Dr Colin Hewlett

 DGSA consultant














UK regulations

ADR regulations

IMDG code




Safety Data Sheets

Supply labelling



 Use of chemicals at work



















Chemicals and Transport Limited






What are Dangerous Goods ?


Goods dangerous for transport are grouped into nine main United Nations hazard classes according to their properties. Some of these classes are further sub-grouped into divisions:

Class 1    Explosive

Class 2    Gases

Class 3    Flammable liquids

Class 4    Other flammables

Class 5    Oxidising and organic peroxides


Class 6    Toxic and infectious

Class 7    Radioactive

Class 8    Corrosive

Class 9    Miscellaneous

Environmentally Hazardous




International Agreements -The UN recommendations


Transportation legislation follows in principle, but not always in detail, the UN Recommendations and Model Regulations (the Orange Book) whose principle of identifying each hazardous substance with a UN Number and specifying for each their principal and subsidiary hazard classes and packing groups has been adopted by all modes of transport, road, rail, air, sea and inland waterways. Although great efforts have been made to harmonize these various modal regulations, there still remains difference between them. The Orange Book contains recommendations for the transport regulators to take into account when framing their regulations but do not in themselves have any force of law. Dangerous goods are classified into nine danger classes (some of which are sub-divided into divisions, eg. 6.1 toxic substances) dependent on the major kind of danger that the substance presents; other risks may be present and these are known as subsidiary risks. Each class or division has a diamond shaped label with a pictorial representation of the danger. The level of danger is indicated by the Packing Group, PGI high danger, PGII medium danger and PGIII low danger. The packing groups form the basis of the allocation of Transport Categories (0 – 4 where Transport categories 1, 2 and 3 correspond in general with the UN packing group but note that this is not a universal rule).

Dangerous goods within the UN classes 1 – 9 are mostly chemicals, either individually named substances eg. 'Tetrachloroethylene', or generic descriptions eg. 'Flammable liquid N.O.S.' (Not Otherwise Specified) but also articles eg. 'Matches, safety'. The criteria for classification in the various UN classes are largely harmonised between the transport modes, for example flammable liquids, class 3 are defined (with some exceptions) as those having a flash point not exceeding 60°C and the initial boiling point will determine the appropriate packing group (and hence the Transport Category). These criteria allow the correct classification of goods which are not individually named. There are procedures for correctly classifying materials possessing multiple hazards.



UK Transport LegislationThe Carriage Regulations





ADR - Carriage of Dangerous Goods by Road

The British transport regulations (The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations) refer to ADR for classification criteria. Dangerous goods are defined as those which are listed in ADR either as individually named substances or N.O.S entries. All dangerous substances are assigned a UN Number and ADR carries two lists, one ordered by UN Numbers and the other alphabetically. Confusingly, the lists can use different chemical names from the Approved Supply List used by the CHIP/CLP regulations. Environmentally Hazardous Substances are not named individually in the indexes but are classified as UN 3082 (Environmentally hazardous substance, liquid, N.O.S.) or UN 3077 (Environmentally hazardous substance, solid, N.O.S.). The latest editions of the various carriage regulations have introduced the application of a new Environmentally Hazardous mark

Carriage of goods by international journeys by road are carried out under ADR (currently the 2013 edition, applicable from 1st January 2013 and mandatory from 1st July 2013)



Which rules apply ?


The GB packaging and labelling requirements of The Carriage Regulations are suspended for international road journeys under ADR and for carriage by road to a port for onward shipment by sea or to an airport for onward shipment by air when the IMDG Code or ICAO Technical Instructions apply respectively. Note that the consignee may carry the responsibilities of a consignor for imported goods where the supplier has no place of business in Great Britain and the consignee has control over the carriage of the goods in Great Britain.



Duties of Consignors and Transport Operators


Duties imposed by the transport regulations can be summarised as follows:

Consignor duties: classification, identification, packaging selection, warning marks and labels, preparation of a transport document for the transport operator.

Transport Operator duties: selection of vehicle and safety equipment, placarding vehicle, loading/unloading/stowage procedures, emergency instructions, parking and supervision, driver training.



Consignor duties


Selection of packagings and labelling - UN specification packaging must be used for dangerous goods which are to be transported but there is an exemption for limited quantity receptacles in combination packages. Marking and labelling of packages is required for packages containing inner packagings above this threshold capacity above which the packages must be marked with the UN Number plus the class (primary) danger label and subsidiary hazard label if applicable; the signs are 100mm diamond shaped labels conforming to the designs given in the regulations.

Documentation – the consignor must supply a transport document to the operator giving the following information:

UN number

Proper Shipping Name (PSN)

Hazard Class

Packing Group

Tunnel Restrictions Code


Control temperature and emergency temperature, where appropriate

The mass/volume of each package and number of packages or in the case of tank/bulk movements, the net mass/volume

Name and address of Consignor

Name and address of Consignee

Consignor's declaration



Transport Operator duties


The operator must ensure that the vehicle is suitable for the load and carries the mandated safety equipment and that the driver has a copy of the transport document for each consignment carried and a total load summary plus emergency instructions and the vehicle placarded (orange rectangle for packaged goods). The driver must hold and carry a Driver Vocational Training Certificate whatever the vehicle capacity. There are relaxations from the regulations when goods are packed in receptacles below the Limited Quantity limits and also when the load is less than Exempted Load limits.




Enforcement of legislation on the transport of dangerous goods by road within the UK falls to DfT.



Code of practice and Guidance Note


The Department for Transport publishes an explanatory booklet “Working with ADR” (Publication reference 04DFT01) which is available as a download on the DfT website.




Carriage by sea - IMDG code

The 2012 edition of IMDG came into first use on the 1st January 2013 with a 12 month transition period. In UK law, IMDG is mandatory (The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997).

Some significant difference from the UN recommendations are as follows:

Dangerous Goods List - IMDG adds some additional special provisions to the UN recommendations.

Special requirements for shipping documentation:

In the case of flammable substances, the flash point should be indicated.

The words “Marine Pollutant” if applicable with the name of the constituent in the proper shipping name.

Special requirements for package marking:

The Proper Shipping Name shall be marked on the package.







Chemicals and Transport Limited

6 Lime Villas,  High St,  Elham, 

Canterbury,  Kent CT4 6TA. UK

Registered No. 4689082 England




Tel: +44 (0)1303 840116



Last updated: January 2013