Transporting Asbestos under ADR
Updated: Jan 23
Is Asbestos ADR Dangerous Goods?
Everyone knows the dangers of Asbestos when working with it, however how it is transported rarely comes to mind for most people. In this article, we will summarise the requirements of transporting Asbestos.
As you probably know, Asbestos is considered “Dangerous Goods” when transported due to the fact that it can release Asbestos fibres from the vehicle whilst travelling down the road. This is a danger to the public and vehicle crew and as a result, it is classified as “Dangerous Goods” like many other products which can pose a danger during transport (e.g. Flammable Liquids, Explosives, Batteries etc.).
Note: In this article, we will consider Asbestos or Asbestos Containing Materials (ACMs) together and refer to them all as Asbestos.
Dangerous Goods Legal Framework
In the UK, the rules for transporting Dangerous Goods are laid out in an international agreement called “The ADR Agreement” – this is brought into force in the UK by UK Law, namely The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009, as amended (often shortened to CDG2009).
This is UK Law, overseen by the Department for Transport and enforced on the roads by The Police and DVSA who both have enforcing powers ranging from Vehicle Prohibition to Criminal Prosecution. Importantly, even for those who do not transport the goods and only prepare, pack or load the goods, there are still requirements that must be met and the Health and Safety Executive can (and does) take action against those who do not do this properly!
As a result, in order to avoid fines, prosecutions, impact to Operator Compliance Risk Score (OCRS) and impacts to Operator Licenses, it is critically important that Haulage Companies, Transport Brokers and even those packing and consigning the materials are aware of the regulations that they must comply with and have trained team members to be able to follow these rules.
Is Asbestos ADR?
Yes. Asbestos is listed in ADR and has been for some time (back to the 1990s)! The ADR Regulations update every two years and Asbestos is one of those products where changes and additional requirements have been added over time.
That said, there is a big difference when transporting a small pot of soil which potentially contains asbestos, when compared to a skip full of the same material.
As well as that, whether the Asbestos is fibrous, or bound can make a big difference to the risks as well – ADR does capture a lot of these nuances and below, we will split out the requirements for each scenario.
What if I am unsure whether my material contains Asbestos?
You should treat any material where there is a reasonable likelihood that it contains Asbestos, as Asbestos or Asbestos Containing Materials (ACMs), unless you can be certain they do not. This includes sending samples for testing – the fact that a test is being undertaken is evidence that there is a likelihood of a positive result.
The Requirements for Transporting Asbestos
Classify your Asbestos
In the Dangerous Goods world, and in ADR, Asbestos is split into two types. Each type has a UN Number and Proper Shipping Name (shown below) which are the method we use internationally to identify different types of Dangerous Goods:
UN2212 – Asbestos, Amphibole – this classification includes Asbestos types like Amosite, Tremolite, Actinolite, Anthophyllite, Crocidolite and Talc containing Tremolite and/or Actinolite.
UN2590 – Asbestos, Chrysotile – this classification is reserved for the less-hazardous Chrysotile (soft-fibred Asbestos).
The first requirement, is to Identify which type you are looking to transport from the above two.
Bound Asbestos
There is one exemption which is relevant at this stage, which is related to situations where you are transporting Asbestos however, there is no likelihood of fibres being released in any hazardous quantity. This exemption is called “ADR Special Provision 168” and the wording is below:
Asbestos which is immersed or fixed in a natural or artificial binder (such as cement, plastics, asphalt, resins or mineral ore) in such a way that no escape of hazardous quantities of respirable asbestos fibres can occur during carriage is not subject to the requirements of ADR.
Manufactured articles containing asbestos and not meeting this provision are nevertheless not subject to the requirements of ADR when packed so that no escape of hazardous quantities of respirable asbestos fibres can occur during carriage.
As a result, cement boards, Bakelite asbestos and similar material can be exempted provided that it is undamaged and in good condition so that there is no likelihood of fibres being released in any hazardous quantity.
In this case, the product is entirely exempted from ADR Requirements and no specialist packaging, marking, labelling or ADR driver/vehicles are required. So, you can stop reading this article – and get it moving!
It would be a good idea to keep a record of who made this determination and your evidence of this on record in case it was ever questioned.
Important note! The catch is that to use this exemption, the fact that the material has no likelihood of fibres being released in any hazardous quantity needs to be the case for the material without packaging or vehicle arrangements – it will not apply if the product is packaged or contained in such a way that there is no likelihood of fibres being released in any hazardous quantity – it has to be the case for the material itself, without packaging.
