There is no doubt that the introduction of the Limited Quantity exemptions has had a significantly positive effect on the cost of shipping relatively small amounts of dangerous goods.
The Regulations governing the transport of Dangerous Goods by Road in EU member states, and some other countries around the world, is covered by the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). ADR is enacted for the UK, with a few modifications, as the Carriage of Dangerous Goods and Use of Transportable Pressure Receptacles Regulations (CDG).
As there are prescribed requirements for transporting dangerous goods there is normally a consequential cost when compared to products that fall outside of these regulations.
Therefore, it is logical that many consignors seek, wherever possible, to have their goods transported under the Limited Quantity (LQ) exemptions. However, it is not necessarily straightforward to determine whether or not a shipment can be consigned legitimately without being subject to the regulations.
What is allowable as Limited Quantity?
To stay within the LQ thresholds for land and sea, the products must be filled in small containers, no larger than specified in the respective regulations, and packed in boxes with a maximum weight of 30kg or shrink-wrapped trays up to 20kg.
In the Dangerous Goods List (DGL) of ADR and RID for rail, products are allocated a Transport Category of 0, 1, 2, 3 or 4. The category will determine the maximum total quantity allowable per transport unit. There are also restrictions on the total gross mass of the packages allowed on a vehicle. Forwarders should be careful to ensure that, when uplifting LQ consignments from more than one site, the combined amount of dangerous goods does not tip the scales into a classified load.
If a consignment is likely to have a journey using more than one mode of transport, it may be subject to different constraints.
- IMDG has segregation rules that may need to be observed and it has more documentation requirements than ADR.
- Shrink wrapped trays are not allowed as LQ under the ICAO Technical Instructions/IATA Dangerous Goods Regulations, which list the applicable LQ packing instructions for each product.
Classifying a Consignment
Labeline supplies a range of solutions to help get the benefits of utilising the LQ exemptions without the risk of exceeding the thresholds…
If you are already shipping dangerous goods you should have purchased the current regulations for the modes that you use. You can refer to the DGL, in part 3 of ADR, RID, IMDG and ICAO TI or section 4 of IATA DGR to check that you are below the limits. This can be a time consuming calculation if a lot of different products are involved.
The Guide to Exemptions from the International Carriage of Dangerous Goods by Road
Written and compiled by Roger Wrapson, formerly RHA’s Senior Manager and DG Specialist, the “Exemptions Guide” lists the products that can be transported by road as LQ (and Excepted Quantity). The 3rd edition of this Labeline publication includes an easy-to-read table that shows the maximum size and amount allowable as LQ in a receptacle, the gross package weight and the maximum load. It also lists the transport category and any special provisions.
DGOffice is an online software solution that simplifies the classification process and makes the calculations thereby enabling users to quickly produce dangerous goods documentation that always complies with current regulations. As the system is updated stealthily, and in a timely manner, there is no need to download updates when the regulations change - it is all done automatically. DGOffice will highlight if a consignment is over the limit for any mode. Labeline offers a free 14-day trial of DGOffice.
Employ a Dangerous Goods Safety Advisor (DGSA)
The appointment of a suitably qualified DGSA is only necessary to comply with ADR and RID and not required if a business is involved in consigning under LQ only. However, a DGSA will have the expertise and resources to determine whether or not a consignment is exempt.
Training is Required
Shipping dangerous goods by any mode comes with an obligation to train staff, including those who handle LQ. For example, ADR 18.104.22.168 states:
“Personnel shall be trained, commensurate directly with their duties and responsibilities in the requirements of the regulations concerned with the carriage of dangerous goods.
Where the carriage of dangerous goods involves a multimodal transport operation, the personnel should be aware of the requirements concerning other transport modes.”
A Safe Transport of Dangerous Goods under Limited Quantity Exemptions course can be held at your premises. The content of the Labeline course would cover the necessary transport modes and can be tailored to focus on the specific products that your business is concerned with.
The Dangerous Goods Awareness course is for personnel who need to be familiar with the dangerous goods transport regulations and have an awareness of the duties that arise from them. It covers the general awareness training requirements in ADR, IMDG Code and RID Regulations and also gives an overview of the air transport provisions. Candidates will have a period of 90 days to study and complete the course online.
Seminars and Events
In advance of the regulations being updated for 2019, the Biennial Dangerous Goods Roadshow will be held at Heathrow and Manchester Airport in November 2018. This seminar provides delegates with a regulatory update of the forthcoming changes across all transport modes. It is an excellent networking opportunity too, with an exhibition of specialist suppliers, experts on hand to answer questions and delegates from all aspects of the dangerous goods industry.
Labels and Marks
It is imperative that hazard labels and handling marks, including those for LQ, not only comply with the dimensions set out in the regulations but they have the adhesive and scuff resistant properties to withstand the rigours of their journey. The labels are usually the cheapest element of a consignment but incorrect, damaged or ineligible labels have been the cause of many expensive snags.
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