How can I determine if the regulations will apply to
the goods?
If the goods are hazardous then the regulations will apply, the real question
is whether all the regulations will apply. This can depend on several factors;
-
The mode of transport being used - Road, Sea, Rail, Air
-
For road, whether they are being transported in packages or in bulk or
in tanks
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The total volume of the load
-
The package size - limited or excepted quantites
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The Packing Group / Transport Category
-
Whether there are any exemptions in place regarding the goods / movement
In ADR there is a table in Chapter 1.1.3.6.3, if the goods are packaged and
total load does not exceed the limit appropriate to its Transport Category
then the
movement
is
exempt
from the provisions of ADR listed in Chapter 1.1.3.6.2. In effect you only
need a 2kg dry powder fire extinguisher, a transport document and you need
to take the safety precautions to prevent an incident as outlined in ADR. If
the goods are transported in Bulk or in Tanks the full regulations will apply
irrespective of the load size.
The table in Chapter 1.1.3.6.3 is the same one at which you would require
a DGSA. Click here if you want to see the table.
For sea freight if the goods are hazardous you will need to complete a Dangerous
Goods Consignmnet Note irrespective of the quantity involved. If the quantity
meets the requirements for Limited Quantities (see IMDG code
Chapter 3.4) the consigment note should
be endorsed with the words "Dangerous goods in Limited Quantities".
The determination for rail transport is in RID Chapter 1.1 and cannot
be easily summarised. I would advise that you consult RID and if you still
have any doubts contact us.
For airfreight there are no quantity thresholds and unless the goods meet
the quantity and packaging criteria for Excepted (IATA Section 2.7) or Limited
Quantities (column H in Section 4) the full regulations will apply.
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