From time to time, the question of how to transport dangerous goods as a private person comes back – because somehow sometimes you have to transport it. Examples of such goods include gasoline, diesel oil, various types of gases, etc. Most people have a feeling that there must be such a thing as the transport of dangerous goods for personal use. Usually, we have no problem with transporting this type of goods (“in reasonable quantities”) within the country. However, the issue comes back when something needs to be transported across borders. What must be taken into account in order to be able to transport dangerous goods freely in this way?
Transport of DG for personal use
Living in Europe, we can enjoy the benefits of the Schengen area and the customs union. But let’s not forget about the benefits of the ADR Agreement, which regulates these types of issues in almost all European countries. The exact list of countries covered by these regulations can be found here. Provision 220.127.116.11 of this Agreement, point (a), informs us about the possibility of transporting dangerous goods by private persons. For this to be possible, several conditions must be met, i.e. the dangerous goods must:
- be packed in retail packaging;
- serve persons carrying them for personal use only;
- be transported using measures to prevent the release of the contents in normal conditions of transport.
An exception is made of flammable liquids carried in refillable vessels filled by or for a private individual. We are talking here about the gasoline canister. In such a situation, we cannot exceed 60 liters for a single package and 240 liters for a transport unit.
It is also worth referring to what the third of the above points actually means. What do normal conditions of carriage mean? These are the conditions in which certain difficulties may occur, resulting, for example, from deteriorated weather conditions. Such conditions do not assume an accident, but allow a number of actions to avoid an accident. This means that you should take into account, for example, sudden braking or a sudden avoidance of an obstacle. Therefore, transport for own needs should be characterized by good protection of the dangerous goods. It should be secured in a way that prevents it from moving on the loading surface or changing its position. Other security measures adequate to the dangerous goods transported with the use of this exclusion should also be taken into account.
This provision also specifies what should not be understood as transport for personal use:
“Dangerous goods in IBCs, large packagings or tanks are not considered to be for retail sale“.
So it’s true that some dangerous goods can even be bought in IBCs. And while it may be a form of retail, the ADR Agreement makes it clear that it cannot be interpreted that way. So here we have a clear quantitative limitation and trying to interpret it differently, in the case of control, may result in consequences.
An example and summary
Argon is an example of a dangerous goods transported for own needs. The title photo of this entry shows an argon bottle with a capacity of 8L. This amount of this gas (UN1006) in such a vessel can be transported using the discussed exemption.
Please note that this exclusion applies only to private individuals. However, there are other ADR exemptions, such as 18.104.22.168 and LQ, that can be used successfully by businesses. At the same time, this means that when performing the transport for our own needs (personal use), we cannot declare that we perform any professional work with the use of this specific dangerous goods.
The skilful use of the exemptions allows for a significant reduction in transport costs or the costs of handling dangerous goods. Please note, however, that most of the exemptions from ADR are partial – this means that some of these requirements still apply. One of them is the need to conduct on-the-job training of the personnel involved in handling such goods. The multitude of ADR provisions makes it worthwhile to consult the DGSA, which will help to determine whether there are any possibilities to reduce the costs of DG’s transport.
Both this post and all content on this website are for general information purposes only. It should not be understood as DG consulting.