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.

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. Although known familiarly as the Kemler system, there is no mention whatsoever of his name in RID or ADR. 

Professor Kemler’s system envisaged a plate to be shown, initially on tanks but now extended to bulk, in which an HIN is shown in the upper part and the UN number in the lower. The HIN explains more about the dangers of the dangerous goods being carried by indicating:

• the extent to which a substance may be flammable, toxic, corrosive, etc.
  
• subsidiary dangers.
  
• the risk of violent reaction of a substance or mixture becoming in contact with water.
  

RS: In practice, what does these mean? For example, we have different placarding requirements in the UK for bulk shipments – how would these be handled for exports?

CR: The EAC codes and the Hazchem system is not recognised outside the UK (apart from Australia, Malaysia and New Zealand), so Kemler placards are often seen in the UK on vehicles being used for international road and rail transport under ADR and RID.

RS: CDG and ADR have different emergency codes. What do these codes mean?

CR: CDG: The EAC’s shown on the Hazchem placards consist of a two or three-character code that must be displayed on all Great Britain-registered road and rail vehicles that carry dangerous goods in tanks or in bulk on domestic journeys within the UK.

EACs provide a quick assessment to the emergency services of what actions should be taken during an incident. The fire and police services use the specific characters and numbers to determine which actions may be necessary, during the first few minutes of an incident involving dangerous goods.

The idea behind the EACs is that emergency responders, especially the fire service, carry a small card with them known as the “Hazchem Scale Card” that translates the EACs into immediate action to be taken at the scene of an incident until specialist advice and help can be obtained.

EACs are characterised by a single number (1–4) and either one or two letters (depending on the hazard).

The number in the EAC indicates a suitable fire-fighting method in ascending order of preference.

• Coarse water spray is signalled with 1.
  
• Fine water spray is signalled with 2.
  
• Normal foam is signalled with 3.
  
• Dry agent is signalled with 4.
  

The EACs list occasionally shows an EAC to have a (dot) before the 2 or 3. The dot is not shown on the vehicle plates, only in the published list.

• Alcohol resistant foam is signalled with 2, but if not available use fine water spray.
  
• Alcohol resistant foam is signalled with 3, but if not available normal foam can be used.
  

The first letter indicates:

• whether the substance or mixture is liable to be violently reactive (shown by P, S, W or Y).
  
• the extent of personal protective clothing and the equipment needed in order to approach the scene (liquid-tight suits, shown by P, R, W or X, or BA and fire kit, shown by S, T, Y or Z).
  
• whether the spillage needs to be contained, or whether the substance or mixture can be diluted with water.
  

It should be noted that the dilution advice does not necessarily accord with protection of the environment considerations so that even if dilution is attempted, the diluted substance or mixture should not normally be allowed to run off into the soil, drainage systems or water courses.

The second letter, if any is used, is “E”. This used to stand for “Evacuate” but is now interpreted as “Public Safety Hazard”, with people being warned to stay indoors with all doors and windows closed, preferably in rooms upstairs and facing away from the incident. Ignition sources should be eliminated and any ventilation stopped. As the effects could spread beyond the immediate vicinity, all non-essential personnel should be instructed to move, for example, at least 250m away from the incident. Evacuation may need to be considered after consultation with the incident control, police and product expert, but in most cases staying inside buildings will be the safer course of action.

The EACs list also provides codes for additional personal protection (APP) which are not shown on the vehicle placards.

ADR: HINs consist of two or three figures and, in general, the figures indicate the following hazards.

• 2 — Emission of gas due to pressure or to a chemical reaction.
  
• 3 — Flammability of liquids (vapours) and gases or self-heating liquids.
  
• 4 — Flammability of solids or self-heating solids.
  
• 5 — Oxidising (fire-intensifying) effect.
  
• 6 — Toxicity (or risk of infection).
  
• 7 — Radioactivity.
  
• 8 — Corrosivity.
  
• 9 — Risk of spontaneous violent reaction.
  

The letter “X” indicates that the substance will react dangerously with water.

RS: In the UK there is a requirement for a telephone number to be shown “In case of emergency”. What kind of a response would the emergency services or enforcement officers expect, should they check the number?

CR: Callers to the emergency number can expect to receive specialist advice on the properties and hazards of the dangerous goods whenever the tank is in transport, including stops. This is a regulatory requirement and often means 24 hours a day, 365 days a year service to cover when the tank is in transport. 

Caroline Raine is an experienced independent DGSA and consultant in the areas of chemical safety legislation in the UK and Europe for both public sector and commercial organisations. 

Caroline is a former Chair of the British Association of Dangerous Goods Professionals (BADGP) and has been an active member of the Chemical Hazard Communications Society (CHCS) for many years.

Having a strong background in analytical chemistry with experience of laboratory and experimental work, she has an excellent understanding of the regulations governing the transport, supply and use of chemicals. 

17-19 June Multimodal (NEC)

Multimodal is the logistics industry’s annual exhibition and conference. Labeline will be exhibiting in the BIFA Village area, demonstrating the DGOffice software solution for creating compliant DG documents.

About Labeline…

Worldwide, Labeline Intl. has maintained its position as the leading authorised distributor for the regulations covering the transport of dangerous goods by road, rail, sea and air. 

As the only authorised reseller in UK and Ireland for all modes of transport, Labeline is at the forefront of compliance when it comes to dangerous goods and stocks 1,000’s of Compliant regulations for ADR, IMO, IATA and ICAO publications.

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