ChemRegs Newsletter – December 2024
Transport Regulations
As 2024 comes to an end, the new year brings into force the latest versions of the transport of dangerous goods regulations.
ADR 2025 is applicable from 1 January 2025 but, due to the transitional measures provided for in 1.6.1.1, there is a six-month transition period whereby the previous version, ADR 2023, may continue to be used until 30 June 2025.
The new version of ADR takes into account all new amendments adopted by the UN Working Party on the Transport of Dangerous Goods (WP.15) in 2022, 2023 and 2024, outlined in documents ECE/TRANS/WP.15/265 and -/Corr.1, and ECE/TRANS/WP.15/265/Add.1.
The changes includes 11 new UN numbers, several amendments and additions to the special provisions, packing instructions etc, and also a new ADR 2.2.9.1.7 covering sodium ion batteries. This is followed by further changes to cover the transport of sodium ion batteries in the rest of ADR.
In Chapter 3.2.1, the explanation of the columns in Table A: Dangerous Goods List, the explanation of column (4) now says that “Packing groups may also be assigned via special provisions in Chapter 3.3 as indicated in column (6).”
An amendment to ADR 8.1.2 ‘Documents to be carried on the transport unit’, now specifies that documents “shall be carried on the driver’s cab of the transport unit” rather than just “on the transport unit” as documents are often just attached to the packages. This also includes documentation such as driver’s photo ID, Instructions in Writing, etc.
Paragraph 5.4.0.2 on the use of electronic documents has been amended slightly to include the statement “The information prescribed in this chapter related to the dangerous goods carried shall be available during carriage in such a way that the goods per vehicle and the vehicle can be identified in the documentation.” The intention of this amendment is to ensure a link between the dangerous goods carried and the transport document. This is because for paper documents the link is automatically ensured by the presence of documents on board, but it was deemed necessary to ensure a link for electronic documents.
There is an additional requirement under the Limited Quantity (LQ provisions) in Chapter 3.4 to include the application of ADR 8.2.3. The addition of ADR 8.2.3 in ADR 3.4.1 (h) expressly indicates the obligation to train not only employees involved in loading, unloading, packing (and other activities related to the transport of dangerous goods), but also drivers (other than ADR drivers) transporting dangerous goods packed in limited quantities. This is not really a major change, as ADR 3.4.1 always indicated that the provisions in Chapter 1.3 on training apply to the carriage of LQ goods. Chapter 1.3, Note 2 also makes reference to ADR 8.2, which describes the requirements for the training of the vehicle crew, including training of persons other than certified drivers, involved in the carriage of dangerous goods by road. However, ADR 3.4.1 (h) previously did not mention 8.2.3, which is inconsistent with the requirements of Section 1.3 and raised doubts as to whether drivers carrying dangerous goods packed in LQs are subject to training in accordance with section 1.3. The addition of rule 8.2.3 in 3.4.1 (h) means that there will be no doubt that the driver (vehicle crew) transporting dangerous goods packed in limited quantities requires training in accordance with 1.3.
The International Maritime Dangerous Goods (IMDG) Code 2024 Edition (inc. Amendment 42-24) comes into force on 1 January 2026 but may be applied voluntarily as from 1 January 2025.
The current edition of the IMDG Code, 2022 Edition (inc. Amendment 41-22) came into force on 1 January 2024 and was able to be applied voluntarily as from 1 January 2023. This means that during 2025, the new amendment (42-24) and the 41-22 edition are both valid.
The majority of the changes included in Amendment 42-24 arise from the 23rd revised edition of the UN Model Regulations and provide harmonisation with the other modal regulations, including the new 11 UN numbers and provisions for sodium batteries. There are some additional changes that are specific to maritime transport, especially in terms of stowage and segregation aboard the ship.
Other regulatory developments in maritime transport include the new Carriage of Cargoes Regulations 2024, which have replaced some out of date regulations and sets out the basic provisions for the carriage of cargo.
The new Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) Amendment Regulations 2024 have updated and consolidated the UK regulations related to the transport of dangerous goods by sea, now bringing together all the relevant regulations in one place. This implements all International Maritime Organisation (IMO) conventions and codes, including the International Maritime Dangerous Goods (IMDG) Code, in the UK.
The 66th edition of the IATA Dangerous Goods Regulations (DGR) is due to come into force from 1 January 2025 and incorporates all amendments made by the ICAO Dangerous Goods Panel in developing the content of the 2025–2026 edition of the ICAO Technical Instructions, as well as changes adopted by the IATA Dangerous Goods Board. The list of the significant changes and amendments is available from the IATA website.
MERRY CHRISTMAS AND A VERY HAPPY NEW YEAR!!
We would like to wish you all a very Happy Christmas and a peaceful New Year
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