Last reviewed 19 October 2020

In this feature Caroline Raine outlines the changes that will be brought into ADR 2021. The changes are applicable from 1 January 2021 and mandatory on 1 July 2021.

General Changes

On 1 January 2021, the ‘“European Agreement concerning the international carriage of dangerous goods by road (ADR)’” will become the ‘“Agreement concerning the international carriage of dangerous goods by road (ADR)’”. This is not because of Brexit, but because there are more and more countries outside of Europe becoming signatories to ADR.

There are only four new UN numbers:

  1. UN0511 — DETONATORS, ELECTRONIC programmable for blasting.

  2. UN0512 — DETONATORS, ELECTRONIC programmable for blasting.

  3. UN0513 — DETONATORS, ELECTRONIC programmable for blasting.

  4. UN3549 — MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid or MEDICAL WASTE, CATEGORY A, AFFECTING ANIMALS only, solid.

Chapter 1 changes

The information for the new UN numbers has been added into chapter 1, specifically in 1.1.3.6.2 and 1.2.3.6.3.

1.1.3.6.2 — In the first indent, replace “and 0500” by “, 0500, 0512 and 0513”.

The two new UN codes (class 1), covered by the exemption of 1.1.3.6 without 1.10 provision.

1.1.3.6.3 — In the Table, for transport category 0, Class 6.2, replace “UN Nos 2814 and 2900” by “UN Nos 2814, 2900 and 3549”.

In 1.1.3.7 b) Exemptions related to the transport of electrical energy storage and generation devices contained in equipment for its operation during transport.

The following extra text has been added, “except for equipment such as data loggers and cargo tracking devices attached to or placed in packages, overpacks, containers or load compartments which are only subject to the requirements in 5.5.4”

Also in Chapter 1 there are new definitions for;

  • Dose rate.

  • IAEA Regulations for the Safe Transport of Radioactive Material.

And the following definitions have been amended;

  • Self-accelerating temperature and self-accelerating polymerisation temperature.

  • Transport Index.

  • Tank container/portable tank operator.

  • Version numbers for GHS, UN Model regulations and Manual of Tests and Criteria updated.

Radiation level has been deleted.

In 1.4.3.3 The Filler the word maximum has been deleted, it now reads

(e) He shall, during the filling of the tank, observe the permissible degree of filling or the permissible mass of contents per litre of capacity for the substance being filled;

And in 1.8.5 The unloader is now concerned by the accident report 1.8.5.4.

1.10.3.1.2

  • A new entry for high risk dangerous goods.

  • Add the following new row after ‘Class 1, Division 1.5’:

Class

Division

Substance or article

Quantity

Tank

(l) c

Bulk

(kg) d

Packages

(kg)

1

1.6

Explosives

a

a

0

Chapter 2

2.1.3.4.3

WASTE.

Used articles, eg transformers and condensers, containing a solution or mixture mentioned in 2.1.3.4.2 shall always be classified under the same entry of Class 9, provided:

  1. They do not contain any additional dangerous components, other than polyhalogenated dibenzodioxins and dibenzofurans of Class 6.1 or components of packing group III of Class 3, 4.1, 4.2, 4.3, 5.1, 6.1 or 8 and

  2. They do not have the hazard characteristics as indicated in 2.1.3.5.3 (a) to (g) and (i).

2.2.62.1.3

The definition of “Medical or clinical wastes” has been amended to read as follows:

'"Medical or clinical wastes" are wastes derived from the veterinary treatment of animals, the medical treatment of humans or from bio-research;”.

2.2.62.1.11.1

Medical or clinical waste containing:

Category A infectious substances shall be assigned to UN No. 2814, UN No. 2900 or UN No. 3549, as appropriate. Solid medical waste containing Category A infectious substances generated from the medical treatment of human or veterinary treatment of animals may be assigned to UN No. 3549. The UN No. 3549 entry shall not be used for waste from bio-research or liquid waste;

Category B infectious substances shall be assigned to UN No. 3291

Note 1: the proper shipping name for UN 3549 is

“MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid”.

Or

“MEDICAL WASTE CATEGORY A, AFFECTING ANIMALS only, solid”.

Chapter 3

3.1.2.8.1.4

For UN Nos 3077 and 3082 only, the technical name may be name shown in capital letters in column 2 of Table A of Chapter 3.2, provided that this name does not include “N.O.S” and that special provision 274 is not assigned. The name which most appropriately describes the substance or mixture shall be used, eg

UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. (PAINT).

UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. (PERFUMERY PRODUCTS).

