All consignors and carriers of dangerous goods within the UK must meet the requirements of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended) (CDG09).
CDG09 transposes into UK law international agreements such as the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR).
ADR assigns dangerous goods to classes ranging from 1 to 9 and requires drivers to hold a valid ADR driving licence (except in very specific circumstances), for the class of dangerous goods they are to carry.
In most cases, the carriage of dangerous goods requires transport documents and instructions in writing to be carried in the transport unit. Further information on this can be found at Chapter 8.1 of ADR.
For Class 7 dangerous goods (radioactive material), CDG09 places additional requirements on both consignors and carriers: they are also required to meet the requirements of the Ionising Radiations Regulations 2017 (IRR17).
CDG09 and IRR17 require consignors and carriers to have the following in place in advance of any transport of Class 7 dangerous goods:
- Suitable and sufficient transport Radiation Risk Assessments, as required by Regulation 8 of IRR17 for the loads they are offering/carrying. ONR has published additional guidance on transport Radiation Risk Assessments.
- Suitable emergency arrangements as required by Schedule 2, Part 1, Paragraph 3 of CDG09 and Regulation 13 of IRR17. ONR has published guidance on transport emergency planning.
- Procedures to report transport incidents to ONR:
https://www.onr.org.uk/notify-onr.htm refers, supported by ONR guidance https://www.onr.org.uk/operational/inspection/onr-rio-proc- 002.docx and https://www.onr.org.uk/operational/inspection/onr-rio-gd- 005.docx.
Note:
If ADR drivers are employed by a carrier company, the company has the responsibility to meet the requirements specified in 1-3 above. However, if ADR drivers are self-employed, they themselves have the responsibility to meet the requirements specified in 1-3 above.
Organisations, such as freight forwarders, import agents or similar, that organise transport on behalf of the consignor or other transport dutyholders, are responsible for ensuring that these requirements have been met by both the consignor and carrier.
How to obtain more information/support
Both CDG09 and IRR17 require transport dutyholders to consult, and where appropriate appoint, Safety Advisers (Dangerous Goods Safety Advisers – DGSAs, and Radiation Protection Advisers – RPAs) to obtain advice on how to comply with CDG09, ADR and IRR17.
The Society for Radiological Protection has also produced a leaflet aimed at anyone considering transporting Class 7 dangerous goods A Guide to the Transport of Dangerous Goods 08 12 2023 (3).pdf.
For any queries, please contact DfT Dangerous Goods Unit (dangerousgoods@dft.gov.uk) or ONR (contact@onr.gov.uk).