Transport Matters

Driving can be hazardous at the best of times, but the safe carriage of dangerous goods requires compliance with complex regulations, an absolute commitment to best practice and professional levels of driver training and skill.

BCGA member companies actively promote safety during any transport journey to ensure their goods are delivered safely, the safety of vehicle crews and the safety of the general public. Within BCGA, transport matters are the responsibility of Technical Sub-Committee (TSC) 4. Members can access information on TSC4 via the ‘Members’ area.

Any goods that pose a risk to people, property and the environment are classified as dangerous goods. For transport, these goods need to be packaged correctly to ensure that they are safe for carriage. Gases are classified as dangerous goods. The transport of dangerous goods is regulated in order to prevent, as far as possible, accidents involving people or property, damage to the environment, to the means of transport employed or to other goods being transported. Each mode of transport, (road, rail, air, sea and inland waterway) has its own regulations but they are generally harmonized with the United Nations Economic Commission for Europe (UNECE). Recommendations on the transport of dangerous goods – Model Regulations.

The UN Model Regulations use a classification system in which each dangerous substance or article is assigned to a CLASS, depending on the nature of the danger it presents. Gases are assigned to Class 2, and are further sub-divided into three divisions:

Division 2.1
Flammable gases
Division 2.2
Non-flammable, non-toxic gases
Division 2.3
Toxic gases

UK Transport Legislation

The Secretary of State for Transport, within the Department for Transport (DfT), is the competent authority for Great Britain.

All vehicles and their drivers, operating on the public highway, shall comply with the Road Traffic Act.

For the transport of dangerous goods by road, rail and inland waterways, compliance is required with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG Regulations).  The CDG Regulations implement:

  • for road, the Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR);
  • for rail, the Convention concerning International Carriage by Rail (COTIF) Appendix C Regulations; The International Carriage of Dangerous Goods by Rail, (RID);
  • for inland waterways, the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN).  The UK is not a signatory to ADN, however, dangerous goods are transported on inland waterways in Europe and this should be taken into account when preparing a consignment for the continent.

For the transport of dangerous goods by sea, compliance is required with the International Maritime Dangerous Goods (IMDG) Code.

For the transport of dangerous goods by air, compliance is required with the International Civil Aviation Organization (ICAO) Technical Instructions.  In practice, compliance is required with the International Air Transport Association (IATA), Dangerous Goods Regulations, this publication is based on the ICAO Technical Instructions and is supported throughout the aviation industry.

Road transport

Everyone transporting gas cylinders in the course of their work has to meet certain basic minimum legal safety requirements.  A threshold level is set based on a quantity of transport units, if below the threshold you are exempt from some requirements of ADR but if you exceed the threshold level you are required to comply with the full ADR regulations.  Useful advice is available in BCGA GN 27.

It is recommended that gas cylinders are transported in open vehicles, open containers or trailers. If it is necessary to transport gas cylinders inside a vehicle, then good ventilation is required. In all spaces, the use of roof ventilators along with side vents will increase the quantity of ventilated air in the vehicle. If there is any possibility of gas accumulating within a vehicle storage space, then appropriate warning signs are to be displayed. Common hazards come from the use of dry ice, i.e. asphyxiant gas, and also the careless handling and use of welding gas cylinders and equipment which may lead to a build-up of flammable and oxidant gases.  Guidance is available in BCGA CP 31 and BCGA GN 27.

Once the journey is completed gas cylinders should be removed from the vehicle.

An empty, or partially filled, gas container that has contained a dangerous substance is to be treated the same as a full container and is therefore subject to all the relevant transport dangerous goods regulations.  Only if adequate measures have been taken to nullify any hazard may the container be treated as non-hazardous.

When dangerous goods are being transported, the driver of the vehicle is required to carry certain documents, these include:

All personnel involved in the carriage of dangerous goods require training and instruction, this includes administration staff, site security staff as well as drivers and vehicle attendants. Additionally, certain drivers of road vehicles carrying dangerous goods may need to hold a vocational training certificate (VTC, or “ADR certificate”). In the UK the VTC is obtained after a driver has attended a training course and successfully completed an examination, approved by the DfT. The examination has to be appropriate to the class or classes of goods which are to be carried on the vehicle. Refer to DfT and to BCGA GN 35.

Dangerous goods can be attractive to thieves and terrorists.  Everybody involved in the storage and distribution of dangerous goods should take appropriate security measures and precautions to minimise the likelihood of theft or misuse.  ADR, Chapter 1.10, has specific requirements.  BCGA CP 40 provides useful guidance.  DfT provide guidance on security requirements for moving dangerous goods by road and rail, including a training film on the security of high consequence dangerous goods, titled ‘Lockdown’. The film is available on request from DfT.

