In this article, Caroline Raine discusses the forthcoming changes to the transport of dangerous goods regulations. This article follows on from Part 1 where the main changes to European Agreement concerning International Carriage of Dangerous Goods by Road (ADR), International Maritime Dangerous Goods (IMDG) and International Air Transport Association (IATA) were outlined. Part 2 looks at each mode in more detail. Please remember to read the regulations in full rather than relying on this update.

Transport update

There are some consistent changes through the modes, which have been detailed in Part 1 of this article. The term “subsidiary risk” is now “subsidiary hazard”. There are new UN numbers and Class 8 classification changes.

ADR changes

ADR 2019 is applicable from 1 January 2019 and must be in use by 1 July 2019. There are over 80 pages of changes and this is a summary of the key changes, it is not comprehensive.

Chapter the table has been updated to include a note “b. The maximum total quantity for each transport category corresponds to a calculated value of ‘1000’ (see also” along with clarification that the “total mass in kilograms of the articles without their packagings”.

Small load exemption — ADR The total quantity and the calculated value of dangerous goods for each transport category shall be indicated in the transport document in accordance with and

New requirement for consignors to appoint a Dangerous Goods Safety Adviser (DGSA) “ Undertakings which participate in the carriage of dangerous goods only as consignors and which did not have to appoint a safety advisor on the basis of the provisions applicable until 31 December 2018 shall, by derogation from the provisions of applicable from 1 January 2019, appoint a safety advisor no later than 31 December 2022”.

Merger of temperature calculation

Type of receptacle


Control temperature

Emergency temperature

Single packagings and IBCs

20°C or less

20°C below SADT/SAPT

10°C below SADT/SAPT

over 20°C to 35°C

15°C below SADT/SAPT

10°C below SADT/SAPT

over 35°C

10°C below SADT/SAPT

5°C below SADT/SAPT


≤ 45°C

10°C below SADT/SAPT

5°C below SADT/SAPT

IMDG changes

The IMDG Code, 2018 Edition (including Amendment 39–18) comes into force on 1 January 2020 for two years and may be applied voluntarily as from 1 January 2019.

The IMDG Code, 2016 Edition Amendment 38–16 came into force on 1 January 2018 for two years.

  • There is clarification in paragraph that only the more applicable PSN be used when there are several distinct ones under one UN number.

  • The stowage categories for several Class 1 entries have been amended.

  • There have been several updates in Chapter 4.2 to existing packing instructions and a few new packing instructions added.

  • There is a new IMO type 9 tank added for road gas elements vehicles for the transport of compressed gases of Class 2. In Chapter 5.2, paragraph, the specimen labels are now presented in a landscape table.

  • Chapter 5.3 is now extended to cover bulk containers.

  • Part 6 has several minor changes to some of the chapters.

  • There is a new table added to paragraph, which provides segregation exemptions for organic peroxides UN numbers 3101 to 3120 with subrisks that clash with other organic peroxides.

  • Section 7.3.7 is restructured to merge the amendments to the Model Regulations and the existing text.

New segregation group codes.

  • 18 new segregation groups are identified and so section 7.2.8 has been updated to reflect the new segregation group codes.

  • SG1 has been amended and new segregation codes SG76, SG77 and SG78 added.

Updates to the Dangerous Goods List (DGL).

  • New UN numbers as listed above have been added.

  • A new entry for 3227 was added to the table in paragraph for Class 4. New entries for 3109, 3116, 3119 were added to the table in paragraph for Class 5.2.

  • The 18 new segregation groups have now been coded and included in column 16b of the DGL.


    If a substance belongs to a segregation group (as identified in paragraph it is now identified in the DGL, column 16b, by inclusion of the “SGG” code. The intention is to make the identification of belonging to a segregation group more easily recognisable directly from the DGL.

  • The heading in column 4 of the DGL now reads “subsidiary hazard(s)”.

  • Many substances in the DGL have now been assigned SG35, SG36 and/or SG49 (stow separated from acids/alkalis/cyanides).

  • The EmS guide has been updated and revised to reflect new assignments in column 15 of the DGL.

IATA changes

From 1 January 2019, the 60th edition of the IATA Dangerous Goods Regulations comes into force. The IATA 60th edition takes into account all of the changes made by the International Civil Aviation Organisation (ICAO) 2019–2020 edition of the ICAO Technical Instructions as well as changes adopted by the IATA Dangerous Goods Board. A copy of the summary of the Significant Changes and Amendments to the 60th Edition (2019) can be found on the IATA website.

  • 1.5 — Training Requirements

    Examples have been added to provide an explanation of the three-month “window” for recurrent training and the application of the original training expiry.

  • 2 — Limitations

  • 2.3 — Dangerous Goods Carried by Passengers or Crew

    • Additional text has been added with regards to the most appropriate entry in 2.3 that describes the item. Where a passenger's carry-on baggage cannot be accommodated in the cabin, the operator must verify with the passenger that the carry-on baggage item does not contain dangerous goods forbidden in checked baggage.

    • Radiopharmaceuticals contained in a person following medical treatment and energy efficient lamps in retail packagings are not subject to these regulations.

    • The term “collapsible” that was applied to lithium ion battery powered mobility aids has been deleted.

  • 2.8 — State and Operator Variations

    There are a number of additions, deletions and amendments to variations submitted by States and operators.