Table A has been updated with the new UN numbers;

  • UN0511 — DETONATORS, ELECTRONIC programmable for blasting.

  • UN0512 — DETONATORS, ELECTRONIC programmable for blasting.

  • UN0513 — DETONATORS, ELECTRONIC programmable for blasting.

  • UN3549 — MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid or MEDICAL WASTE, CATEGORY A, AFFECTING ANIMALS only, solid.

For UN 3528, 3529, 3530 — Machinery, internal combustion or fuel cell, flammable liquid powered or flammable gas powered. Special provision SP 363 has been amended so that the second indent reads as:

“For carriage that includes passage through restricted tunnels, the transport unit shall display orange-coloured plates according to 5.3.2 and the tunnel restrictions according to 8.6.4 apply.”

SP 376 Lithium batteries has also been updated

“NOTE: In assessing a cell or battery as damaged or defective, an assessment or evaluation shall be performed based on safety criteria from the cell, battery or product manufacturer or by a technical expert with knowledge of the cell’s or battery’s safety features. An assessment or evaluation may include, but is not limited to, the following criteria:

  1. Acute hazard, such as gas, fire, or electrolyte leaking;

  2. The use or misuse of the cell or battery;

  3. Signs of physical damage, such as deformation to cell or battery casing, or colours on the casing;

  4. External and internal short circuit protection, such as voltage or isolation measures;

  5. The condition of the cell or battery safety features; or

  6. Damage to any internal safety components, such as the battery management system.”

The following new special provision has been added:

“390 When a package contains a combination of lithium batteries contained in equipment and lithium batteries packed with equipment, the following requirements apply for the purposes of package marking and documentation:

  1. the package shall be marked “UN 3091” or “UN 3481”, as appropriate. If a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package shall be marked as required for both battery types. However, button cell batteries installed in equipment (including circuit boards) need not be considered;

  2. the transport document shall indicate “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” or “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”, as appropriate. If a package contains both lithium metal batteries and lithium ion batteries packed with and contained in equipment, then the transport document shall indicate both “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” and “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”.”

Chapter 4

P801a has been deleted and P801 has been amended. It applies to UN Nos. 2794, 2795 and 3028 and used batteries of UN No. 2800.

For Rigid outer packagings, wooden slatted crates or pallets the following text was added;

Batteries shall not leak under normal conditions of carriage or appropriate measures shall be taken to prevent the release of electrolyte from the package (eg individually packaging batteries or other equally effective methods).

For Stainless steel or plastics bins may also be used to carry used batteries the following text was added;

Measures shall be taken to ensure that filled bins cannot lose their content.

4.1.4.1, P903

“(5) For packagings containing both cells or batteries packed with equipment and contained in equipment:

  1. For cells and batteries, packagings that completely enclose the cells or batteries, then placed with equipment in a packaging conforming to the requirements in paragraph (1) of this packing instruction; or

  2. Packagings conforming to the requirements in paragraph (1) of this packing instruction, then placed with the equipment in a strong outer packaging constructed of suitable material, and of adequate strength and design in relation to the packaging capacity and its intended use. The outer packaging shall be constructed in such a manner as to prevent accidental operation during carriage and need not meet the requirements of 4.1.1.3.

The equipment shall be secured against movement within the outer packaging.

Devices such as radio frequency identification (RFID) tags, watches and temperature loggers, which are not capable of generating a dangerous evolution of heat, may be carried when intentionally active in strong outer packagings.

Note:

For carriage in a transport chain including air carriage, these devices, when active, shall meet defined standards for electromagnetic radiation to ensure that the operation of the devices does not interfere with aircraft systems.”

TP19 At the time of construction, the minimum shell thickness determined according to 6.7.3.4 shall be increased by 3 mm as a corrosion allowance. Shell thickness shall be verified ultrasonically at intervals midway between periodic hydraulic tests and shall never be lower than the minimum shell thickness determined according to 6.7.3.4.

Chapter 5

5.2.1.1

Amended to “The UN number and the letters "UN" shall be at least 12 mm high, except for packages of 30 l capacity or less or of 30 kg maximum net mass and for cylinders of 60 l water capacity or less when they shall be at least 6 mm in height and except for packages of 5 l capacity or less or of 5 kg maximum net mass when they shall be of an appropriate size”.

5.2.1.7.6

Added the following sentence at the end:

“Any mark on the package made in accordance with the requirements of 5.2.1.7.4 (a) and (b) and 5.2.1.7.5 (c) relating to the package type that does not relate to the UN number and proper shipping name assigned to the consignment shall be removed or covered.”