DGSA. Organisations that handle (including the transport related activities of loading and unloading), process or transport dangerous goods need to appoint a dangerous goods safety adviser(s) (DGSA).  DGSA’s need to be competent for the role and to have obtained a vocational training certificate (VTC) after undergoing training and successfully completing a written examination approved by the DfT.  The role and duties of a DGSA are laid out in ADR Chapter 1.8. As part of these duties the DGSA is required to produce an Annual Report.  BCGA GN 45 provides guidance for DGSAs, with further information available through the British Association of Dangerous Goods Professionals (BADGP).

Publications

Publications

CP16 The movement of static gas storage tanks by road. Revision 5: 2019

30/06/2019 Codes of Practice CP16

The movement on public roads of storage tanks, as well as other gaseous equipment, designed for use in a static location. This code does not apply to tanks designed to comply with the road transport Regulations.

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CP27 Transportable vacuum insulated containers of not more than 1000 litres volume. Revision 1: 2004

01/09/2004 Codes of Practice CP27

This code of practice applies to transportable, vacuum insulated, tanks of not more than 1,000 litres water capacity, for the following gases: Nitrogen, argon, oxygen, carbon dioxide, helium or nitrous oxide.This code provides guidance for the minimum requirements for: General safety precautions, design and construction, operation, tank management and filling, transportation, in-service examination, modifications/repairs and records.

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CP29 The design and operation of cylinder and tube trailers (battery vehicles) and multiple-element gas containers for the safe transport of compressed gases by road. Revision 2: 2013

01/09/2013 Codes of Practice CP29


Provides practical guidance on the design, construction, examination, testing and certification, and the filling/discharging of cylinder vehicle/trailers used for the domestic conveyance of compressed, but not liquefiable gases.

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CP31 The safe storage and use of cylinders on mobile workshops and service vehicles. Revision 5: 2020

01/09/2020 Codes of Practice CP31

Details the design, construction and operation of vehicles which are used as mobile workshops or provide a specialist capability, where there is a specific requirement to use a gas. It covers the safe carriage of gas cylinders and the safe installation of gas equipment on such vehicles. It provides guidance on safe use and the competence of operators to ensure high levels of safety awareness and operational safety.

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CP38 In-service requirements for refrigerated gas transportable pressure equipment. Revision 1: 2018

01/09/2018 Codes of Practice CP38

Provides guidance on the management of in-service refrigerated gas transportable pressure equipment to ensure that it is serviceable for the safe transportation of gases without unintended release during the complete journey. The equipment covered includes road tankers, tank containers and other tanks used for the operation of special equipment used during transport, such as cooling equipment.

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GN27 Guidance for the carriage of gas cylinders on vehicles. Revision 2: 2017

09/05/2017 Guidance Notes GN27

Provides guidance on safely transporting gas cylinders in order to comply with ADR and provides a method for calculating the threshold quantity for any gas cylinders being carried.

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GN35 Vehicle selection and transport management. 2017

09/04/2017 Guidance Notes GN35

Provides advice on vehicle selection, the recruitment, training and assessment of transport personnel and the relevant elements of a transport management system associated with Class 2 dangerous goods.

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L1 The carriage of small quantities of gas cylinders. Revision 6: 2021

04/08/2021 Leaflets L1

Highlights the legal and basic safety requirements for transporting small quantities of gas cylinders on a vehicle whilst at work and provides sound advice if transporting gas cylinders for personal use.

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L13 Medical gases. Medical oxygen in a vehicle. Revision 3: 2020

22/07/2020 Leaflets L13

This leaflet highlights the key safety information for patients and drivers where medical oxygen cylinders or medical liquid oxygen equipment is used and / or transported for personal use in a vehicle.

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TIS26 Model risk assessment for the transport of gas cylinders. 2012

26/07/2012 Technical Information Sheets TIS26

A Model Risk Assessment intended to support BCGA Code of Practice 31 and which assists users with identifying and managing the safety hazards associated with the transportation of gas cylinder packages containing both compressed, liquefied and dissolved gases. It does not cover cylinder bundles and cryogenic liquid vessels.

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TIS45 Guidance for the protection of vehicle crew working in all weather conditions. 2019

19/02/2019 Technical Information Sheets TIS45

Vehicle crews are required to work outdoors in all weather conditions. This document provides guidance on the weather conditions that may be encountered and advice on the risk assessment and subsequent control measures that may be necessary.

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GN45 Dangerous Goods Safety Advisor. 2022

12/01/2022 Guidance Notes GN45

Sets out the purpose, role and duties of a Dangerous Goods Safety Advisor, with an emphasis on Class 2 (gases) dangerous goods.

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