ADR 2017: Key developments

The 2017 ADR, applicable from January 1st, updates the regulations for transporting dangerous goods. Key changes include updates to safety advisor requirements, package labeling, and the addition of polymerizing substances.

Marie Faucon
Consultante HSE
Publication : 
11.07.2016
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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Regulations for the road transport of dangerous goods are updated every odd-numbered year with the adoption of a new version of theADR. With the 2017 ADR set to be released in a few days, we are providing an overview of the main changes that can be applied starting January 1st , 2017, and will become mandatory on July 1st , 2017.

New ADR version

Safety Advisor

Dangerous goods packaging and tank filling operations must now be explicitly included in the Safety Advisor's duties. Consequently, the Safety Advisor will be required to review:

  • verification processes for equipment used in packaging and filling operations
  • emergency procedures for accidents or incidents occurring during packaging or filling operations
  • instructions and awareness training for personnel performing these types of operations.

Similarly, the Safety Advisor must prepare an accident report for company management in the event of an accident involving injury to persons, property, or the environment during a packaging or filling operation.

The 2017 ADR also introduces the option to conduct the Safety Advisor examination electronically, a practice already in place in some countries. However, the Interprofessional Committee for the Development of Training in the Transport of Dangerous Goods (CIFMD), which organizes the exam in France, does not currently plan to adopt this method in the near future.

Classification of dangerous goods

If a consignor determines through testing that a dangerous good specifically named in theADR presents a subsidiary risk not indicated on the hazard labels associated with its UN number, they may, with the agreement of the competent authority, ship the substance:

  • either under a more appropriate generic n.o.s. entry
  • or under the same UN number corresponding to the specifically named substance, provided that the transport document, package labels, or vehicle placards are updated to reflect the identified subsidiary risk, and that the primary hazard class is maintained and the transport rules applicable to the combination of risks are applied.

In such cases, the transport document must include the statement "classified in accordance with 2.1.2.8".

Polymerizing substances

Class 4.1, which previously included flammable solids, self-reactive substances, and desensitized solid explosives, now includes a new category: "polymerizing substances." This category covers 4 new UN numbers, 3531 to 3534, which are subject to various provisions designed to prevent product polymerization during transport.

Package marking

Additional marks required on packages by a special provision of ADR 2017 must be at least 12 mm high, easily visible and legible, and weather-resistant without significant degradation. This applies in particular to the "AEROSOLS" and "LITHIUM BATTERIES FOR DISPOSAL OR RECYCLING" marks.

Environmentally hazardous substances

Environmentally hazardous substances classified under UN 3077 (solids) and UN 3082 (liquids) are no longer subject to any tunnel passage restrictions. Previously, vehicles transporting these substances were prohibited from using category E tunnels (except for transport in packages with a net quantity ≤ 5 liters or 5 kg per single or inner packaging).

Aerosols

The packaging of aerosols (UN 1950) in large packagings must comply with a new packing instruction, LP200, replacing the current LP02 instruction. The large packagings used must, in particular, meet the packing group II test level ("Y" marking) instead of packing group III ("Z" marking). However, a transitional measure will allow the continued use of large packagings compliant with packing instruction LP02 until December 31, 2022.

Dry ice

Previously exempt from ADR, the transport of solid carbon dioxide (UN 1845) as a dangerous good will now be subject to the same provisions as the transport of packages or vehicles containing it for the purpose of cooling or conditioning other products.

In summary, packages must:

  • withstand low temperatures
  • not be affected by dry ice
  • be designed to allow gas to escape, in order to prevent a pressure build-up that could lead to the package rupturing
  • bear the marking "DRY ICE"
  • be transported in well-ventilated vehicles and containers (= carbon dioxide concentration below 0.5% by volume + oxygen concentration above 19.5% by volume), unless no gas exchange is possible between the loading compartment and the driver's cab.

If the vehicle or container is not sufficiently ventilated, and given the risk of asphyxiation, the following warning mark must be affixed at each access point. It must be easily visible to anyone opening the doors or entering the vehicle or container.

Empty, uncleaned packagings

As a reminder:

  • A contaminated packaging must have contained goods classified as dangerous by the ADR to be classified under the ADR itself.
  • Among packagings contaminated with dangerous goods, only empty AND cleaned packagings can be exempt from the ADR.

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In case no. 1, the empty packagings are in good condition. They can be closed and are intended for reuse. For transport in compliance with the ADR, they must be marked (UN number) and labeled as if they were full.

In accordance with ADR 2017, the description on the transport document accompanying such packagings that have contained substances of classes 3 to 9, excluding 7, will now be "EMPTY PACKAGING WITH RESIDUES OF [...]" followed by the class(es) and subsidiary risk(s) corresponding to the various residues.

For example, empty, uncleaned packagings that have contained class 3 goods transported with empty, uncleaned packagings that have contained class 8 goods presenting a class 6.1 subsidiary risk. They may be designated in the transport document as follows: "EMPTY PACKAGINGS WITH RESIDUES OF 3, 6.1, 8".

Lithium batteries

A new mark must be applied to packages containing "small" lithium batteries or cells prepared in accordance with special provision 188.

Furthermore, a new 9A label is being introduced for the labeling of other lithium battery and cell packages. This label replaces the Class 9 label for UN numbers 3090, 3091, 3480, and 3481.

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ADR safety instructions

The written safety instructions required to be kept on board vehicles have undergone several changes to reflect other developments in the ADR (e.g., the addition of polymerizing substances and the new 9A label for lithium batteries).

Updated safety instructions following the new template must be provided by carriers to their drivers byJuly 1, 2017, at the latest.

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