The ADR Agreement: transport of empty UNCLEANED packagings

ADR: Do we have to comply with all the provisions of the ADR Agreement on the carriage of dangerous goods? You often have to transport packagings, large packagings or IBCs (intermediate bulk containers) that are empty but uncleaned.

These packagings must normally be identified by the UN number, danger labels and marks of the substance they last contained.

Drivers and carriers may therefore interpret and understand that the transport of these packagings involves complying with the requirements of the ADR Agreement on the carriage of dangerous goods.

Is it really an ADR transport?

Do we need a transport unit fitted with ADR equipment, a driver holding an ADR vocational training certificate, etc…?

In this very short article we present the conditions for transporting packagings that are empty but UNCLEANED!

Requirements concerning the transport of empty, uncleaned packagings.

Packagings, large packagings and intermediate bulk containers (IBCs) that are empty BUT uncleaned fall, for the purposes of transport under chap. 1.1.3.6, into transport category 4.

These empty, uncleaned packagings can be carried partially exempted from the provisions of ADR, provided that the last substance, that is, the residues of the substance, is not assigned to transport category 0 (extremely dangerous substances).

When empty, uncleaned packagings are carried, except for those with residues of dangerous substances of transport category 0, the following requirements of the ADR Agreement do NOT apply:

• The requirements concerning high consequence dangerous goods (chap. 1.10)
• The marking of the transport unit
• The requirements concerning instructions in writing, nor their presence on board the transport unit
• Special provisions concerning packages
• Obligations concerning the vocational training of drivers
• General and personal protective equipment
• Requirements concerning the bodywork and approval of vehicles

In view of the above, the following requirements are mandatory.

• Mandatory entry in the transport document:

RO: IBC-uri GOALE CU REZIDUURI……………. (in English: EMPTY IBCs WITH RESIDUES OF…)

EN: EMPTY IBC WITH RESIDUES OF……………

The class(es) and subsidiary hazard(s) corresponding to the various residues in the IBCs are to be entered on the dotted line, in the order of the class numbers.

Example:

RO: IBC-uri GOALE CU REZIDUURI 3, 8, Categoria de transport 4, 0 puncte

EN: EMPTY IBC WITH RESIDUES OF 3, 8, Transport Categorie 4, 0 puncte

• Language of the entries

For national transport, in the language of the country.

If the official language of the country of dispatch is not English, German or French, then for international transport the declaration of the goods (the entry concerning the empty packagings) must be made in a language of international circulation (EN/DE/FR).

Requirements concerning transport

• When empty, uncleaned packagings are carried, the transport unit does NOT have to be marked with orange-coloured plates. (provided that the completed CMR consignment note refers to the transport category and the points value)

• For exempted transports, the driver must hold the ADR 1.3 training attestation or certificate, because the driver must know the provisions concerning the exemption.

• It must be checked whether the packagings are approved for ADR transport, and labelled and marked with the appropriate UN number and other special marks.

Requirements concerning empty, uncleaned packagings:

• They must be approved for ADR transport
• They must be labelled with danger labels
• Marking with the UN number preceded by the letters “UN”.
• The packagings must be closed, clean on the outside and intact.
• If the residues of the substance are hazardous to the environment, the “environmentally hazardous” mark must be applied to/kept on the empty, uncleaned packagings.

• blue - approval mark
• yellow - marking with the UN number
• green - labelling

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