The Exemption related to quantities carried per transport unit of ADR 220.127.116.11 is often responsible for some confusion by being referred to as a full exemption from ADR.
Indeed, it is listed under the ADR Chapter on Exemptions, 1.1.3, but does not exempt the undertaking from all of the ADR provisions.
The exemption allows for vehicles, referred to in ADR as Transport Units, carrying small loads of dangerous goods, typically less than 1000kg, in packages, via road, to be exempt from some of the main provisions of ADR.
For example vehicle marking, equipment – (except for 2 kg fire extinguisher) and driver ADR training (but general awareness training still required).
Whether the exemption is applicable is calculated as follows.
Transport categories of 0, 1, 2, 3 or 4 are assigned to each UN Number entry in Column 15 of the dangerous goods list, Table A of ADR Chapter 3.2.
Empty, uncleaned packages which formerly contained material classed as dangerous goods are assigned to transport category 4, unless the previous contents was assigned to category 0, in which case the empty package is still assigned to category 0.
Single Loads or All One Category
Where the dangerous goods to be carried on the transport unit (TU) are of the same transport category given, the threshold limit is as given in 18.104.22.168.3:
Except for UN Nos. 0081, 0082, 0084, 0241, 0331, 0332, 0482, 1005 and 1017 which are given a maximum of 50kg.
Also please note GB Derogation 5 gives higher thresholds for certain Class 1 goods.
The maximum total quantity per transport unit referred to above is given as follows;
- For articles it is described as the gross mass in kg, except for explosives and dangerous goods in machinery where it is the net mass of the explosive or dangerous goods contained in the machinery.
- For solids, liquefied gases, refrigerated liquefied gases and dissolved gases it is given as the net mass in kg and
- for liquids, it is the total quantity of dangerous goods contained in liquids (thankfully re-phrased in ADR 2015)
- for compressed gases it is the capacity of the receptacle(s) in litres. (Note Aerosols are “articles” and not “receptacles”).
For example, Fireworks of UN 0337 (Class 1, 1.4S) are Transport Category 4 and therefore an unlimited amount can be carried per transport unit without application of the majority of ADR provisions.
For dangerous goods assigned different transport categories in column 15 of 3.2 Table A, the total quantity of each transport category is multiplied by a set quantity as given below. Excluding Category 4, the sum of the totals must not exceed 1000.
For example, ASBESTOS, CHRYSOTILE (UN 2590, PG III) is assigned to transport category 3 and ASBESTOS, AMPHIBOLE (UN 2212, PG II) is assigned to transport category 2.
It is possible to carry up to 1000 kg of UN 2590 therefore or up to 333 kg of UN 2212, with no other dangerous goods of transport categories 1, 2 or 3 and meet the requirements for the exemption.
If both types are to be carried in the same transport unit, the total net mass in kg of UN 22112 (TC 2) multiplied by 3, added to the net mass in kg of the UN 2590 (TC 3) must not exceed 1000.
Non Applicable Provisions Under the Small Load Threshold
The following table is a summary of ADR provisions which are not applicable under the small load threshold.
The remaining ADR provisions are still applicable, including packaging, marking and labelling requirements, vehicle supervision requirements if applicable and general awareness training, a record of which must be kept.
If you require training or advice to help your organisation comply with the requirements for transporting dangerous goods, please contact us. We’re always happy to help.