Updated: Aug 12, 2020
As you may know, the main set of regulations for shipping Dangerous Goods by Road is the ADR manual. If you are new to ADR, we have another post to introduce ADR here that you may want to read first. ADR has a whole range of Exemptions relating to certain activities, quantities carried and types of shipping Dangerous Goods by Road that can help companies to move Dangerous Goods by Road with less restrictions. One of the most-used is probably the ADR Small Load Exemption which is listed in section (and sometimes referred to as), 184.108.40.206.
This exemption relaxes some of the rules, mainly for the haulier, if the amounts carried on-board a vehicle are below the stated limits. In this post, I will dive into the exemption, look at how it works and some of the ways it can help a haulier. If you're looking for our Dangerous Goods by Road (ADR) Training, that can all be found here.
How do we know if the ADR Small Load Exemption 220.127.116.11 applies?
As you probably know from our previous posts or your experience, Part 3 of ADR is our Classification, or the List of Dangerous Goods Section. In Part 3, ADR lists every type of Dangerous Goods by their assigned UN Number and there are columns which give us specific information for those UN Numbers. In column 15, ADR lists both a 'Transport Category', as well as a 'Tunnel Restriction Code' (we will cover Tunnel Codes in a future post). In the below example, we will look at Acetone - UN1090, to demonstrate and in column 15, we are given Transport Category 2, and Tunnel Restriction Code (D/E) (which we will cover in another post).
Using this method, ADR assigns every UN Number, a Transport Category of either 0, 1, 2, 3 or 4. This is our first step done!
General Requirements for Hauliers
To understand how the ADR Small Load Exemption 18.104.22.168 helps, we must first understand the requirements that hauliers must normally follow under ADR, we will call them the 'Full' ADR Requirements, and in very simple terms, a haulier must do the following*:
Apply Hazardous Placards to their vehicle (ADR 5.3)
Apply an Orange Plate Marking to their vehicle (ADR 5.3)
Carry a set of Instructions in Writing (ADR 5.4.3)
Observe special rules for the carriage of packages (ADR 7.2)
Carry documents onboard the vehicle including ID (22.214.171.124 d) and Dangerous Goods Note (ADR 126.96.36.199 a)
Carry a full set of fire extinguishers (ADR 8.1.4)
Hold an ADR Driver's License (ADR 8.2.2)
Staff to have Dangerous Goods Training (ADR 8.2.3)
Cannot Carry Passengers (ADR 8.3.1)
*not an exhaustive list
Let's now look at how ADR Small Load Exemption 188.8.131.52 affects this list of requirements.
What does using the ADR Small Load Exemption 184.108.40.206 tell us and what does it change?
In ADR 220.127.116.11, we are given a table (18.104.22.168.3) and that table lists all our transport categories (0 to 4) and states what quantity (kg for solids and L for liquids respectively) we must keep below on-board the vehicle, to be able to use our Small Load Exemption 22.214.171.124. The quantities are as follows:
In our example we had Acetone, UN1090 which was Transport Category 2. Therefore, if we are shipping Acetone and we have 333 litres on board (or less) we can use the ADR Small Load Exemption 126.96.36.199.
That means we can ship these goods, without needing to follow all of the 'Full' ADR Requirements and this list of things we need to do becomes much shorter:
Observe special rules for the carriage of packages (ADR 7.2)
Carry Dangerous Goods Note on-board (ADR 188.8.131.52 a) - UK Derogations can exempt this.
Carry a full set of fire extinguishers (ADR 8.1.4)*
Staff to have Dangerous Goods Awareness Training (ADR 8.2.3)
*When using the Small Load Exemption 184.108.40.206, we only require minimal fire extinguishers, as detailed in ADR 220.127.116.11
This makes a huge difference. Simply not needing an ADR Qualified Driver, or Hazardous Placards and Orange Plate Markings saves a lot of costs for hauliers!
If, in this example, we were carrying over 333 litres, we would have two options. Either split the load over two vehicles, or follow all of the 'Full' ADR Requirements (including ADR Qualified Driver, Hazardous Placards and Orange Plate Markings)
That's it. . . or is it?
If all of your questions are not answered, here's a little bit extra for you!
So what happens if on one vehicle, I was to carry 300 litres of a Transport Category 2 substance and also 67kg of a Transport Category 3 Substance?
You cannot just add the allowances together!
In the Transport Category Table above, we saw you could carry 333kg of a Transport Category 2 substance or 1000kg of a Transport Category 3 substance. Not both.
Transport Category 0 is irrelevant really, as even if you have 1 gram of a Transport Category 0 substance, you must follow all of the 'Full' ADR Requirements.
Transport Category 4 is also irrelevant, as you can carry an unlimited amount and never need to follow the 'Full' ADR Requirements.
But if we are carrying a combination of Transport Category 1, 2 and/or 3 substances, we need to calculate the 'percentage' of our allowance that we are using for each Transport Category and add them together. ADR, in section 18.104.22.168.4, explains how to do this and refers to it as the 'Calculated Value'. It's actually very simple, and the process is this:
Transport Category 0 - Irrelevant (see above)
Transport Category 1 - multiply the amount on-board by 50
Transport Category 2 - mutliply the amount on-board by 3
Transport Category 3 - multiply the amount on-board by 1
Transport Category 4 - Irrelevant (see above)
Then we take our calculated values, add them together, and if our load is 1000 or below, we can use the exemption. If we are over, then we must follow the 'Full' ADR Requirements.
In the example above, I was going to carry 300 litres of a Transport Category 3 substance and also 67kg of a Transport Category 3 Substance. Let's work out our Calculated Value:
So our Calculated Value for this example was 967 which is equal to, or less than 1000, so we can use the Small Load Exemption. If our Calculated Value was over 1000, we would again just need to split the load over more than one vehicle, or follow the 'Full' ADR Requirements.
So that is it, an introduction to the ADR Small Load Exemption 22.214.171.124, there are some exceptions and detailed nuances to this exemption, so always check with your Dangerous Goods Safety Adviser (DGSA) if you're unsure. If you have any questions, you can always comment below, 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 Dangerous Goods, it is not intended as a reference material 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.*