ADR 1.1.3.1 c) exemptions: Transporting hazardous with less regulations
Normally the very strict ADR special regulations apply to the transport of hazardous goods by road. In addition to flammable liquids (petrol, paints), explosives, many gases and toxic or corrosive chemicals, these also include lithium-ion batteries, which are often used by tradespeople in their tools. However, thanks to exemptions in section 1.1.3.1 c) of the ADR many companies that transport dangerous goods do not need to worry about training, labelling requirements on the vehicle, a second fire extinguisher or similar regulations.
Who can benefit from the the exemptions and when?
The following requirements must all be met in order to be able to transport dangerous goods without complications in accordance with ADR 1.1.3.1 c):
- The transport of hazardous goods is carried out as a secondary activity in connection with another main activity. The main activity is typically a craft. However, commercial agents (e.g. samples of chemicals sold), artists (e.g. paints), engineers (e.g. material for measurements) and other professional groups can also benefit.
- A maximum of 450 litres can be transported per package (including large packages).
- The 1000-point rule according to section 1.1.3.6 ADR is complied with.
- This is not a (pure) supply run.
- Under normal transport conditions, the hazardous substances are prevented from being released.
- The goods are not class 7 dangerous goods (radioactive material).
What is the 1,000-point rule?
According to section 1.1.3.6 ADR, different hazardous substances are each assigned a point value (factor) per kilo or litre. (Whether the points apply per kg or per l depends on the specific dangerous goods.) This factor can be between 0 and 50. For example, most lithium-ion batteries (UN numbers 3480, 3481) fall into transport category 2, which means they have 3 points per kg. Diesel, on the other hand, falls into category 3 and has 1 point per litre.
The individual quantities are multiplied by the respective factors and then added together. Here is an example calculation:
An employee of a civil engineering company is to take battery-powered tools and diesel fuel with him on his way to the construction site. The batteries together weigh 10 kg, with a factor of 3 this corresponds to 30 points.
As diesel has 1 point per litre, the construction worker can carry up to 970 l of diesel (divided into several containers) in the vehicle if he wants to comply with the 1000-point rule.
What are supply runs within the meaning of the ADR regulations?
Transports for internal and external supplies are excluded from the ADR 1.1.3.1 c) regulation. These supply runs are not explicitly defined in the ADR. However, journeys from a supplier to your own warehouse, journeys between your own sites and other journeys that are used exclusively for transport are definitely excluded. You should be on the safe side if the employee driving the vehicle is supposed to work at the destination of the transport himself and has not just driven off to fetch something.
How do I protect my employees?
The ADR 1.1.3.1 c) exemptions are not a free pass for inadequate cargo securing. Dangerous goods in particular must be secured against leaking, slipping, falling over and mechanical stress (e.g. from other cargo sliding around) during transport. Many hazardous goods must also be secured against heat, cold and/or sources of ignition. In addition to the 1000-point rule, common sense should also be observed. If two chemicals that can easily react with each other are to be transported, they should be placed in different vehicles if possible. As lithium-ion batteries – especially if they are damaged or inflated – can have a thermal runaway and thus cause a fire, they should not be transported together with flammable material or be placed in a fireproof box for batteries.
