Last reviewed 2 January 2020
In this article on the transport of dangerous goods by road, Caroline Raine discusses exemptions that may be used to reduce the requirements when transporting dangerous goods. Caroline will highlight the small load exemptions, limited quantities and special provisions.
The current legislation in the UK governing the carriage of dangerous goods is:
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 as amended in 2011.
ADR current version applicable as from 1 January 2019 — European Agreement Concerning the International Carriage of Dangerous Goods by Road — Volumes I and II.
The diagram above shows when the different requirements apply.
There may be an ADR exemption or UK derogation in place, which means that the dangerous goods in question are exempt from the regulations. Now it may be that certain conditions must apply, or it may be that relaxed requirements are applicable. Dangerous goods may be permitted to be transported in limited quantities if the threshold applies or the goods may fall under the small quantity loads. If neither of these apply the goods must be transported under the full requirements of ADR.
Exemptions for the transport of dangerous goods by road can be found in Chapter 1.1.3 of ADR and the current UK Carriage of Dangerous Goods Approved Derogations document.
Special provisions for substances may provide some exemptions with conditions.
A few examples of applicable exemptions by road are:
a Maximum of 60 litres can be carried in fuel containers such as Jerri cans in a vehicle
moving goods between private premises across a public road
small quantities of substances and articles can be carried with relaxation to the regulations
<5 kg/litres of environmentally hazardous substances is exempt from all modes
machinery which contains dangerous goods, ie fuel, provided that leaks are prevented
dangerous goods packaged and carried in limited quantities provided conditions are met.
Please note that this list is not exhaustive.
ADR 18.104.22.168 — exemptions related to the nature of the transport operation
The provisions laid down in ADR do not apply to the carriage undertaken by enterprises which is ancillary to their main activity, such as deliveries to or returns from building or civil engineering sites, or in relation to surveying, repairs and maintenance, in quantities of not more than 450 litres per packaging, including intermediate bulk containers (IBCs) and large packagings, and within the maximum quantities specified in 22.214.171.124. Measures shall be taken to prevent any leakage of contents in normal conditions of carriage. These exemptions do not apply to Class 7.
Carriage undertaken by such enterprises for their supply or external or internal distribution does not fall within the scope of this exemption.
ADR table A, column 7a lists the Limited Quantity (LQ) value for each substance or article, Chapter 3.4 states the limited quantities requirements.
LQ are often small receptacles — eg the sort that go into the retail distribution chain (such as DIY stores) — which contain dangerous goods and are packed in boxes or on shrink-wrapped trays. Tins of paint in boxes are one example.
Under the Carriage of Dangerous Goods Regulations, LQ goods can be carried without having to meet the usual marking requirements under the International Agreement on the Carriage of Dangerous Goods by Road — known as ADR. The principle of LQ exemption is that an acceptable level of safety is assured, providing your goods receptacles are in a box or a shrink-wrapped tray. You must however meet certain conditions to transport “broken down” LQ packages.
Dangerous goods are assigned an LQ value, the maximum volume per inner package that can be used. The maximum mass of combination packaging and substance or article cannot be more than 30kgs which includes the inner packaging and strong outer packaging. Shrink- and stretch-wrapped trays cannot be more than 20kgs.
UN-approved packaging does not have to be used for LQ goods, although general packaging rules do apply. Each LQ category has specific packaging limits and particular labelling requirements, depending on the category they are in. LQ goods may be packed together with other articles or substances, as long as they will not react dangerously if leakage occurs.
LQ Packaging must be:
good quality, strong enough to withstand shocks and loadings normally encountered during carriage
constructed and closed to prevent loss of contents
no residues to the outside of the packaging
not affected by the direct contact with the dangerous goods
when filing sufficient ullage must be left to ensure no leakage
marked with black tipped diamond label, orientation labels and Overpack Labels where required.
Limited Quantities of Dangerous Goods packed in limited quantities are not subject to other provisions of ADR.
Transport categories — small load thresholds
Transport categories are used to determine the amount of packaged dangerous goods that can be carried under small quantity load relaxations to the regulations before the full ADR requirements apply. Chapter 126.96.36.199 of ADR and Table A column 15 for the Transport Category for each substance or article.
Small Quantity Loads — Exemptions: For dangerous goods at or below the small load quantity thresholds, the following general exemptions apply and some requirements still apply.
No ADR Driver Training Certificate or license required, but basic training in carriage of dangerous goods is required.
No orange warning plates required.
No need to carry driver Instructions in Writing.
The vehicle must carry a minimum of a 2kg fire extinguisher in cab of vehicle.
Smoking is not permitted.
Applicable stowage, parking and supervision rules apply.
Packaging, marking and labelling requirements apply.
The small load thresholds are determined by the transport category and are listed in the table below.
Substance Transport Category
Total Quantity Per Vehicle (kg or litres)
TC0 — Extremely Dangerous
TC1 — Very Dangerous
TC2 — Medium Danger
TC3 — Low Danger
TC4 — Very low danger
The kilogram or litre threshold relate to:
For mixed loads the following calculation must be used to determine the load size.
Quantity x 50
Quantity x 3
Quantity x 1
= (Maximum, 1000 units per vehicle)
For loads comprising different Transport Categories, apply the multiplier above.
If the sum of x, y and z exceeds 1000 units (kg/litres) then the load falls into the full ADR load provisions.
ADR2019 introduced the requirement to show the small load calculation on the transport document.
Fully regulated loads and special provisions
If the dangerous goods that are being transported are unable to be transported under one of the exemptions, as limited or excepted quantities or via the small load exemption then they must be transported under the full requirements of ADR.
When transporting goods under the full requirements of ADR it is important to check the special provisions applied. The special provisions can either be exemptions or may state additional requirements to ensure tighter control.
The special provisions can be found in column 6 of the dangerous goods list for each UN number.
The transport of dangerous goods is heavily regulated to ensure the safety of all involved in the process.
There are agreements in place to reduce the onerous requirements where the risk is lower.
Rather than assuming the load must be fully regulated, always check to see if any of the exemptions, derogations, limited quantities, small load thresholds or special provisions can make the load easier and cheaper to transport.