In Figure 5.2.1.9.2

  • Replace “120 mm” by “100 mm” and “110 mm” by “100 mm”.

  • In the last paragraph:

    • First sentence: replace “a rectangle” by “a rectangle or a square”.

    • Second sentence: replace “120 mm wide x 110 mm high” by “100 mm wide x 100 mm high”.

    • Fifth sentence: delete “/line thickness” and replace “105 mm wide x 74 mm high” by “100 mm wide x 70 mm high”.

5.4.1.1.1 (k)

Amended to read as follows:

“(k) for carriage that includes passage through tunnels with restrictions for carriage of dangerous goods, the tunnel restriction code given in Column (15) of Table A of Chapter 3.2, in capitals within parenthesis, or the mention ‘(─)’.”

5.5.3.4.1

At the beginning of the first sentence, “Packages” has been replaced by “Packages containing dry ice (UN 1845) as a consignment shall be marked "CARBON DIOXIDE, SOLID" or "DRY ICE"; packages”.

The following new sub chapter has been added;

5.5.4

Dangerous goods contained in equipment in use or intended for use during carriage, attached to or placed in packages, overpacks, containers or load compartments.

5.5.4.1

Dangerous goods (eg lithium batteries, fuel cell cartridges) contained in equipment such as data loggers and cargo tracking devices, attached to or placed in packages, overpacks, containers or load compartments are not subject to any provisions of ADR other than the following:

  1. the equipment shall be in use or intended for use during carriage;

  2. the contained dangerous goods (eg lithium batteries, fuel cell cartridges) shall meet the applicable construction and test requirements specified in ADR; and

  3. the equipment shall be capable of withstanding the shocks and loadings normally encountered during carriage.

5.5.4.2

When such equipment containing dangerous goods is carried as a consignment, the relevant entry of Table A of Chapter 3.2 shall be used and all applicable provisions of ADR shall apply.”

Chapter 6

6.1.3.1 (e)

In the text of the note explaining the asterisk, after the clock, the second sentence has been replaced with the following:

“In such a case and when the clock is placed adjacent to the UN design type mark, the indication of the year in the mark may be waived. However, when the clock is not placed adjacent to the UN design type mark, the two digits of the year in the mark and in the clock shall be identical.”

6.1.3.1.4 has been added in, it is confirmation of the practice already applied.

“6.1.3.14  Where a packaging conforms to one or more than one tested packaging design type, including one or more than one tested IBC or large packaging design type, the packaging may bear more than one mark to indicate the relevant performance test requirements that have been met. Where more than one mark appears on a packaging, the marks shall appear in close proximity to one another and each mark shall appear in its entirety.”

Chapter 7

7.5.11

CV36 has been amended to read as follows:

“If this is not feasible and packages are carried in other closed vehicles or containers, gas exchange between the load compartment and the driver’s cab shall be prevented and the cargo doors of the vehicles or containers shall be marked with the following in letters not less than 25 mm high:

Chapter 8

8.5, S1 (6)

In the second paragraph under the list, “substances and articles shall be supervised at all times in order to prevent” has been replaced by “substances and articles, when subject to the provisions in 1.10.3, shall be supervised in accordance with the security plan in 1.10.3.2 at all times to prevent”.

8.5, S16

The second paragraph has been replaced by “In addition, vehicles carrying more than 500 kg of these substances shall, when subject to the provisions in 1.10.3, be supervised in accordance with the security plan in 1.10.3.2 at all times to prevent any malicious act and to alert the driver and competent authorities in the event of loss or fire.”

8.5, S21

The second sentence has been deleted and after the sub-paragraphs, a new paragraph has been added to read: “In addition, these goods shall, when subject to the provisions in 1.10.3, be supervised in accordance with the security plan in 1.10.3.2 at all times to prevent any malicious act and to alert the driver and the competent authorities in the event of loss or fire.”.

Chapter 9

9.1.3.4

A new paragraph has been added after the first paragraph to read as follows:

“The vehicle shall not be used for the carriage of dangerous goods after the nominal expiry date until the vehicle has a valid certificate of approval.”

Conclusions

Due to Covid-19 there are not as many changes to ADR as usual although the changes still need to be considered and adhered to.

This article has not considered any of the changes to class 7 radioactives. Nor are these all of the changes — you MUST check the regulations or ask your Dangerous Goods Safety Advisor (DGSA) if you are unsure of the regulations.

Remember, ADR 2021 is applicable from 1 January 2021 and mandatory from July 2021.