In this article Desmond Waight explains Eurotunnel’s provisions relating to the carriage of dangerous goods on vehicles through the Channel Tunnel.
Eurotunnel is not a road tunnel and therefore it has not been allocated a tunnel code according to ADR. The tunnel is subject to its own rules, though it complies with ADR as a starting point.
The Eurotunnel rules are outlined in the current copy of the 2013 ADR regulated goods — The practical guide, which can be obtained from Eurotunnel Freight Commercial Department, UK Terminal, Ashford Road, Folkestone, Kent CT18 8XX (tel: 01303 282 244, e-mail: firstname.lastname@example.org).
Although this is the 2013 edition, it should be noted that, unlike ADR 2013, the rules outlined in the guide were not made available until the middle of February 2013, and thus could not be applied to the new UN Number entries introduced by ADR 2013. It is to be hoped that, in future, Eurotunnel will have these published before 1 January of each odd-numbered year, to be applicable from 1 January of that same year. However, Eurotunnel, like ADR, does provide a transition up to 1 July before the new edition becomes mandatory and the older edition can no longer be used. Hopefully, also in future editions, Eurotunnel will introduce a system of identifying new, revised or deleted texts so that users can be more readily aware of the changes with which they have to comply.
ADR as basis for Eurotunnel policy
Eurotunnel’s policy is built round a requirement for dangerous goods and their carriage to be fully compliant with ADR before any consideration is given to taking them through the tunnel (ie classification of the goods, their identification, containment, labelling and/or marking, and documentation).
However, it should be noted that Eurotunnel does define transport units rather differently from ADR. For example, in the case of a tractor unit with semi-trailer, carrying two containers, each container would represent a separate transport unit for Eurotunnel but would be a single transport unit for ADR.
For fully regulated dangerous goods (per ADR) to be acceptable for carriage through the tunnel, they must be listed by UN Number and PSN and Packing Group level (if applicable). Thus, of the six new “chemicals under pressure” UN Numbers listed in ADR 2013, only UN 3500, for such chemicals with only an asphyxiant risk, is now permitted through the tunnel.
Generally, fully regulated goods bearing two or more danger labels (labels 1–9) are not authorised for transit via Eurotunnel Freight, with the exception of the goods specified under Class 2. Further exceptions are made for goods that pose a secondary hazard derived from their method of packaging. This is the case for UN 3291 CLINICAL WASTE, UNSPECIFIED, N.O.S. or (BIO) MEDICAL WASTE, N.O.S. or REGULATED MEDICAL WASTE, N.O.S., which is accepted when packed in refrigerated liquid nitrogen.
It should be noted, therefore, that certain goods that are dangerous for sea, eg UN1845 DRY ICE, but are not regulated under ADR, while not listed as being acceptable are nevertheless authorised for carriage through Eurotunnel. However, the amount of such goods that are accepted by Eurotunnel and may be carried on a transport unit may be limited in the quantity that is allowed per transport unit.
There follow some examples where the quantity or size of the packaging is restricted.
UN1950 AEROSOLS will normally be carried as LQ packages and are not restricted by Eurotunnel (but must of course conform to ADR). However, in large package sizes they are restricted to a maximum of 1500kg gross weight per transport unit.
UN 1993 FLAMMABLE LIQUID N.O.S. but of PG II and PG III only is limited to a maximum of 250 litres per transport unit (whether in a single package or as an aggregated quantity).
UN 2810 TOXIC LIQUID, ORGANIC, N.O.S. of PG II is permitted without quantity restriction per transport unit, but transport must be in unit packages not exceeding 250 litres/400kg maximum, whereas at PG III level there is no restriction except as set down by ADR and subject to the load size restrictions.
UN3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCES, SOLID, N.O.S., which used not to be allowed through the tunnel (until mid-2012), and UN3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCES, LIQUID, N.O.S. are both permitted without any additional Eurotunnel restrictions.
LQ and EQ packages
Dangerous goods that are packaged and marked in compliance with ADR provisions for Limited Quantity packages per ADR Chapter 3.4 and dangerous goods that are packaged and marked (if necessary) in compliance with ADR provisions for Excepted Quantity packages per ADR Chapter 3.5 are permitted for transport through Eurotunnel, even if the same goods are not permitted if carried as “fully regulated” packages.
For example, while the guide says in relation to Class 4.3 Water reactive goods that “No substances of this Class will be accepted for carriage via Eurotunnel Freight”, carriage of such goods (eg UN3134 WATER-REACTIVE SOLID, TOXIC, N.O.S.) as EQ packages is permitted.
On arrival at the tunnel, the driver must give the customer service agent the transport document carrying the information required by ADR, if applicable (a transport document is not required for LQ and EQ packages). The transport document must therefore contain:
PSN (supplemented as necessary)
effectively the Class (though in many cases ADR actually requires the first label number)
number and type of packages
For goods being consigned from the UK the use of English is, of course, mandatory. For incoming goods, this must include the details in either English, French or German, as well as any additional language(s) for goods coming from an ADR country whose official language is other than English /French/German.
Eurotunnel’s guide also states that the applicable ADR classification code should be given, though ADR does not require this information on the transport document. The Eurotunnel website further confuses by stating that both gross and net weight are required (though ADR only requires the applicable one of the two), as well as the net weight per inner package.
Though these inconsistencies have been reported to Eurotunnel and updates have been promised, this has yet to happen.
Drivers should follow the signs for the freight terminals and then follow the route identified to the Freight Drivers Information Centre (FDIC). At the FDIC, the driver must declare on the self-check-in screen whether he or she is carrying ADR-regulated goods, though it is less than clear that LQ and EQ goods are not considered by Eurotunnel as “ADR-regulated Goods”. The driver will then be directed to the Freight Drivers Centre Control Point located after check-in where, once the documentation and vehicle have been checked, the customer service agent will issue the driver with a “label” that displays an internal reference number. The agent will create a file with this number as a reference.
Reference numbers enable Eurotunnel Freight to follow the vehicle’s location in the Eurotunnel freight system and thus, should the need arise, react swiftly according to the nature of the goods being carried.
The label has to be placed on the vehicle’s windscreen in a visible position and must not be removed until the vehicle has left the destination terminal at the end of its journey.
Last reviewed 9 May 2013