If this is not the case (for example you’re transporting fibrous Asbestos or Asbestos which is not bound, continue below to find out the requirements for transporting Asbestos under ADR.
Asbestos in Soils
The text in the ADR regulations, lists asbestos in soils as an example of ADR Dangerous Goods however, there is a caveat to this. Asbestos in soils under the Definition of Waste is considered "Hazardous" if it is visible or if the concentration is 0.1% or greater, so what if concentration of fibres in soils is less than 0.1%?
The exemption states that to use this exemption, the material has to have no likelihood of fibres being released in any hazardous quantity without packaging and is therefore effectively bound. The regulation allow for consideration of the materials in the raw form and this can be extended to soils.
So, if you can see it or it has likelihood of fibre release, then ADR should be observed, however the concentrations, type of asbestos, its form, the soils type and moisture content can be considered by a competent person to assess the risk of fibre release. It could therefore be likely that a moist non-granular cohesive soils would be regarded as an effective binder and removing the load from the ADR regulations under ADR Special Provision 168. If you are planning to use this retionale to ensure that your load falls outside of ADR, you should keep a record of this determination, evidence of material and evidence of competency of the person making this determination.
Quantify your material
Next, it is important to consider how much you’re looking to transport per package.
This is important because if you have 1000kg to transport but you are able to package these into 20 x 50kg bags and transport all 20 bags on one vehicle, you can still use the Packaged System below as the limits are per package, not per vehicle - the thresholds for different amounts are:
1kg or less per package – Limited Quantity System
400kg or less per package – Packaged System
Over 400kg per package – Bulk System
Once you have determined this, you can go to the related section below and find the requirements.
Transporting Asbestos in Limited Quantities
Small quantities of Asbestos (less than 1kg per package) can be transported under the ADR Limited Quantity system – the requirements for this are:
Double Packing – The Asbestos must be double packed – the material must be contained in an inner packaging (i.e. in a pot/bag not exceeding 1kg in material weight).
This/these inner packaging(s) must then be packed into an outer packaging (i.e. in a box) and you can put as many as you can fit in there as long as this outer package does not exceed 30kg Gross Weight.
The inner and outer packaging needs to be good quality and suitable for the amount of material you’re putting into it – it should be able to withstand all of the normal shocks and conditions of transport.
Once packed, each outer package must show the Limited Quantity marking (as shown below) and these must be 100mm x 100mm in size, unless they physically cannot fit on the package, in which case they can be reduced to no less than 50mm x 50mm.
Once packaged in this way, the product does not require an ADR transport document for UK Road movements and you can transport up to 8 tonnes of these packages per vehicle without the need for any vehicle markings.
Important – those that package these materials do require documented training to do so – see our certified E-Learning Module “Preparing Consignments of Limited Quantities” if you don’t have training in place already.
An example of when this could be useful is a company who are looking to have soils tested for Asbestos contamination. If there is a reason to suspect that the soils could contain Asbestos, we would need to treat them as Dangerous Goods.
The test facility could provide plastic pots and require 5 x 500g samples – these can be transported as limited quantities and in this case, the site staff will take the samples and seal in the pots – they will then be stacked into an outer cardboard box, or plastic coolbox and on the outside, the Limited Quantity mark should be applied.
The site staff would need some training to do this however no ADR driver is needed (less than 8 tonnes of Dangerous Goods material on the vehicle in total) and a Dangerous Goods Safety Adviser (DGSA) would not be required (see below).
Transporting Asbestos in packaged form (over 1kg per container/package)
If it is not practical to transport Asbestos in 1kg or less per container, we can transport this material as ADR Packages.
In this case, we can use a range of packagings, for example:
Intermediate Bulk Containers (IBCs)
Drums
Bags
Boxes
Jerricans
Each type of packagings have differing limits ranging from 50kg to 400kg per package – speak to your Dangerous Goods Safety Adviser (DGSA) for details.
IMPORTANT – The packaging used MUST be approved for Dangerous Goods – we call this “UN Specification” and you will know if your packaging is approved by the markings which are printed on the packagings which look like the below – Speak to your DGSA for more details:

