Domestic Transport Dangerous Goods DGN v CMR

ASK THE EXPERTS SAFETY, LAW AND WORKING TIME DIRECTIVE FORUM (INTE
1

For UK (domestic) journeys involving Dangerous Goods from my place of work, other drivers rip up their DGN’s and rely on a CMR document as their valid Transport Document for the journey. (Both sets of paperwork are automatically generated by the computer system used on site). Is this compliant with CDG 2009 / ADR? I was under the impression CMR only applies for journeys between 2 countries, one of which is a contracting party to the CMR agreement. If this is the case, it would seem counter intuitive to rely on a CMR document as the Transport Document for a Domestic Journey. If what they are doing is acceptable, please could you quote the relevant regs for my benefit?

Thanks,

Beerexpressman

2

YOU MIGHT NEED…

I’M SURE HE WILL BE ALONG AS SOON AS HE CAN :smiley: :smiley: :smiley:
Or you can click the picture of the ADR Truck to send him a PM (Private Message) :bulb:

3

ROG:
Or you can click the picture of the ADR Truck to send him a PM (Private Message) :bulb:

Great idea, then no one else will get the benefit of the answer.

4

Mike-C:

ROG:
Or you can click the picture of the ADR Truck to send him a PM (Private Message) :bulb:

Great idea, then no one else will get the benefit of the answer.

I don’t know of any on-site questions that DD has not answered openly…

5

ROG:

Mike-C:

ROG:
Or you can click the picture of the ADR Truck to send him a PM (Private Message) :bulb:

Great idea, then no one else will get the benefit of the answer.

I don’t know of any on-site questions that DD has not answered openly…

Me neither, but i wouldn’t know the answers to anything he’s answered by PM which is my point. Actually i’m suprised you havn’t rang him up to tell him to answer it. Give him a bell, you know you want to.

6

beerexpressman:
For UK (domestic) journeys involving Dangerous Goods from my place of work, other drivers rip up their DGN’s and rely on a CMR document as their valid Transport Document for the journey. (Both sets of paperwork are automatically generated by the computer system used on site). Is this compliant with CDG 2009 / ADR? I was under the impression CMR only applies for journeys between 2 countries, one of which is a contracting party to the CMR agreement. If this is the case, it would seem counter intuitive to rely on a CMR document as the Transport Document for a Domestic Journey. If what they are doing is acceptable, please could you quote the relevant regs for my benefit?

Thanks,

Beerexpressman

I would follow the instructions on this website as they seem to know what is going on.

sitpro.org.uk/trade/dangerous.html

When dangerous goods are transported, the consignment must be accompanied by a transport document that contains information declaring the type and nature of the goods. The SITPRO DGN enables the shipper to complete one standard document for all consignments irrespective of port or inland depot. By doing so, it provides the receiving authority with complete, accurate and timely information as well as providing all those with an interest in the consignment with adequate information at each stage of the transport movement. The greatest benefit of using the DGN is that receiving authorities have clear and precise information on the way the goods should be handled.

sitpro.org.uk/trade/standard.html

Throwing any documents away or destroying them is going to cost you eventually. No problem using a CMR on domestic traffic but why not keep both documents?

A shipper is legally obliged to make a declaration of the danger or hazard of the goods being transported. For the movement of dangerous goods by sea, inland waterways, road and rail, the shipper can fulfil this requirement by completing a SITPRO Dangerous Goods Note (DGN); for air, the correct documentation is the International Air Transport Association Shipper’s Declaration of Dangerous Goods. However, the shipper can design, prepare and present a bespoke or ‘in-house’ document for the surface modes (roads or rail) provided it contains the mandatory information. Some chemical and automotive companies have done this to accommodate specific business processes, such as the need for landscape (instead of a portrait) documentation.

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beerexpressman:
For UK (domestic) journeys involving Dangerous Goods from my place of work, other drivers rip up their DGN’s and rely on a CMR document as their valid Transport Document for the journey. (Both sets of paperwork are automatically generated by the computer system used on site). Is this compliant with CDG 2009 / ADR? I was under the impression CMR only applies for journeys between 2 countries, one of which is a contracting party to the CMR agreement. If this is the case, it would seem counter intuitive to rely on a CMR document as the Transport Document for a Domestic Journey. If what they are doing is acceptable, please could you quote the relevant regs for my benefit?

Thanks,

Beerexpressman

Hi Beerexpressman,

CDG and ADR are as one on the subject of a Transport Document once a load is subject to ADR.
Any document will suffice as long as the required information is written on the document and set out in the correct format and layout. The document may also be an electronic version.

The relevant Regs are CDG 2009 Reg.5 and ADR 2009 5.4.1.1.1

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dieseldave:
Hi Beerexpressman,

CDG and ADR are as one on the subject of a Transport Document once a load is subject to ADR.
Any document will suffice as long as the required information is written on the document and set out in the correct format and layout. The document may also be an electronic version.

The relevant Regs are CDG 2009 Reg.5 and ADR 2009 5.4.1.1.1

So DD provided all the relevant information is on the CMR, written out in the correct order, then a DGN isn’t strictly necessary ?
Although I don’t do ADR work any more, my personal opinion is - if your given a DGN just leave it with the other paperwork for that consignment. It’s got all the relevant information to help the emergency services if they should need it, without having to go through their channels to get the info. Also, it’s only a sheet of paper, how difficult is it to leave it in the bundle?

