Changes in the ADR Convention - what to remember about after the amendment

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Although the amendment of the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) came into force on January 1, 2017, the older version could have been used until the end of June. Not everyone was able to take advantage of the transition period and get ready for the new solutions. What must be remembered about in order to ensure appropriate conditions for transported goods and not to pay penalties for errors in documentation?

Changes in the Convention are nothing surprising for ADR advisers. The agreement is amended every two years (always in odd years). Its unabridged and current version can be found on the website of the UN Economic Commission for Europe (UNECE).

For someone just starting their adventure with dangerous goods, the issues related to chemical names, IUPAC nomenclature, or the slogan "fish and tree", may sound a bit complicated or even exotic. There is nothing to be afraid of, however. All data necessary for preparing correct transport documents should be available in material safety data sheets (MSDS) in section 14 (Transport information) and in the Agreement in question.

The list of the most important changes for carriers and logistics operators introduced in ADR 2017 can be found below.

NAMES AND IDENTIFICATION NUMBERS OF GOODS

ADR 2017 has introduced changes in shipping names. However, it is worth paying a little more attention to the names as some countries (including Poland) have taken advantage of the amendment to standardise chemical names in line with the nomenclature of the International Union of Pure and Applied Chemistry (IUPAC).

Changes in Appendix A introduce eight new UN numbers, half of which refer to polymer materials. There have also been some changes with reference to packagings and markings of goods as well as a new label for lithium batteries has been introduced. Label 9A applies to UN 3090, 3091, 3480, 3481 (see below):

 

 

One of the most frequently made errors connected with ADR is entering a wrong shipping name for goods where the UN number has two or more names assigned (e.g. UN1263 Paint or Paint Related Material) In the documents we enter one of those names which is appropriate for shipped goods. If the shipment contains paints and related materials with the same UN number and Packing Group, these data must be entered separately. One must pay attention to this as the consequence of a wrong entry is a financial penalty not only for the carrier but also for other links of the logistics chain (the consignor and the logistics operator).

 

TECHNICAL NAMES

It is worth remembering that selected dangerous goods require specifying the name by providing a technical name (special provision 274). Some use the trade name instead of this, which is against legal requirements and may result in financial consequences for the carrier and other members of the supply chain. 

According to the ADR Agreement, the technical name is the recognized name of the chemical or biological substance (ingredient which justifies the classification as a dangerous substance). In case of mixtures, technical names of maximum two ingredients are provided which determine the ADR classification (information from section 14 of MSDS).

INSTRUCTIONS FOR DRIVERS

Amendment of appendixes to the ADR Convention resulted in the necessity to prepare new written instructions for drivers. Their updated version in national languages of signatories of the Agreement can be found on the website of UNECE and on websites of relevant ministries.

ADR 2017 has not introduced any revolutionary changes in this area. One could rather refer to is as updating the former instructions with new, previously unprecedented hazards (e.g. ban on using e-cigarettes by drivers in case of an accident or a hazard), or adding a new sticker 9A in class 9 (which has already been mentioned).

ENVIRONMENTALLY HAZARDOUS SUBSTANCES

The amended ADR table directly points to just two substances which are environmentally hazardous (bearing UN numbers 3077 and 3082). For other goods, the consignor is under obligation to specify if the substance, mixture or product poses a risk for the environment. One should rely on the amended Appendix A in which the description of the criteria for goods dangerous for the aquatic environment complies with the criteria of Regulation no 1272/2008 of the European Parliament and of the Council .

To simplify, it can be said that apart from the aforementioned goods bearing UN numbers UN 3077 and 3082, goods described and environmentally hazardous in transport documents will be goods which have a marking of the "fish and tree" on the packaging and have the hazards CLP H400, H410, H400 or H411 assigned on the label. Those goods required entering the information "ENVIRONMENTALLY HAZARDOUS" on the transport document for dangerous goods.

DANGEROUS GOODS PACKED IN LIMITED QUANTITIES (LQ) AND GOODS PACKED IN EXCEPTED QUANITIES

The amendment also introduces specific information on the markings of transport packagings beyond the previously used ones.

Each overpack (e.g. pallet with cartons) must now bear a sign "overpack" in the local language. In case of export, one must also add an additional sign in English, German or French (e.g. Overpack)  One should also remember that the provision also defines the minimum height of the letters at 12 mm.

 

 

Sources:

https://www.unece.org/trans/danger/publi/adr/adr2017/17contentse0.html

https://www.unece.org/trans/danger/publi/adr/adr2017/17contentse0.html

https://www.unece.org/trans/danger/publi/adr/adr_linguistic_e.html

http://eur-lex.europa.eu/legal-content/Pl/TXT/?uri=CELEX%3A32008R1272

https://www.unece.org/trans/danger/publi/adr/adr2017/17contentse0.html

https://www.unece.org/trans/danger/publi/adr/adr_linguistic_e.html

http://eur-lex.europa.eu/legal-content/Pl/TXT/?uri=CELEX%3A32008R1272

 

16.08.2017
Grażyna Łukasik

Grażyna Łukasik

SHE Manager

Runs SHE projects (Safety, Health and Environment)in Raben Group. Specializes in occupational health and safety as well as in ergonomics of workstations. A DGSA Advisor since 2003.

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