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Final stages of distribution to retailers and/or end users

1) Road Derogation 4 and Rail Derogation 5 in the Carriage of dangerous goods: approved derogations and transitional provisions guidance published under Regulations 11(3) of the permit alternative carriage provisions for the retail distribution of small quantities of dangerous goods.

These allow the carriage of dangerous goods under the limited quantity (LQ) provisions or packaged according to Chapter 4.1 of ADR without their original outer packaging (eg drum, box, shrink- or stretch-wrapped tray) and without having to meet the marking requirements that would normally be required under ADR for single packagings.

2) These derogations only apply to carriage within GB for the final stages of the carriage operation by road or rail, between a distribution centre and a retailer or end user or between a retailer and end user.

3) They do not apply to dangerous goods of Classes 1, 4.2, 6.2 or 7.

4) The derogations are intended to facilitate, for example, the distribution of goods to DIY stores. When small numbers of a particular product are required, it may be necessary to break into LQ or UN approved combination packages to select a few items to prepare an order for delivery to individual stores.

The effect of these provisions is that the inner packaging does not have to be marked with UN certification marks or the hazard symbols and does not have to be re-boxed.

5) The total quantity of goods on the transport unit carried under these derogations must not exceed 30kg or litres per type, colour, strength or inner package size of a substance or article (e.g. colour or type of paint or size of tin) and must not exceed 333kg or litres per transport unit.

6) Inners from LQ packages carried 鈥榣oose鈥� under this derogation will continue to be treated as LQs under the other provisions of ADR Chapter 3.4.

7) However, 鈥榣oose鈥� inners from UN combination packs will still be subject to all the other provisions of ADR and will count towards the overall load calculations under ADR 1.1.3.6. Formal awareness training of drivers will be required, for example, as will the carrying of at least a 2kg fire extinguisher.

8) Some carriers may find it appropriate to provide the driver with a Retail Distribution Dangerous Goods Load Card that can be shown to enforcement officers. Formal transport documents would not otherwise be required for these types of load and many transfers are done using paperless systems.

The use of such a voluntary card could avoid misunderstandings at roadside checks and the driver having to describe the journey and the load and prove that the relevant conditions are met. The suggested text for the card is annexed to this document.

Use of 鈥榯ote鈥� boxes for carriage of LQ inners

9) Many distributors of retail goods find it convenient to use 鈥榯ote鈥� boxes to assemble inners to meet individual orders from stores, after split-packing from their original combination packaging. It is permitted to use such tote boxes for dangerous goods within GB provided that they meet the general requirements for packaging suitability set out in Chapter 4.1 of the UN and ADR texts (including being securely lidded).

They will enjoy the easements afforded for Limited Quantities in ADR Chapter 3.4, subject provided that the provisions, including the maximum permitted size of inners, the 30kg gross maximum mass and compatibility of the dangerous goods with different dangerous goods or non-dangerous goods packed together, are complied with.

It is also agreed that the 鈥�LQ鈥� diamond mark as per ADR Chapter 3.4 may be put on the lid of the box to make logistical control easier. (Note: ADR only allows the letters 鈥�LQ鈥� to be used if more than one UN number of dangerous goods are present as inners in the outer packaging: if all the goods are of the same UN number, then the actual UN number preceded by the letters 鈥�UN鈥� must be used.)

10) If UN approved inners are placed in a tote box, the box becomes an overpack and must be fully labelled and marked in accordance with ADR 5.1.2.

Packing Provision PP1 for paints, inks, adhesives and resin solutions

11) It should be noted that PP1 of Packing Instruction P001 may be utilised within the terms of PP1, including the requirement for the full marking and labelling of inner packages, driver training, fire extinguishers, etc. Such packs count towards the load calculations under ADR 1.1.3.6.

Display packs

12) It is possible for a 鈥榙isplay pack鈥� to be designed to meet all the marking and construction requirements set out in ADR Chapter 3.4 for Limited Quantities.

Alternatively, if a 鈥榙isplay pack鈥� contains shrink-wrapped trays or boxes correctly marked as LQs, then the display box is an 鈥榦verpack鈥� and will need to be marked in accordance with ADR 3.4.7. If the box contains UN marked packagings then again the box is an 鈥榦verpack鈥� and will again need to be correctly labelled and marked as such.

However, if the 鈥榙isplay pack鈥� does not meet any of these conditions then the display box will need to be tested as a UN packaging. For aerosols the test will not be required BUT no display box can exceed 50kg in fibreboard (Packing Instruction 204).

For other substances and articles then the limits of the relevant packing instruction will apply. Of course this will lead to other implications with ADR in respect of 3.4.7 and 5.1.2 for use of overpacks for LQs and non-LQs respectively.

IMDG Code (sea transport) issues

13) It should be noted that, notwithstanding the 鈥榩ackaged for retail sale鈥� easement of the IMDG Code 3.4.7 (鈥淟imited quantities of dangerous goods for personal or household use that are packaged and distributed in a form intended or suitable for sale through retail agencies are in addition exempt from marking of the UN Number on the packaging鈥�), it may not always be possible to take advantage of the tote box option for sea transport. This will depend upon the type of outer packaging used.

The requirements for packaging and marking for transport within UK waters are set out in [Marine Guidance Note MGN 342] (/government/publications/mgn-342-carriage-of-dangerous-goods-for-sale-on-uk-ferries) issued by the Maritime & Coastguard Agency.

14) Such limited quantity carriage by sea does also require dangerous goods documentation as per IMDG Code Chapter 5.4, additionally endorsed with the words 鈥楲imited Quantity鈥� or 鈥楲TD QTY鈥� and, if no other dangerous goods are involved, cargo transport units containing such goods need to be marked on the exterior as 鈥楲IMITED QUANTITIES鈥� or 鈥楲TD QTY鈥� not less than 65mm high in accordance with 5.3.2.4 of the IMDG Code.

15) For international transport by sea, including to the Channel Islands, the full provisions of the IMDG Code must be adhered to.

Annex

RETAIL DISTRIBUTION DANGEROUS GOODS LOAD CARD

Road Transport

Carrier name

Address

This transport unit is carrying some dangerous goods in accordance with the provisions of Derogation 4 in the 鈥淎pproved Derogations and Transitional Provisions鈥� document published under Regulations 11(3) of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (SI 2009 No. 1348).

Certain goods have been removed from their 鈥淟imited Quantity鈥� (LQ) packaging for distribution to retail sites or end users.

This document confirms that the permitted quantity thresholds are not exceeded. The 鈥渘on LQ鈥� load is within the thresholds specified in part 1.1.3.6 of ADR and by virtue of Derogation 2, dangerous goods documentation is not required to be carried.

For further information please contact:

Name:

Transport manager / Dangerous Goods safety advisor

Tel: