In this feature article, Caroline Raine discusses some of the common mistakes made on dangerous goods notes by companies transporting dangerous goods.
When transporting dangerous goods, information is legally required to be provided to the carrier in a traceable format. The transport document used to provide this information is often known as a dangerous goods note (DGN), dangerous goods consignment note, or transport documentation.
The requirements for dangerous goods notes are set out in Chapter 5.4 of ADR, and 5.4 of the IMDG Code.
The DGN must be prepared in an official language of the forwarding country, and also in English, French or German if the official language is not one of these. For some countries, there are multi-lateral agreements in place that allow relaxations to this rule. For example, M85 allows the DGN to be written in Danish, Swedish or Norwegian if the consignment is being transported between Denmark, Sweden or Norway.
Multilateral Agreement M178 permits the use of Portuguese or Spanish for carriage between Portugal and Spain.
Information required on the dangerous goods note
The following is mandatory required on the dangerous goods consignment note:
- The UN Number
- Proper shipping name
- Class (with subsidiary hazard, if any, in brackets)
- Packing group (where assigned)
- Number and description of packages
- Total quantity of each item of different UN Number
- Name/address of consignor
- Name /address of consignee(s)
- Where assigned, the tunnel code, except where it is known that the journey will not involve passing through a relevant tunnel (not required for sea).
- Container / vehicle packing certificate & Flash Point– for containers and vehicles taking a sea voyage as part of their journey the vehicle / container packing certificate must be completed.
- Also for shipments taking a voyage by sea if the dangerous goods have a flash point of 60°C or below then the minimum closed up flash point shall be indicated in brackets, ie (55°C).
Let’s look at some common mistakes found on dangerous goods notes.
Incorrect order or missing information
The regulations quite clearly state that the information on the type of dangerous goods must be provided in the prescribed order, namely the UN Number, Proper shipping name, Class (with subsidiary hazard, if any, in brackets), Packing group (where assigned), tunnel code.
Often there is information missing or it is presented in the incorrect order.
Examples of such permitted dangerous goods descriptions are:
"UN 1098 ALLYL ALCOHOL, 6.1 (3), I, (C/D)" or
"UN 1098, ALLYL ALCOHOL, 6.1 (3), PG I, (C/D)"
Special provision 274
Dangerous goods that are transported under not otherwise specified (NOS) names are assigned the Special Provision 274 (SP274). SP274 under ADR simply states that the provisions of ADR 184.108.40.206 apply.
ADR 220.127.116.11 refers to generic or names and stipulates the requirement to insert the technical name (in brackets) after the proper shipping name (PSN) NOS entry. The only exception to withholding this name is if national law or international convention prohibits its disclosure if it is a controlled substance. The technical name should be a recognised chemical name, or chemical group name; trade names are not allowed. Additional words such as “contains”, “containing”, “solution” or “mixture” may also be used, as may percentages, “UN1993 FLAMMABLE LIQUID, N.O.S. (CONTAINS XYLENE AND BENZENE), 3, II”.
When the dangerous goods being transported are a mixture, no more than two of the constituents should be shown. When deciding which constituents to show, the most hazardous substance or those which most predominantly contribute to the hazard must be shown.
Examples of the PSN with the technical name for NOS entries are shown in ADR 18.104.22.168.1.3, as follows:
“UN2902 PESTICIDE, LIQUID, TOXIC, N.O.S. (drazoxolon).”
“UN3394 ORGANOMETALLIC SUSTANCE, LIQUID, PYROPHORIC, WATER-REACTIVE (trimethylgallium).”
For transport by sea, if the goods have a flashpoint of 60°C or less, minimum flashpoints need to be provided or, if applicable, the appropriate IMDG code segregation group needs to be indicated.
“UN 1098 ALLYL ALCOHOL, 6.1(3), I (21°C c.c.) Carriage in accordance with 22.214.171.124.1”
Environmentally hazardous materials
For materials that are classified as environmentally hazardous, ADR requires that the words ‘ENVIRONMENTALLY HAZARDOUS’ are given on the DGN. Similarly, IMDG requires that the words ‘MARINE POLLUTANT’ be included. This is often completely forgotten on transport documents.
Both ADR and IMDG recognise the use of the combined phrase ‘ENVIRONMENTALLY HAZARDOUS/MARINE POLLUTANT’ for multi-modal consignments. This combined phrase is preferable to avoid potential confusion.
If transporting by sea, IMDG requires that for marine pollutants assigned a generic N.O.S. proper shipping name, it is supplemented by the chemical name of the substances primarily responsible for the marine pollutant classification.
When transporting wastes by road or sea, the word ‘Waste’ must be inserted into the dangerous goods description, in front of the proper shipping name. Again, this if often missed from DGNs.
"UN 1230 WASTE METHANOL, 3 (6.1), II, (D/E)", or
"UN 1230 WASTE METHANOL, 3 (6.1), PG II, (D/E)", or
"UN 1993 WASTE FLAMMABLE LIQUID, N.O.S. (toluene and ethyl alcohol), 3, II, (D/E)", or
"UN 1993 WASTE FLAMMABLE LIQUID, N.O.S. (toluene and ethyl alcohol), 3, PG II, (D/E)".
Container/Vehicle Packing Certificate Not Completed
The minimum information required on the Packing Certificate is a name, date and signature. The person who packed and loaded the goods onto the vehicle must complete this.
The Container/Vehicle Packing Certificate must be completed by the person responsible for loading the goods into the vehicle.
When shipping limited quantities by sea the words “LIMITED QUANTITY” should be included after the substance/article description. Shipping lines will not accept any goods as LQs unless the words “LIMITED QUANTITY” or “LIMITED QUANTITIES” are included on the dangerous goods declaration.
This feature does not list all of the potential mistakes that could be made on the transport documents but highlights those that are commonly spotted when checking dangerous goods notes.
It is important to provide this information in the required format. It is important information that may be used in the event of an incident and so it must be correct. Not only that it is a legal requirement!
If you are unsure on how to complete the dangerous goods note, speak to your Dangerous Goods Safety Advisor (DGSA) who will be able to assist.