Last reviewed 17 December 2020
Caroline Raine discusses the Carriage of Dangerous Goods (CDG) prohibition notices issued in 2019 and highlights common mistakes that are made by those transporting dangerous goods.
The Health and Safety Executive (HSE) publishes the list of Carriage of Dangerous Goods — Prohibition Notices Issued by Police or Driver and Vehicle Standards Agency (DVSA) or Department for Transport. The notices are published in a separate spreadsheet for each month and just recently the last for 2019 (December) was published.
The list can be accessed through the HSE website.
In 2019, a total of 601 notices were issued by the Police, DVSA or Department for Transport (DfT). This is compared to 762 in 2018, 860 in 2017, 976 in 2016, 984 in 2015 and 541 in 2014. The question is are less checks being carried out or is their improvement!?
Prohibition notices were issued by Avon and Somerset, Cumbria Constabulary, Cheshire Constabulary, Cleveland Police, Greater Manchester, Hampshire Constabulary, Metropolitan Police, Norfolk Constabulary, North Yorkshire, Suffolk Constabulary, Thames Valley Police, Tri Force Specialist Ops and the DVSA.
The DVSA issued the most with 442 (compared to 606 in 2018) followed by Thames Valley Police with 35, Hampshire with 33, and Suffolk having issued 24.
Companies from the UK, France, Belgium, Bulgaria, Germany, Turkey, Romania, Spain, Hungary, Czech Republic, Slovakia, Slovenia, Ireland, Northern Ireland, The Netherlands, Italy, Estonia, Poland, Macedonia, Portugal, Switzerland, Ukraine, Herzegovina, Latvia and Lithuania were among those that received prohibition notices.
Common issues identified included inadequate provision of fire extinguishers, transport documentation not containing the required information or missing entirely, and the vehicle not being equipped so that the driver can take those measures detailed in the emergency information and, in the case of the carriage of toxic gases, to enable the crew to escape.
Instructions in Writing
Thirty four prohibition notices related to Instructions in Writing (IiW) — either there was no IiW or it was not in a format the driver could understand or it was an old out-of-date version.
Two hundred and sixty-five related to fire extinguishers; common mistakes included them being out of date, or not being tested. Some loads had no fire extinguishers, the incorrect amount or they were not readily available. A few were found to have no pressure.
One hundred and twenty prohibition notices were as a result of the transport documentation. Either there was no document, or it contained insufficient or incorrect information on document, eg no proper shipping name, or wrong packing group.
Eleven cases related to driver training, where the driver had received no awareness training on ADR and so the driver of the vehicle had not received adequate instruction and training to comply with the law and/or would not be able to take proper action to in an emergency.
Emergency phone number
Three notices were issued relating to the emergency response telephone number for answering emergency queries, on all three occasions the emergency number was not displayed.
Many of the notices issued also involved equipment, namely, the vehicle not equipped so that the driver can take those measures detailed in the emergency information and in the case of the carriage of toxic gases, to enable the crew to escape. Many were not carrying the mandatory equipment, or it was not working correctly. This included lack of warning signs, torch, eye wash, chocks, collecting container.
Fifty-three loads were found to have problems with their orange plates or placards. In some cases, they were not being displayed when they should have been, or they were dirty or obscured. In one case it was found that the IMDG UN marks on the orange plates were less than 650mm tall.
Other reasons for the prohibition notice included 51 occurrences of unsecure loads.
A number of loads were found to be leaking dangerous goods, one load was full of split bags, another had no strapping and one was found to have buckle straps that were unsuitable.
Several vehicles were found to have multiple missing items of PPE: no wheel chocks, no eye rinse liquid, no portable lighting apparatus, no shovel, no drain seal, no collecting container. One hundred and three vehicles were “not equipped so that the driver can take those measures detailed in the emergency information and in the case of the carriage of toxic gases to enable the crew to escape”.
Other non-compliances included lack of approval certificates, IBCs and other packaging that was non-compliant.
Reminder of the requirements
ADR specifies the equipment that should be carried on board a vehicle carrying dangerous goods. Chapter 8.1 outlines general requirements concerning transport units and equipment on board, and the IiW in Chapter 5.4 list the equipment needed. The list includes:
a wheel chock
two self-standing warning signs
For each crew member:
a warning vest
Also, required for certain classes:
an emergency escape mask (for each crew member)
a drain seal
a collecting container.
Chapter 8.1 also specifies the requirement to carry fire extinguishers, the number and size of which is dependent on the transport unit size.
There is a legal requirement to carry both a transport document and IiW.
The transport document is specific to the load being carried and should contain:
the name and address of consignor
the name and address of consignee
a dangerous goods description for each dangerous substance
the number and description of the type of packages for each dangerous substance
material or article in the consignment
the total quantity of each type of dangerous goods with a different UN number, proper shipping name or packing group.
For loads being carried under ADR 188.8.131.52 (small load exemption) the calculation must be shown on the transport document.
For each dangerous substance, material or article in the consignment, a dangerous goods description must be provided. This consists of a number of pieces of information, which must be listed in the Dangerous Goods Note (DGN) in the following order.
UN number — preceded by the letters “UN”.
Proper shipping name — including the technical name (if applicable).
The label numbers, as listed in column 5 of the dangerous goods list in the ADR. Note: It is the label numbers that are required, not the class number listed in column 2 — the primary hazard class should be listed first, followed by any applicable secondary hazard classes in brackets.
Packing group (if applicable) — in roman numerals. May be preceded by the initials “PG” or the equivalent initials in the language in which the DGN is being prepared.
Tunnel restriction code, as listed in column 15 of the dangerous goods list in the ADR. This should be listed in capital letters and within brackets. The tunnel code can be omitted if it is known that the consignment will not have to pass through any tunnels.
The IiW is a generic document that can be found in Chapter 5.4 of the ADR. It is a four-page document that can be used as an aid in the event of an emergency situation. The document must be carried in the vehicle crew’s cab and must be readily available. There is also a requirement to have an emergency response telephone number on the vehicle placards.
All staff involved in any way with the dangerous goods must receive training appropriate to their responsibilities and duties prior to such involvement.
The training must cover a range of topics.
General awareness training: training to make personnel familiar with the general requirements of the provisions for the carriage of dangerous goods of the mode(s) concerned.
Function-specific training: detailed training relevant to their duties and responsibilities concerning the carriage of dangerous goods.
Safety training: commensurate with the degree of risk of injury, training on the hazards and dangers presented by the goods and emergency response procedures.
Drivers of vehicles carrying dangerous goods are subject to specific training requirements.
Drivers must receive adequate training and instruction to enable them to understand:
The nature of the dangers of the goods and actions to be taken in an emergency.
Duties under the Health and Safety at Work, etc Act 1974 and, where relevant, duties under the applicable carriage regulations.
Drivers of tanker and bulk vehicles, and vehicles carrying packaged goods above the ADR 184.108.40.206 load threshold, must attend a course approved by the DfT and pass written examinations set by the Scottish Qualifications Authority to obtain a vocational training certificate (ADR certificate) valid for the classes of goods carried in packages or tanks.
The transport of dangerous goods is heavily regulated.
Make sure that your company doesn’t get a fine or prosecution by ensuring that the regulations are followed.
Pay particular attention to the detail of fire extinguishers, training, transport documents and equipment.
If there is any doubt about your responsibilities, speak to your Dangerous Goods Safety Adviser (DGSA).