In this article, Desmond Waight covers the requirements to carry Instructions in Writing when transporting large loads of dangerous goods, and highlights forthcoming minor changes, which will be made in the ADR 2015 edition.

The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) requires that a vehicle should carry emergency Instructions in Writing (IiW) when carrying large loads. Before the re-structuring of ADR in 2001, the requirements used to be covered in two places within ADR.

First, in annex A — which dealt with consignor duties — there was a requirement for consignors to prepare and provide appropriate transport emergency IiW. These had to be produced by the consignor in the language(s) of the country of dispatch, the language(s) of the country of destination and, if applicable, the language(s) of the countries over which the goods would transit. Due to the work of the European Chemical Industry Council (Cefic) in setting out a system for these, including reproduction on light card material, these became known generically as “Tremcards”.

Second — in annex B, which dealt with carrier duties — there was a requirement for these to be carried on the transport unit. Due to the product-specific nature of these Tremcards, ADR, at that time, required that applicable Tremcards had to be kept “readily identifiable in the driver’s cab”, but separate from any non-applicable Tremcards in a way “such as to prevent confusion”.

In the mid 2000s, the decision was taken to do away with the requirement for these product-specific emergency IiW provided by the consignors, and replace them with single, general IiW covering all sorts of dangerous goods, and that the carrier should provide these.

As the requirements had been split between annexes A and B, this was continued, putting some of the revised text in annex A, in the new chapter 5.4, which dealt with documentation, and further revisions of the text in annex B, in chapter 8.1 at s.8.1.2, which concerned requirements for documentation to be carried. In retrospect, perhaps it would have been better for the requirements to be consolidated into annex B, chapter 8.1.

Current requirements

In chapter 5.4, s.5.4.3, ADR sets out the requirements for provision and location of IiW. This does not apply if the goods are Limited Quantity or Excepted Quantity packages, or if only a small load of “fully regulated”, packaged and dangerous goods are being carried. The requirement will always apply to tanks and bulk carriage in any amount.

First, it requires that ADR-standardised IiW shall be carried in the vehicle crew’s cab, and shall be readily available. Note that, strangely, in chapter 8.1, it only mentions that they shall be kept readily available, and does not repeat the requirement for them to be kept in the vehicle crew’s cab. Also, it should be noted that, surprisingly, there is no similar requirement for the transport document detailing the dangerous goods to be carried in the vehicle crew’s cab. The presence or absence and correctness of IiW is an easy item for an enforcement officer to check, and has resulted in a number of prohibition notices for failure to carry.

Second, it requires that the standard ADR IiW be provided by the carrier, before the commencement of the journey, to the vehicle crew in “language(s) that each member can read and understand”. This means that a Polish-speaking driver operating in the UK, who is unable to understand English instructions, must be provided with IiW in Polish.

Note:

  • There were changes made to the original ADR 2009 standard by ADR 2011, and only models conforming to the 2011 standard are currently acceptable.

    • If they do not have a red triangle with a thermometer symbol as the last entry in column 1 of the table that shows the various class label and other marks that can be required for large loads/tanks/bulk carriage, then they are not the correct version.

  • IiW, in many of the ADR contracting state languages, are available on the UNECE website.

  • There is no requirement to remove or hide IiW.

  • IiW must be as described in ADR, and reproduced in colour — they may however:

    • be A4 or A5 or any other suitable size

    • carry a company logo at the top, but must otherwise not have any changes.

Third, it requires that the carrier ensure that each member of the vehicle crew understands and is capable of carrying out the instructions.

Finally, it requires that, before the start of a journey involving “fully regulated” dangerous goods on any transport unit bearing orange plates, the members of the vehicle crew shall inform themselves of the dangerous goods loaded (details of which are, of course, in the transport document) and then consult the IiW for details on the action that they would need to take in case of an accident or emergency. It has been the experience of the author (from attendance at police inspections of dangerous goods vehicles) that many drivers have failed to undertake this action.

ADR 2015 changes

At the meeting held in November 2013 to consider changes to ADR for the 2015 edition, the Belgian expert introduced a paper containing specific proposals. The paper was discussed, and the official meeting report notes that: “The personal protection equipment that must be on board vehicles was listed in 8.1.5. The Working Party considered that it was not necessary to set it out in such detail in the Instructions in Writing, as indicated in 5.4.3.4. The Working Party adopted the amendments to 5.4.3.4 and the transitional measure proposed by the representative of Belgium.”

Accordingly, the text of ADR 2015 will contain a slightly revised standard IiW. The changes are shown in the table below, with changes highlighted in bold for readers’ convenience (it will all be in normal font when published).

Current text

Revised text (from 1 January 2015)

The following equipment shall be carried on board the transport unit:

  • for each vehicle, a wheel chock of a size suited to the maximum mass of the vehicle and to the diameter of the wheel

  • two self-standing warning signs

  • eye rinsing liquida.

The following equipment shall be carried on board the transport unit:

  • for each vehicle, a wheel chock of a size suited to the maximum mass of the vehicle and to the diameter of the wheel

  • two self-standing warning signs

  • eye rinsing liquida.

The following shall be carried for each member of the vehicle crew:

  • a warning vest (eg as described in the EN 471 standard)

  • portable lighting apparatus

  • a pair of protective gloves

  • eye protection (eg protective goggles).

The following shall be carried for each member of the vehicle crew:

  • a warning vest

  • portable lighting apparatus

  • a pair of protective gloves

  • eye protection.

Additional equipment required for certain classes include:

  • an emergency escape maskb for each member of the vehicle crew, which shall be carried on board the vehicle for danger label numbers 2.3 or 6.1

  • a shovelc

  • a drain sealc

  • a collecting containerc.

Additional equipment required for certain classes include:

  • an emergency escape mask for each member of the vehicle crew, which shall be carried on board the vehicle for danger label numbers 2.3 or 6.1

  • a shovelb

  • a drain sealb

  • a collecting containerb.

  1. Not required for danger label numbers 1, 1.4, 1.5, 1.6, 2.1, 2.2 and 2.3.

  2. For example, an emergency escape mask with a combined gas/dust filter of the A1B1E1K1 P1 or A2B2E2K2-P2 type, which is similar to that described in the EN 141 standard.

  3. Only required for solids and liquids with danger label numbers 3, 4.1, 4.3, 8 or 9.

  1. Not required for danger label numbers 1, 1.4, 1.5, 1.6, 2.1, 2.2 and 2.3.

  2. Only required for solids and liquids with danger label numbers 3, 4.1, 4.3, 8 or 9.

Note:

Although the references to the standards of the personal protective equipment requirements have been dropped from the IiW, they still remain specified in s.8.1.5.

The changes, while minor, will mean that all existing IiW and copies will need to be replaced by updated versions. However, rather than just the normal six-month transitional provisions, a longer period will be provided by a new transitional provision in chapter 1.6:

1.6.1.35: The instructions in writing in accordance with the requirements of ADR applicable up to 31 December 2014, but which do not however conform to the requirements of 5.4.3 applicable as from 1 January 2015, may continue to be used until 30 June 2017.

Conclusion

Though split into two places in ADR, the requirements for IiW are relatively straightforward and there is little excuse for failure to carry the required IiW. In addition, carriers should ensure that drivers and other members of the crew are aware of, and carry out, their duties in relation to the IiW.

Last reviewed 4 February 2014