Truck and Track Summer 2025 www.truckandtrack.com 66 DANGEROUS GOODS ADR 2025 becomes mandatory on 1st July, as highlighted in the Spring edition of Truck and Track. However, it is The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations that are referred to for enforcement in the UK. These Statutory Instructions are updated periodically so it is important that the latest versions are referred to. So, how does this differ from other states across the world that have implemented ADR (and those that are in the process of doing so, such as Mexico and UAE) - and how are the regulations used to enable imports and exports to and from the UK? To help understand the differences and how the rules interact, I first asked Caroline to explain what the relevant regulations are. CR: The EU Directive 2008/68/EC on the Inland Transport of Dangerous Goods Directive (ITDGD) requires Member States to apply the provisions of ADR (road), RID (rail), and ADN (inland waterway) to domestic transport, subject to some national derogations and additional provisions. In addition to EU Member States, other countries around the world have adopted ADR. RS: So, ADR is effectively a directive and not the law within the UK? CR: I suppose that is one way of looking at it, the EU Directive is implemented via ADR.. However, in the UK, the main regulations covering the consignment and carriage of dangerous goods are as follows: ■ Since 1 July 2009, the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG2009) have applied. These make the current editions of ADR and RID applicable. They have been amended by Carriage of Dangerous Goods and Transportable Pressure Receptacles (Amendment) Regulations 2011 (SI 2011 No. 1885) (CDG2011) to implement the requirements of Directive 2010/35/EU on transportable pressure equipment (new TPED). Other minor amendments have also been made. ■ In Northern Ireland, separate Statutory Rules apply. However, these reflect what is in the British rules. Consequently, those operating in or to Northern Ireland normally act as if the British regulations also apply there. ■ In October 2020, the UK published The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) (EU Exit) Regulations 2020. It amends The Carriage of Dangerous and Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009) to ensure that Great Britain has a functioning statute book at the end of the transition period. It came into force on 1 January 2021 and was further updated in 2021. Brexit had very little impact on the transport of dangerous goods regulations and requirements. This is because the regulations come from the UN rather than EU. RS: What are the primary differences between ADR and the CDG Regulations? CR: There are several differences that are listed in the CDG Regulations, however the main variation involves vehicle placarding. In the UK, the Hazchem Emergency Action Codes (EAC’s) must be used for the domestic transport of dangerous goods in tanks and in bulk. This system of marking differs from the ADR requirements, which use Hazard Identification Numbers (HINs), also known as the Kemler Code, which all other tankers and bulk vehicles must use. EACs were first introduced in the early 1970s following a fatal incident on the M6 Motorway near Wigan. A nurse was on her way to help out at the scene of a multiple accident when she walked through a stream of powerful acid spilling from a road tanker. She died as a result. A voluntary Code of Practice using EACs was introduced and is referred to as the Hazchem system. The Hazchem system was incorporated into UK law in 1981 with the first road tanker regulations. Hazchem marking consists of a large one-piece panel with fixed dimensions containing the primary hazard danger symbol against a white background on the upper right hand-side and, to the left of it, an orange panel divided horizontally in two. The EAC is shown in the top section and the UN number (which identifies the substance) at the bottom. Occasionally, a second danger symbol may be shown next to the Hazchem placard, where required, to indicate environmental hazards in addition to the primary hazard. This is commonly seen on petrol tankers, for example. Hazchem Placard for Petrol (UN1203) At around a similar time, a French professor, Professor Kemler, developed a system for marking tanks which was soon adopted by the European Agreements Concerning the International Carriage of Dangerous Goods by Rail (RID) and ADR authorities. Dangerous Goods by Road – how is ADR interpreted differently in the UK than elsewhere? In the UK, ADR is not the sole reference for the transport of dangerous goods by road Labeline’s Richard Shreeve asks highly respected and experienced dangerous goods professional, Caroline Raine, to explain how the rules are enforced
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