Once packaged, each packaging will need marking with the UN Number of the Asbestos you’re transporting, as well as a Class 9 Hazard Marking/Label.

Finally, you will need a Transport Document which lists all of the ADR Dangerous Goods details. This document may be part of another document (such as the Consignment Note, if a waste), example shown below:

The requirements for this entry above (including the part in brackets) are specific and detailed, refer to your training and DGSA for more information.
These packages can then be loaded into any vehicle/container which is sheeted or closed. However, when bagged Asbestos is transported, the vehicle must be capable of being closed (i.e. not sheeted skips etc.) but the vehicle must have sides/roof which completely close.
Do I need an ADR driver to transport Asbestos in packages?
Normally, yes. An ADR driver is a vehicle driver who has undertaken the UK Government approved training and passed the relevant exams to carry Dangerous Goods. These drivers will carry a card as evidence of this, example shown below:

This license should be in-date and on the reverse of the card, it lists what “Hazard Classes” the driver is qualified to carry and in “Other than tanks” column, a “9” should be listed for Asbestos.
That said, there is one exemption to this…
ADR Small Load Exemption for Asbestos
There is an exemption if you are carrying packages of Asbestos but there is 333kg or less on each vehicle. In this case, any driver can carry these consignments by road, provided that they have Dangerous Goods Awareness Training (we have an e-learning module for this if you’re stuck) and the driver must also carry an in-date 2kg Dry Powder fire extinguisher (for wheel/engine fires), as a minimum.
Carrying Asbestos in Bulk or Skips by ADR (Special Provision 678)
Finally, if you’re looking to carry Asbestos in bulk quantities, this is also possible under ADR as well through an exemption called ADR Special Provision 678.
The conditions are that the Asbestos cannot reasonably be packaged, and the materials which can be moved in this way are:
Solid waste from roadworks, including asphalt milling waste contaminated with free asbestos and its sweeping residues
Soil contaminated with free asbestos
Objects (for example, furniture) contaminated with free asbestos from damaged structures or buildings
Materials from damaged structures or buildings contaminated with free asbestos which, because of their volume or mass, cannot be packed in accordance with the packing instruction
The Special Provision 678 restrictions are:
The waste is carried only from the site where it is generated to a final disposal facility. Between these two types of sites, only intermediate storage operations, without unloading or transferring the container-bag, are authorized
Waste covered by these provisions shall not be mixed or loaded with other asbestos containing waste or any other hazardous or non-hazardous waste
Wastes need to be loaded into a rigid container (i.e. skip or shipping container) and this must be fitted with a container-bag liner which is suitable for the material (speak to your DGSA for more details).
Each load shall be considered a full load and this means that the load originates from one consignor - for which the use of a vehicle is exclusively reserved and all operations for the loading and unloading are carried out upon instructions of the consignor or of the consignee. (often called a dedicated vehicle).
If the material being transported are objects which are not Asbestos, but are contaminated with free asbestos from damaged buildings or structures or demolition – the total quantity of material/objects on one vehicle is 7 tonnes.
When this Special Provision is being used, this must be noted on the ADR Transport Document with the statement “Carriage under Special Provision 678”. If a Consignment Note is used, this can be added to the Special Handling Requirements section.

A copy of the container-bag datasheet must be included with the documents given to the driver and if the consignor/consignee/carrier are in agreement for the bag to be tipped when unloaded, a copy of this agreed procedure must be handed to the driver with these other documents.
When do I need to appoint a Dangerous Goods Safety Adviser (DGSA)?
If you are the Haulier/Carrier or the Consignor (the person preparing materials, packing or handing over to a haulier) of Asbestos you must legally appoint a Dangerous Goods Safety Adviser (DGSA).
The exception to this is:
You only ever send/carry Limited Quantities (less than 1kg per container).
Other than that, you are legally required to formally appoint a Dangerous Goods Safety Adviser.
A Dangerous Goods Safety Adviser is someone who has passed UK SQA Department for Transport exams and holds a valid Dangerous Goods Safety Adviser (DGSA) certificate. This DGSA is responsible for three things:
Monitoring the compliance of The Organisation with respect to these ADR requirements.
Advising The Organisation with respect to these ADR requirements.
Preparing and submitting the DGSA Annual Report for The Organisation (a legal report which must be retained for five years).
If you don’t have a DGSA and think you might need to appoint one, speak to us and we can talk it through with you (send us a message on here, call us on +441273 569048 or email asbestos@dangerous-goods.co.uk) and you can join our 250+ clients who currently benefit from our 24/7 National Support.
What training is needed to transport Asbestos and Dangerous Goods?
There are three types of training which are legally required to transport Asbestos:
Dangerous Goods Awareness – this is for anyone involved in the booking of haulage, and generally involved in transport. This needs to be renewed every 2-5 years.
Dangerous Goods Consignor Training – this is for anyone who packs/loads or raises Consignment Notes for Dangerous Goods. This needs to be renewed every 2-5 years.
ADR Driver Training – this is for any driver who is carrying Asbestos (or other Dangerous Goods). This needs to be renewed every 5 years.
If you’re missing any of this training, speak to us and we can talk it through with you (send us a message on here, call us on +441273 569048 or email asbestos@dangerous-goods.co.uk) our courses are cost-effective and many can be done online, same-day and are all certified and compliant with ADR.
What if I need more information?
Dangerous Goods Training can be a complicated subject and we hope that this has helped to explain what ADR requirements apply to Asbestos. If you have any questions, you can always comment below, speak to your DGSA, contact us or use the live-chat in the bottom right-hand corner of your screen. Thanks for reading!
Notice: This blog aims to give you an introduction to Asbestos in ADR and it is not intended as a reference material or formal advice so always conduct your own research and check anything with your Dangerous Goods Specialist or DGSA before taking any action based on the subjects discussed here.
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