Last reviewed 25 April 2017
We have recently seen the 18th anniversary of one of the most serious road tunnel incidents in Europe, when on 24 March 1999, in the Mont Blanc tunnel, a vehicle carrying flour and margarine was involved in a deadly fire which claimed so many lives. The driver of the goods vehicle was one of those prosecuted. In this article, Andrew Shylan of AJS HAZ Training, reminds all those involved in the transport of dangerous goods by road of the restrictions on transporting dangerous goods through tunnels in the UK and Europe.
Potted history of tunnel incidents
Over 30 serious tunnel fires worldwide in the last 50 years.
On 24 March 1999, Mont Blanc tunnel fire, vehicle carrying flour and margarine, 38 fatalities.
In 2000 Euro Test programme set up to look at Europe’s infrastructure (evolves into European Tunnel Assessment Programme (EuroTAP)).
On 24 October 2001, Gotthard tunnel, collision between two vehicles with diesel and a consignment of tyres, 11 fatalities. Tunnel closed for two months and only 150 trucks per hour allowed to enter the tunnel.
In 2004 founding of EuroTAP inspections of European road tunnels.
Over 250 tunnels across Europe inspected by EuroTAP and graded from very good to very poor on their potential and risk of a major incident occurring.
The United Nations Economic Commission for Europe (UNECE) produces the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) which lists the ADR tunnel restriction codes for all dangerous goods.
The competent authorities are to assign tunnel categories to all road tunnels based on the tunnel characteristics, alternatives routes and traffic management. The same tunnel may be assigned to more than one tunnel category, depending on the hours of the day or the day of the week which could increase the risk of an accident.
The tunnel categories are based on the assumption there are three major dangers which may cause injury and death or serious damage to the tunnel structure, they are as follows:
Release of toxic gas or volatile liquid
European road tunnels are assigned the following categories.
Tunnel Category A — No restriction for the carriage of dangerous goods.
Tunnel Category B — Restriction to dangerous goods which may lead to a very large explosion.
Tunnel Category C — Restriction for the carriage of dangerous goods which may lead to a very large explosion, a large explosion or a large toxic release.
Tunnel Category D — Restriction to the carriage of dangerous goods which may lead to a very large explosion, to a large explosion, to a large toxic release or to a large fire.
Tunnel Category E — Restriction for all dangerous goods other than those for which “(—)” is marked in column (15) of Table A Chapter 3.2 and for all dangerous goods carried in accordance with Chapter 3.4 Limited quantities, in quantities over 8t total gross mass per transport unit.
The Department for Transport (DfT) has assigned the following codes for UK tunnels (these have not changed since 2010).
East India Dock Road
Between 0400 and 2300: Category E. At other times: Category C.
As you can clearly see several of the UK tunnels are highly restrictive to all vehicles displaying orange plates and carrying dangerous goods which are exceeding the ADR threshold limits, Chapter 184.108.40.206 exemptions (UK small loads) or the dangerous goods are subject to the limited quantity exemptions and exceed 8t gross mass per transport unit.
Tunnel restriction shall not apply when the carriage of dangerous goods is carried in accordance with ADR Chapter 1.1.3 or the dangerous goods are transported using the limited quantity exemptions and do not exceed 8t gross mass per transport unit.
Tunnels not mentioned above are assigned tunnel category A and therefore have no restriction to the transport of dangerous goods through them.
The Eurotunnel is not subject to the ADR tunnel categories and has its own policy which is more restrictive, but based on the ADR regulations, the new 2017 Eurotunnel policy document on dangerous goods can be found here.
ADR dangerous goods list (Chapter 3.2 Table A)
Where there is a restriction to the transport of dangerous goods, ADR Chapter 3.2, Table A, column 15 will indicate a transport category and the tunnel code for the specific entry in the dangerous goods list, this will be indicated by one or two letters or the inclusion of a “—”.
Tunnel restriction code for whole load
Passage forbidden through tunnels of Category B, C, D & E
Carriage where the total net explosives mass per transport unit — exceeds 1000kg: Passage forbidden through tunnels of Category B, C, D & E; — does not exceed 1000kg: Passage forbidden through tunnels of Category C, D & E
Tank carriage: Passage forbidden through tunnels of Category B, C, D & E Other carriage: Passage forbidden through tunnels of Category D & E
Tank carriage: Passage forbidden through tunnels of Category B, C, D & E Other carriage: Passage forbidden through tunnels of Category E
Passage forbidden through tunnels of Category C, D & E
Carriage where the total net explosives mass per transport unit — exceeds 5000kg: Passage forbidden through tunnels of Category C, D & E; — does not exceed 5000kg: Passage forbidden through tunnels of Category D & E
Tank carriage: Passage forbidden through tunnels of Category C, D & E Other carriage: Passage forbidden through tunnels of Category D & E
Tank carriage: Passage forbidden through tunnels of Category C, D & E Other carriage: Passage forbidden through tunnels of Category E
Passage forbidden through tunnels of Category D & E
Bulk or Tank carriage: Passage forbidden through tunnels of Category D & E Other carriage: Passage forbidden through tunnels of Category E
Passage forbidden through tunnels of Category E
Passage allowed through all tunnels (for UN numbers 2919 and 3331, see 220.127.116.11)
A vehicle is treated as the most restrictive tunnel category loaded.
Examples of application of tunnel category codes.
If an ADR road tanker has the tunnel category (D/E) then the tanker is forbidden through tunnel category codes D and E (can travel through categories A, B & C).
When carriage is in packages then the restriction is to tunnel category code E only.
If a vehicle is carrying only 400kg Net Explosive Mass (NEM) and has the tunnel category code C5000D then it has not exceeded 5000kg NEM, and is only forbidden through tunnel category codes D & E only.
Transport documents (dangerous goods notes)
It is the consignor’s (shipper’s) safety obligations to inform the carrier/road haulier of the tunnel codes or inform the carrier in a traceable form when over 8t gross of limited quantities are to be carried.
The tunnel category must be shown on all transport documents at the end of the mandatory sequence as required by 18.104.22.168.1. of the ADR regulations, for example:
UN1202, Diesel fuel, 3, PG III, (D/E)
UN 0415, Charges, Propelling, 1.2C, (B1000C).
The tunnel restriction code need not be added onto the transport document where the carriage is known beforehand not to pass through a tunnel with restrictions, however consignors should always use caution and add the tunnel code if the route is not reasonably known or in case of diversion on route.
ADR would require tunnel codes to be added after the sequence required by the ICAO Technical Instructions/IATA or the IMDG Code where the carriage includes maritime or air carriage (See Chapter 22.214.171.124.3 of ADR).
Examples of European road tunnels assigned tunnel categories
Kieiner Ring (Brussels)
0600–2300 Hr C, 2300–0600 Hr B
E (with certain exceptions)
A complete and comprehensive list of tunnels and roads with dangerous goods restrictions can be sought from the contracting parties’ competent authorities.
Tunnel code indication signs at tunnels
The drivers are warned of the ADR tunnel codes sign on the approach to a restricted tunnel.
Although the consignor must inform the carrier of the tunnel codes, it is the transport operator or carrier who is ultimately responsible to ensure any vehicles which are restricted through tunnels are routed correctly and do not enter a restricted tunnel for their load. All those from the consignors, carrier and drivers who are involved in the transport of dangerous goods must ensure that consignments that are forbidden though European road tunnels are not despatched or routed through a restricted tunnel. They should be aware of the financial implications of a prosecution as well as the very real risk to the lives and safety of those that use the tunnel and the wider economic impact to the economy if the tunnel was closed for a lengthy period of time, so “stay safe in tunnels”.