  • 3 — Classification

    • Clarification on the classification of ammonium nitrate fertilisers.

    • Classification of infected animal material has been deleted.

    • Class 8 classification changes as listed above.

    • For hybrid lithium batteries that are comprised of lithium metal and lithium ion cells, manufacturers and subsequent distributors of lithium cells or batteries must make available a summary of the UN 38.3 tests with effect from 1 January 2020.

    • New classification criteria have been added for energetic samples.

    • New provisions for the classification of articles containing dangerous goods, nos. This addresses the classification of articles where the type or quantity of dangerous goods that are an integral part of the article exceed that allowed as UN 3363.

  • 4 — Identification

    • New UN numbers as listed above have been added.

    • UN 3316 — chemical kit and first-aid kit to delete reference to packing groups II and III. The shipper must assign the appropriate packing group.

    • “stabilised” added to UN 3302, 2-dimethylaminoethyl acrylate.

    • Assignment of ID 8001 to disilane. This has been done as a placeholder until the UN subcommittee addresses a gap in the existing regulations for pyrophoric gases. The entry for disilane identifies that it is completely forbidden.

    • ERG Code for all lithium battery entries has been changed from “9FZ” to “12FZ”.

  • 4.4 — Special Provisions

    Amendments to the special provisions include:

    • replacement of A21, A134, A203 and A207, assigned to vehicles, which all become “not used” with a new special provision A214

    • revision to A59 to include reference to a maximum gauge pressure under which the exception for unserviceable or damaged tyre assemblies applies

    • revision to A67 to include the test requirements for classification of non-spillable batteries from Packing Instruction 872

    • revisions to A79 and A90 and change to A89 to become “not used”, to clarify the classification of ammonium nitrate fertilisers

    • revision to A107 to address the transport of UN 3363, Dangerous goods in apparatus or Dangerous goods in machinery where the quantity of the dangerous goods exceeds the allowance in PI 962

    • revision to A201 to include provisions permitting the transport of lithium metal or lithium ion batteries as cargo on passenger aircraft with the approval of the States of Origin, destination and operator.

    New special provisions have been added as follows:

    • A213 — Identifies that hybrid lithium batteries, which are comprised of lithium metal cells and lithium ion cells, must be assigned to UN 3090 or UN 3091 and the limits that apply when assigned to Section II

    • A334 — Identifies the conditions that apply to lithium batteries shipped under approval as provided by special provision A201

    • A806 — Provides information on how a shipper must determine the subsidiary hazard(s) for articles containing dangerous goods, n.o.s. and identifies that any subsidiary hazard must be shown on the Shipper's Declaration

    • A807 — Identifies that the assigned entry must not be used for disilane or other pyrophoric gases.

  • 5 — Packing

    Packing instructions

    • PI 200 and PI 218 — have been revised to clarify the terminology associated with the calculation of the pressure in the cylinder.

    • PI 361 and PI 364 — has been revised to restrict UN 1308, zirconium suspended in a flammable liquid in packing groups I and II to combination packagings with a maximum of 75kg gross weight of the completed package.

    • PI 459 — packing provisions for small quantities of energetic samples have been added.

    • PI 620 and PI 650 — the conditions for the pressure differential test and the temperature ranges have been separated to be standalone requirements.

    • PI 958 — changes have been made to introduce the use of combination packagings, in addition to single packagings.

    • PI 966 and PI 969 — clarification has been introduced into these packing instructions on the number of spare cells or batteries that may be in a package with equipment.

  • 6 — Packaging Specifications and Performance Tests

    Reference to new ISO standards has been added and the period during which the ISO standards may be applied for manufacture and also after which time the standards may no longer be used.

  • 7 — Marking and Labelling

    • A note has been added to draw attention to the correct application of GHS pictograms on packages.

    • The specification for hazard labels has been revised to remove the requirement for the outside line to be a minimum of 2mm in thickness.

    • Clarification has been added that the new Class 9 lithium battery hazard label must not have any text in the bottom half other than the Class number “9”.

    • Lithium battery handling label — the provisions that previously existed in and Figure 7.4.H have been deleted as the lithium battery handling label is no longer valid in air transport.

  • 8 — Documentation

    The Shipper's Declaration form in the format as shown in the 59th edition of the DGR remains valid until 31 December 2024. The Shipper's Declaration form has been revised to replace “subsidiary risk” by “subsidiary hazard” in association with the class or division. The example given in IATA has been updated accordingly.

  • 9 — Handling

    • A new provision has been added to identify that engines or machinery assigned to Class 3, UN 3528, do not require segregation from dangerous goods with a primary or subsidiary hazard of Division 5.1.

    • An additional exception for accessibility on loading of cargo aircraft only dangerous goods has been included to allow loading of UN 3528 or UN 3529 in any location on a cargo aircraft.

    • The information required on the written information to the pilot-in-command has been revised to also require that the date of the flight be shown.


There are many changes to the modes for the transport of dangerous goods. Some of these are significant while many are editorial. If you are shipping batteries pay particular attention to the fact that the lithium battery handling mark is no longer applicable and must have been changed. This is a summary of the changes and the regulations must be referred to in full before any shipment is made. Please do contact your company’s DGSA if you require further advice.

Last reviewed 6 December 2018