International Association of dangerous goods Safety Advisers IASA
Radonie, 29.10.2025 r.
Subject: Clarification of the application of exemption 1.1.3.6 of the ADR in the context of the appointment of an advisor in accordance with 1.8.3.2 (b).
Introduction
Due to the interconnection of provisions 1.8.3.2 (b) and 1.1.3.6 regarding the obligation to appoint a safety advisor, the interpretation of exemption 1.1.3.6 is crucial. Does it apply to the carriage of packages, or also to the carriage of bulk and tanks? ADR 2025 regulation 1.8.3.2 (b) reads:
"The competent authorities of the Contracting Parties may provide that these requirements shall not apply to undertakings:
The activities of which concern quantities in each transport unit not exceeding those referred to in 1.1.3.6, 1.7.1.4 and in Chapters 3.3, 3.4 and 3.5; or (…)”
The regulation does not specify the mode of carriage: in packages, in bulk, in tanks. The reference is only to "quantities in each transport unit," which could mean that the mode of carriage is irrelevant. However, provision 1.1.3.6.2 states:
„Where the quantity of dangerous goods carried on a transport unit does not exceed the values indicated in column (3) of the table in 1.1.3.6.3 for a given transport category (when the dangerous goods carried in the transport unit belong to the same category) or the value calculated in accordance with 1.1.3.6.4 (when the dangerous goods carried in the transport unit belong to different transport categories), they may be carried in packages in one transport unit without application of the following provisions: (...)"
If the Competent Authority of a Contracting Party has implemented provision 1.8.3.2 (b) without any amendments, does this mean that for quantities of goods in each transport unit not exceeding those given in 1.1.3.6, the exemption applies only to transport in packages, or also to the transport of goods in tanks and in bulk?
Example 1
The consigning of 1,000 liters of UN3082 waste (transport category 3) in a tank. The tank is filled by the driver/carrier. The tank is marked with orange-coloured plate with hazard identification number and UN number. The consignor, who is responsible for classifying the goods, must also issue a transport document for the carrier. Does the consignor shall appoint safety adviser?
Example 2
The consigning of 1,000 kg of UN 3509 waste (transport category 3) in bulk. The bulk container is filled by the consignor's employee. The vehicle with the bulk container is marked with orange-coloured plate with hazard identification number and UN number. Does the consignor/filler shall appoint safety adviser?
In both cases, the situation is clear for shipping the same dangerous goods in identical quantities in packages, e.g., drums. Pursuant to 1.1.3.6.2, in conjunction with 1.8.3.2 (b), there is no obligation to appoint an advisor to transport in packages.
Justification
It is crucial to clarify whether a transport participant is legally obligated to appoint a safety advisor. In some countries, failure to appoint an advisor may result in the imposition of penalties by competent authority. At the same time, failure to appoint an advisor and their supervision of transport operations may pose a threat to the safety of road users.
We request clarification as to whether, under provision 1.8.3.2 (b), in conjunction with 1.1.3.6, a transport participant is obligated to appoint an advisor for the quantities of goods in each transport unit that do not exceed the quantities specified in 1.1.3.6 – for transport in packages, or also for transport in bulk and in tanks?
Dear all
As agreed in Luxembourg we in the WG for the white paper have been working on the questions that will be the basis for the paper to be issued; and for which we need your input by latest 20 December 2025.
We acknowledge that there are many questions that will take some time to answer as well some questions are subjective; for those subjective we still would like to collect the opinions and based on all the answers we can decide how to best use the feedback.
To allow flexibility, the questions are shared to all IASA members in attached word document so the questions can be reviewed.
Responses can either be by providing responses in this word file and submit to generalsecretary@dgsa-iasa.org or by first work in this file and copy/paste the responses to the Microsoft Forms accessed via this link >>>
To get as good data as possible we do really hope and appreciate that all of you members respond to this questionnaire by latest 20 December 2025.
The more responders the more credible paper we will be able to create and publish. As we cover about 50% of the ADR/RID contracting countries, if all members could respond we would get a really good overview.
Thank you
Rgds
// WG IASA for the Future
Giovanni Adamo – AES, João Cezília – APSEI, Les Richings – BADGP, Magnus Falk – IASA/SFGS, Martin Kints – BSAA, Michèle BODSON – ALMD
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