Last reviewed 28 March 2012
Les Richings examines the requirements for completion of transport documents for surface transport, which are often misunderstood.
In completing documentation for transport by road and rail, Chapter 5.4 of both ADR and RID requires basic information, which most of us are aware of. ADR and RID do not specify a particular format for the document. They do, however, provide an example document 5 and use of such a document format is normally advised.
All documentation requires the name and address of the “consignor” to be completed, however different terminology is sometimes used. One organisation which provides a template for documentation commonly used for sea transport refers to the “shipper” or “exporter”; however all three terms are, in essence, the same.
UN No. and PSN
For most regulations five common elements are required for the description of the goods. The first is the UN Number (which must be preceded by the letters UN), followed by the Proper Shipping Name (PSN). The PSN is the name shown in the dangerous goods list in capital letters. Text shown in lower case is descriptive text and does not form part of the PSN, and need not be included in the document. As an example the entry for “PAINT the additional text (including paint, lacquer, enamel, stain, shellac, varnish, polish, liquid filler and liquid lacquer base)” is shown, but only “PAINT” or “PAINTS” is the correct PSN.
One question that often occurs is should the transport document show the PSN in capitals? ADR specifically allows upper or lower case in 22.214.171.124.2, to be used for the PSN.
For those products that have Special Provision 274 (these include generic descriptions such as: organic peroxides or pesticides or products designated as “Not Otherwise Specified” (N.O.S.)), the technical name or main constituents must be shown following the PSN in brackets as in the two examples below.
“FLAMMABLE LIQUID, N.O.S. (Aliphatic Petroleum)” or
“CORROSIVE LIQUID, ACIDIC, INORGANIC, N.O.S. (Contains Hydrochloric Acid and Sulphamic Acid)”.
You will note that in the example above the individual elements are separated by commas, which is how the examples are shown. Nowhere does it specify in ADR/RID or IMDG 5.4 that this is a requirement. However they do show commas in their examples.
The third element is the description of the “class”. An interesting issue arises here. ADR/RID generally requires the first label model number from column 5 to be shown with the second and subsequent numbers (subsidiary hazards) to be displayed in parenthesis immediately after.
IMDG, however, specifies the primary hazard class from column 3 and the subsidiary hazard class from column 4, which must be enclosed in brackets. While the IMDG Code allows an option to include the word “class” or “division” to prefix the number, ADR does not allow this, so the recommendation must be not to show the word.
ADR 2011 126.96.36.199.1 sub-para (k) says that the core dangerous goods description shall be shown in the order listed “with no information interspersed, except as provided in ADR”. In ADR 188.8.131.52.1(d) the insertion of “PG” is permitted, but unlike the IMDG Code and UN ADR, does not indicate in 184.108.40.206.1(c) that the word “Class” may be used.
ADR also identifies the classification code in column 3b, but this is not required to be shown, neither is the transport category from column 15. There are examples where both of these items have been shown. To display either is not in itself an offence but it does show a lack of understanding leading to greater scrutiny and possible delay in transporting the goods. Note, however, that for Class 1 ADR/RID require the Hazard Classification Code, ie Class, Division and Compatibility Group to be shown.
All regulations require the Packing Group (PG) to be shown where one is assigned. In all regulations this may be preceded by the letters “PG”. However, ADR and RID also allow the abbreviation to be in other languages.
For ADR, the tunnel restriction code is then also required. This should be shown as capital letter(s) in brackets, eg “(D/E)”. The tunnel restriction code is the lower information in column 15 of the dangerous goods list.
Although this need not be shown if the journey will not pass through a restricted tunnel, it is recommended that it is always displayed, as this allows for continuity. This is particularly important if using software to complete the document. It also allows for any change in routing which may not have been planned for.
There are regular examples of failure when completing transport documents for transport by sea, where people miss key items of information required to supplement the description for the product.
One of these is the requirement to show the flashpoint. IMDG requires this for all products with a flashpoint of 60°C (closed cup) or below. This not only applies to goods that are Class 3, but also to those with a Class 3 subsidiary hazard. In some cases column 17 of the IMDG dangerous goods list identifies this. Note, however, it does not always, particularly for N.O.S. entries. The safety data sheet is usually the best source of this information.
Another common problem, particularly when transporting limited quantity packages, is that while ADR does not require a transport document to be provided, IMDG does. This can lead to a situation where a driver arrives at the port without the necessary documentation.
Recent changes to ADR/RID now mean that if the goods are designated as an Environmentally Hazardous Substance (EHS), the additional description “ENVIRONMENTALLY HAZARDOUS” must be shown, except if Class 9 UN3077/3082. This is an important factor as the number of products meeting this requirement is growing, and there is no indication of this need in the Dangerous Goods List. Confirmation can usually be sought from the SDS. Most petrol tankers show the EHS mark, so for a consignment of petrol meeting this requirement the description should be; “UN 1203, PETROL, 3, II, (D/E) ENVIRONMENTALLY HAZARDOUS”.
ADR /RID allow the term “MARINE POLLUTANT” to replace the term “ENVIRONMENTALLY HAZARDOUS” if the goods are being carried as part of a multi-modal operation, including a sea crossing, while IMDG insists on using “MARINE POLLUTANT”. Accordingly, it may be best to always show “MARINE POLLUTANT/ENVIRONMENTALLY HAZARDOUS”.
The need to supplement the description with MP/EH does not apply if the inner packaging or single outer package is 5 litres or 5kgs.
Finally, for marine pollutants, IMDG requires a technical name, in brackets, for N.O.S or generic entries, even if not identified in accordance with SP 274.
Paragraph 220.127.116.11.2 provides a good example: “UN 1263 PAINT (triethylbenzene) class 3 PG III (27°C c.c) MARINE POLLUTANT”.