Articles in dangerous goods, which contain dangerous goods

This is a surprise – in the ADR 2019, articles in dangerous goods have their own specific numbers that did not exist before. With the application of the Carriage of Dangerous Goods Regulations, 12 new UN numbers have been introduced. These new UN numbers replace the previous regulation that dangerous goods in the functional elements of machines and devices are explicitly exempted from the Carriage of Dangerous Goods Regulations.

What are the transitional rules which apply?

• Road transport: the current exemption applies until 31/12/2022
• Maritime transport: the current exemption applies until 31/12/2019
• Air transport: the regulation applies since 01/01/2019

What is covered by these new UN numbers?

All articles which contain dangerous goods in their functional elements and are not yet explicitly named in the Carriage Regulations have to be assigned to one of the new UN numbers. The new UN numbers do not apply to articles which contain radioactive or explosive substances. These must always be assigned to one of these two classes. Examples of the new UN numbers:

1. Articles containing environmentally hazardous liquids or solids
2. Articles containing flammable or toxic gases
3. Test equipment with attached gas cylinders
4. …

Currently, day-to-day practice shows which articles may be assigned to these UN numbers. An in-depth exchange of experience is still needed here.

Do safety data sheets have to be created for these articles?

Safety data sheets are necessary when substances or mixtures of substances are involved. Such an obligation may also exist for products under certain circumstances. Articles which are named in the Dangerous Goods Act will not be subject to such an obligation as a rule, as the dangerous goods are present in the functional elements and must not be able to escape under normal conditions of carriage. As a result, it is possible to refer to the safety information in such cases.