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International Carriage of Dangerous Goods by Road : ADR 2015 is now applicable ! [EU]

The new version of the European Agreement concerning the International Carriage of Dangerous Goods by Road, adopted on 30 September 1957 (known as “ADR“) is applicable as from 1 January 2015.  Apart from the changes, mainly formal, of the written procedures to be available in the vehicle, which will be applicable from 30 June 2017, this new version of the ADR will become mandatory as from 30 June 2015, until when the previos version of (ADR 2013) may continue to be used due to the transitional measures provided for in Chapter of Annex A.

ADR New total exemptions : 


The transport of certain lamps

New exemptions related to transport lamps containing dangerous goods exclude the application of all the requirements of ADR to the transport of (point
  • lamps collected directly from individuals and transported to a collection point or recycling;
  •  lamps or used lamps containing not more than 1g of dangerous goods, and packed in packages containing not more than 30g of dangerous goods;
  • lamps containing only gas group A (asphyxiant) and O (oxidizing).

Transportation of fuel contained in a “non-road mobile machinery”

It is now specified that the transportation of fuel in the tank of non-road vehicles is not subject to ADR requirements (section

ADR New partial exemptions :

Exemptions due to quantities carried per transport unit

For liquid dangerous goods, it is not the nominal total capacity of the container, but the amount of dangerous goods actually contained in the container, which must be taken into account for the calculation of maximum permissible quantities.

Exemption for certain substances hazardous for the environment (UN 3077 and UN 3082)

From now on, when these substances are transported in single or combination packagings containing a net quantity per simple packaging or lower than 5l for liquids, or having a mass lower than or equal to 5 kg for solids, are not subject to any other provision of the ADR provided that the packaging meets the general provisions, and to (point 3.3, special provision 375).

New classifications and categories

Soiled packaging

From now on, soiled packaging that will not be reused can be classified under UN No 3509 and thus it will be possible to take into account the classification of hazardous waste in the packaging. However, only the following packagings shall be classified under this UN number: (except desensitized explosives), 4.1 (except autoreactive and desensitized explosives), 5.1, 6.1, 8, 9 (except PCBs, PCTs and Asbestos) and packaging not belonging to group I or entitled to limited quantities.

Adsorbed gases

A new section concerning gaseous materials is provided for in point Adsorbed gases are defined as gases which, when packaged for transport, are adsorbed on a porous solid material resulting in an internal pressure of the container below 101.3 kPa at 20 ° C and less than 300 kPa at 50 ° C. These gases are under the UN codes No. 3510-3526.

Radioactive materials

For radioactive materials, a new UN number 3507 is assigned and it concerns uranium hexafluoride, radioactive materials, less than 0.1 kg per package, non-fissile or fissile excepted, in excepted packages. Specific requirements for packages containing this material are set out in point and following. Please note, this material does not fall within class 7 (radioactive materials), but within class 8 (corrosive). Consequently, the provisions of the ADR referring to “Class 7 materials” now concern “radioactive materials” in order to cover all radioactive materials regardless of their class. To note, concerning these goods, many amendments were made to the ADR, in particular as regards point 1.7 (General provisions for Class 7), due to the inclusion of the new Regulation on the transport of radioactive materials of the IAEA (international Atomic Energy Agency).

Amended sections: asbestos

Asbestos is no longer classified into the following categories: white, blue and brown asbestos. These categories are grouped only under the UN No. 2212. Only the chrysotile remains under the UN No. 2590.

Amendments to the instructions in writing to be kept in the vehicle

A first amendment, mainly formal, consists in a change of vocabulary: on the first page of the written instructions in the first indent, “engage the brake system” is replaced by “apply the braking system.” The second amendment aims to clarify that the use of the electronic cigarette is prohibited. These amendments must be included in the written instructions no later than 30 June 2017.

Smoking ban

As indicated above, from now on the smoking ban also concerns the use of electronic cigarettes.


It is now clarified that the section No. 1044 (Fire extinguishers with compressed or liquefied gas) only concern (special provision 225):
  • portable fire extinguishers for handling and manual operations;
    •   fire extinguishers to be placed on aircraft;
    • fire extinguishers mounted on wheels for manual handling;
    • fire-fighting equipment or devices mounted on wheels and to a wheeled cart or to a transport vehicle similar to a trailer;
    • extinguisher composed of a pressure drum and a non-wheeled equipment and manipulated for example by means of a forklift or a crane in the state loaded or unloaded.
To note, these extinguishers are not subject to the requirements of ADR if they are provided with protection against accidental openings and placed in a robust packaging. To note, the new version of the ADR states that for large extinguishers, the “robust” packaging ” is not necessary if they comply with the requirements under the packaging provision PP91 and P003 (special provision 594).

Marking, labeling and placarding

The marking of overpacks and packages

The marking of overpacks and packages is subject to certain amendments. For example, it is now clarified that the letters of the marking “OVERPACK” must be at least 12 mm in height.

The danger labels

The danger labels to be affixed to packages are also subject to amendments: the “line forming the diamond” must be 2mm thick.

Materials transported at high temperature

As regards materials transported at high temperature, from now on all vehicles transporting materials at a temperature equal or higher than 100°C for liquids, and 240 °C for solids, must bear the appropriate marking. So far, this marking was made mandatory by the special provision 580 for substances classified under the UN Nos. 3256, 3257 and 3258.


Intermediate packaging

The use of an intermediate packaging, located between the inner packaging and the outer packaging (in addition to the packaging provided for in the instructions for the packaging of goods), shall from now on permitted subject to compliance with applicable regulations and the use of a cushioning material (new point New packaging provisions are provided for fire extinguishers in the packaging instruction P003 (special packaging provision PP91). In addition, amendments are made as regards the periodic checks of certain pressure equipment (instruction P200).  Thus, for seamless steel cylinders, bottles in aluminum alloy and the frames of these bottles, the time between periodic inspections may be extended to 15 years subject to certain specific requirements, especially with respect to their condition of use and their marking.

New packaging instructions

The new entries mainly concern the following new packaging instructions: – the P208 instruction, applying to adsorbed gases of Class 2; – the P805 instruction, applying to Un No. 3507

New packaging instructions for lithium batteries

The new P908 and P909 instructions, applying to damaged or defective lithium batteries, are thus created. To note, amendments are also made with regard to to the construction requirements of certain packaging, mainly pressure vessels referred to in Chapter 6.2 and packagings for radioactive materials concerned in Chapter 6.4. Red-on-line EHS Legal experts Sources:

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