “fully regulated dangerous goods” is carried as cargo on the transport unit.
Although the term “fully regulated dangerous goods” is not defined anywhere in ADR, it is being used in this article to describe dangerous goods in packages that do not gain any package-related exemptions, such as those available to dangerous goods in Limited Quantity (LQ) or Excepted Quantity (EQ) packages. “Fully regulated dangerous goods” are recognisable as the package that will bear at least one class danger label and the applicable UN Number.
Loads of “fully regulated dangerous goods” that do not qualify for the relaxations available for “small loads” (an undefined and unused term in ADR), are often described as being “within scope”, although this term is also not defined or used within ADR.
The small load relaxations are based on the principle that while the hazard of the load is unchanged, the risk is reduced due to the lesser amount of dangerous goods being carried.
small load relaxations are not available for carriage in tanks or in bulk.
Determination of whether or not a load of fully regulated dangerous goods packages qualifies for small load exemption from certain requirements is laid out in ADR in Section 22.214.171.124.
Firstly, it requires that the transport category (TC) of each different dangerous good is ascertained. There are five transport categories 0, 1, 2, 3, and 4 (shown in Arabic numerals to differentiate them from Packing Groups (PGs)). Ascertaining the TC for any dangerous good is a simple look-up task in the dangerous goods list (DGL) of ADR Chapter 3.2. The applicable TC for the particular good (and PG level) is the upper figure in column 15. (Note the central column (2) of the table at 126.96.36.199.3 is really only for the regulators.)
The most dangerous goods are assigned TC 0, meaning that for these goods, there are no small load relaxations available to any load that includes them, regardless of the amount of such goods.
TC 1, 2 and 3 are usually* the same as the PG, where PGs are assigned within a class or division. TC 4 is assigned to a few specific dangerous goods.
* It cannot however, be assumed that there is a 1:1 relationship between the PG and the TC. For example, UN2811 TOXIC SOLID, ORGANIC, N.O.S. PG III is assigned to TC 2.
Also, where the fully regulated goods are normally assigned to TC 1, 2 or 3, but are being consigned and carried as empty un-cleaned packages thereof, then they are re-allocated to TC 4 for the purposes of the load calculation.
Secondly, the amounts of the fully regulated goods of each of the TCs 1, and/or 2, and/or 3, must be ascertained as a simple number. ADR in 188.8.131.52.3 defines how the amount is to be measured (eg in kg gross mass or actual liquid content**) and then simply treats these as numbers, so one can “add” the contribution from explosives (measured as net explosive mass) and liquids (as litres of content).
** This is consequent on the rather unusual definition of nominal capacity given in Chapter 1.2 and water capacity (for compressed gases).
Loads of goods having the same TC
If the fully regulated dangerous goods are all of one TC, then a small load will be one where the “amount” of such dangerous goods does not exceed the amounts shown in the table.
20 (although for certain dangerous goods, the figure is 50)
*TC 4-only goods are always a small load in dangerous goods terms, even if the load is the maximum amount the transport unit can legally carry under road traffic requirements.
For example, a load consisting of one drum of UN1133 ADHESIVE flammable PGII (TC2) containing 100 litres (although capable of containing 200 litres), eight 25kg drums of UN2811 TOXIC SOLID, ORGANIC, N.O.S. PG III (but TC 2) totals out at 300; which is less than 333, and so the load is small and will benefit from the relaxations.
Loads of goods having differing TCs
Here, one ascertains the amount of fully regulated goods subject to each limit, and then multiplies this amount (see table) as set down in ADR (see below) to arrive at a factor for that TC band. One then adds the factors and compares the result to 1000. If the sum of factors does not exceed 1000, then the load is a small load.
TC of goods
Maximum of that TC for small load
Here, one would ignore the fully regulated goods assigned to TC 4.
For example, for a load consisting of one UN1133 ADHESIVE flammable PGII (TC 2), containing 100 litres (although capable of containing 200 litres), ten 25 litre drums of UN3349 PYRETHROID PESTICIDE, SOLID, TOXIC PG III (but TC 2) and one combination package containing 4 x 0.5 litres of UN1144 CROTONYLENE PG 1 (TC 1) and three 25 litre drums of UN3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCES, LIQUID, N.O.S. PG III (TC 3), the mathematics would be as follows.
TC of Goods (max)
Aggregated Amount of such goods
TC 1 (20)
4 × 0.5 = 2
TC 1 (50)
10 × 25 = 250
3 × 25 = 75
Sum of factors = 925
Thus, the load of fully regulated packages is a small load as the sum of factors does not exceed 1000.
Putting one more box (of 2 litres) of the UN1144 would increase the sum of factors to 1025, putting the load “within scope”, so that the small load relaxations cannot be applied.
Relaxations for a small load
The relaxations (ie exemptions from certain specific aspects of ADR (not a total exemption from ADR)) for small loads set out in 184.108.40.206.2 are somewhat difficult to understand, since they may be exempt from a whole section of ADR, but only then to reapply certain subsections.
However, once unscrambled the relaxations are essentially as follows.
Generally (there are certain exceptions for some explosives and radioactives), there is no requirement for security training of all involved personnel (not just the driver).
There is no need for the driver to have a current driver vocational certificate (ADR licence) for the carriage of dangerous goods, but the driver still has to have had appropriate dangerous goods familiarisation, function-specific, and safety (regarding the dangerous goods) training for the work they will be carrying out.
The transport unit does not have to be (and should not be) orange plate marked at the front and/or rear, nor carry any placards (even on containers, although these will need to be placarded if there will be sea transport).
Only a 2kg dry powder fire extinguisher (or equivalent) needs to be carried.
There is no need to carry the ADR Instructions in Writing (but equally, no prohibition against so doing).
There is no need for photo identification of the crew to be carried.
Tunnel restrictions do not apply.
Vehicle dangerous goods additional construction requirements do not apply.
In this article, the ADR “small load” relaxations for transport units carrying “fully regulated dangerous goods packages” has been briefly described. Readers are reminded that they must acquaint themselves with the full ADR requirements. Also, it should be noted that for domestic-only carriage, there are some variations to the ADR provisions (basically for explosives) which may be applicable.
Last reviewed 24 April 2013