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:

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 CP 50.

Gas cylinders should be transported in open vehicles, open containers or trailers. If it is necessary to transport gas cylinders inside a vehicle, then this should be subject to a specific risk assessment with appropriate controls implemented.  In all cases, good ventilation is required.  The use of roof ventilators along with side vents can help 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. an asphyxiant gas, and from the careless handling and use of welding gas cylinders and equipment, which may lead to a build-up of flammable and oxidant gases.  For vehicle selection refer to BCGA GN 35, for cylinders installed in vehicles refer to BCGA CP 31 and for the carriage of gas cylinders refer to BCGA CP 50.

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:

• Instructions in Writing for the dangerous goods
• Their Vocational Training Certificate (specific to the Class of dangerous goods being carried).

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).