On a different tack all together, I put those Reg’s numbers into Google for a quick look.
In both cases the first two offerings were links directly to the relevant regs, and the third offering was a link to this thread :open_mouth: . I’ve probably ruined it now, by posting after Dave :cry:

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Simon:

dieseldave:
Hi Beerexpressman,

CDG and ADR are as one on the subject of a Transport Document once a load is subject to ADR.
Any document will suffice as long as the required information is written on the document and set out in the correct format and layout. The document may also be an electronic version.

The relevant Regs are CDG 2009 Reg.5 and ADR 2009 5.4.1.1.1

So DD provided all the relevant information is on the CMR, written out in the correct order, then a DGN isn’t strictly necessary ?

That’s correct for a road journey Simon. :smiley:
If a road vehicle is conveyed on a train or ferry for part of a journey, then a multi-modal document becomes necessary.

Dave’s strange but true…
The Channel Tunnel DOESN’T count as multimodal, because it uses ADR as the basis for its own set of Regs. :wink:

Simon:
Although I don’t do ADR work any more, my personal opinion is - if your given a DGN just leave it with the other paperwork for that consignment. It’s got all the relevant information to help the emergency services if they should need it, without having to go through their channels to get the info. Also, it’s only a sheet of paper, how difficult is it to leave it in the bundle?

Agreed!!

Simon:
On a different tack all together, I put those Reg’s numbers into Google for a quick look.
In both cases the first two offerings were links directly to the relevant regs, and the third offering was a link to this thread :open_mouth: . I’ve probably ruined it now, by posting after Dave :cry:

You’ve not ruined anything Simon. :smiley:
The whole of ADR is publicly available, BUT… I would urge great caution on anybody who thinks they can just ‘Google’ the answers to their questions…
(The other Regs {IATA, IMDG and RID} can only be bought as hard-copy and aren’t available online, so the minute that we speak of Multi-Modal transport, the ‘Googlers’ come unstuck. :wink: )

The dangerous goods list in Part 3 of ADR (3.2.1 and 3.2.2) has many Special Provisions (SPs) which are capable of altering the rules, or adding extra requirements and is looked at PER INDIVIDUAL SUBSTANCE. To add extra ingredients to the mix, there are also transitional measures, derogations, exemptions, multilateral agreements and other fiendishly difficult stuff to contend with. Then of course, there’s the UK Regs (CDG 2009) that completely modify certain bits of ADR for UK domestic traffic.

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Thanks to all who replied, especially Diesel Dave. Cheers.

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beerexpressman:
Thanks to all who replied, especially Diesel Dave. Cheers.

Hi beerexpressman, Thanks for that!! :smiley:

Dangerous goods, especially ADR is what I do, so it’s no problem for me to give you good answers, although to be fair to Wheel Nut, his answer was also correct and SITPRO is a good and highly reputable source of info. :wink:

I’m glad I was able to help. :smiley:

12

I have just been looking in detail at one of our CMR documents for a UK delivery of dangerous goods in packages, and they don’t appear to have the number of packages printed on them (although a description of the packages is there) as required by ADR 5.4.1.1.1 (e), which you referred me to.
I reckon these CMR documents are therefore not suitable as a valid transport document and we should use the DGN’s. Any thoughts?

Thanks again,

beerexpressman

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beerexpressman:
I have just been looking in detail at one of our CMR documents for a UK delivery of dangerous goods in packages, and they don’t appear to have the number of packages printed on them (although a description of the packages is there) as required by ADR 5.4.1.1.1 (e), which you referred me to.
I reckon these CMR documents are therefore not suitable as a valid transport document and we should use the DGN’s. Any thoughts?

Thanks again,

beerexpressman

Hi beerexpressman, You are correct. :smiley:

The number of packages can be added to the document at any time, even if it’s written in by handwriting.

Do you own the vehicle you drive, or are you an employed driver??

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Just an employee.

Thanks once again!

Beerexpressman

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beerexpressman:
Just an employee.

Thanks once again!

Beerexpressman

Hi beerexpressman, If you’re an employee, then you can rest easy mate.
As an ADR trained driver, you know that you need documentation and it seems that you’ve got that covered.
If the ADR documentation is discrepant in some of its detail, then it’s really not your problem mate.

Here’s how ADR deals with this situation:

1.4.2.1 Consignor
1.4.2.1.1 The consignor of dangerous goods is required to hand over for carriage only consignments
which conform to the requirements of ADR. In the context of 1.4.1, he shall in particular:

(a) Ascertain that the dangerous goods are classified and authorized for carriage in
accordance with ADR;

(b) Furnish the carrier with information and data and, if necessary, the required transport
documents and accompanying documents (authorizations, approvals, notifications,
certificates, etc.), taking into account in particular the requirements of Chapter 5.4 and
of the tables in Part 3;

So, if a load is subject to ADR, then the consignor has to provide the transport document, because it’s necessary.
Next up is the carrier’s responsibility:

1.4.2.2 Carrier
1.4.2.2.1 In the context of 1.4.1, where appropriate, the carrier shall in particular:
(a) Ascertain that the dangerous goods to be carried are authorized for carriage in
accordance with ADR;
(b) Ascertain that the prescribed documentation is on board the transport unit;

From the above, you can see that the carrier doesn’t have to provide the transport document, but he cannot escape the responsibility to ensure that a transport document is on board the transport unit.

Both the consignor and the carrier are required to appoint a DGSA under ADR 1.8.3.1, so my advice is to let the consignor and your boss sort it out between them, cos it’s your company DGSA’s responsiblity to go into such detail and to advise your boss. (ADR 1.8.3.3.)

Please don’t have nightmares mate, cos this really isn’t your problem. :smiley: