The new Carriage of Dangerous Goods Regulations

Untitled Document

What do they mean for transporters of small loads?

The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2004, SI 2004/568 are expected to be published on 10 th May 2004. The new regulations will come into immediate effect with no transition period, although HSE have said that they will take a pragmatic approach to enforcement initially. The new regulations, which will be known as the Carriage Regulations are a major change from the old CDG package of regulations. The Carriage Regulations provide direct reference to ADR for most of the technical detail related to classification, labelling, documentation, operational requirements etc. However the new regulations also contain some 110 pages of additional information related to various exemptions, derogations, additional requirements, etc which those involved in the transport of dangerous goods will need to digest in addition to the 500+ pages of ADR!

This article outlines some of the main changes in relation to the carriage of small quantities of dangerous goods, however, there are many differences between the old CDG Regulations and ADR, and readers should check the regulations carefully themselves to be sure they are in compliance. In particular, Class 1 (Explosives) and Class 7 (Radioactive Materials) requirements are not covered in this article. This article discusses two types of exemptions:

  • Limited Quantity Packages where articles or substances are exempt from the provisions of ADR, provided they meet certain requirements, and in particular when the size of the packages do not exceed certain limits.
  • Small Loads where relaxations to some of the provisions of ADR apply, provided the total quantity of dangerous goods on a transport unit (excluding limited quantity packages) does not exceed certain limits. These are sometimes referred to as Limited Quantity Loads, but should not be confused with Limited Quantity Packages.

Limited quantity packages

The Limited Quantity package provisions of ADR are set out in Chapter 3.4, and are significantly different to the old CDG Regulations. Under ADR, Dangerous Goods are assigned a 'LQ' Code in column 7 of Table A (the Dangerous Goods list). This is then checked against the table in ADR 3.4.6 which gives details of the maximum contents per inner packaging and per package.

It should be noted that the package sizes allowed under ADR differ significantly to the old CDG regulations for many substances, and not all substances which were previously allowed to be carried in limited quantities can still be carried in this way.

Marking of Limited Quantity packages is also different. Under ADR, the UN No. of the Dangerous Goods is displayed in a diamond-shaped frame. If goods with more than one UN No. are included in a package, then all UN Nos. should be included in the diamond, or the letters LQ may be displayed instead. However, it is worth noting that the LQ mark is not acceptable for sea transport,

Figure 1 Example limited quantity markings

so if your goods are going to be transported to the Isle of Wight or the Scottish Islands for instance, you should not use it.

Other differences to the old CDG Regulations are that all limited quantity packages must be composed of small inners in combination packs - either fully sealed cartons or shrink wrapped trays. The GB derogations which allowed transport of loose packs will cease. However, regulation 7(4) of the new Carriage Regulations provides a derogation allowing small quantities of dangerous goods to be distributed to retailers and end users, as long as the total quantity of such goods on the vehicle does not exceed 30 kg/l per substance or article (interpreted as a stock keeping unit) and not more than 333 kg/l in total on the vehicle. Readers who regularly split packages for delivery to end-users are advised to put in place procedures to ensure these limits are not exceeded. Returns from customers, however, will not meet the requirements for this derogation and will need to be fully boxed to meet the usual Limited Quantity requirements.


When a small load of dangerous goods is being carried which does not meet the requirements for limited quantity packages, some provisions of the regulations may still be relaxed if the total quantity of dangerous goods does not exceed certain thresholds. The requirements for loads to take advantage of these relaxations are laid down in Chapter of ADR. However, for GB transport, regulation 3(7) makes some amendments to ADR.

The relaxations are based on a system of transport categories to which the dangerous goods are assigned, ranging from category 0 for the most dangerous goods, through to category 4 for less dangerous goods. The transport category for a particular item can be found in Column 15 of Table A (the Dangerous Goods list). If all the goods are in one transport category and the quantity to be carried does not exceed the limit in the table in ADR as modified by Reg 3(7), or, if the goods are of more than one transport category, the value of the load calculation as described in ADR =1000, then the relaxations described in figure 2 will apply.

Further, where these small load conditions are met, regulation 7(16)of the Carriage Regulations also exempts companies who are both consignor and carrier from producing the transport information and documentation described in ADR However, this will not apply when a third party carrier is used, as the carrier may also be transporting other dangerous goods and will need this information to check separately whether the small load relaxations apply.




Placarding and marking of containers etc


Documentation - instructions in writing

7.2, except for V5, V7 and V8 of 7.2.4

Carriage in packages

CV1 of 7.5.11

Prohibitions on loading and unloading in public places

Part 8, except for, 8.2.3, 8.3.4,8.4, and S1(3), S1(6), S2(1), S4 , S14-S21 of 8.5

Vehicle crews, equipment, operation and documentation

Part 9

Construction and approval of vehicles

Figure 2 ADR relaxations for small loads

Further information

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