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ADR | August 31, 2017

Last month, company A from Ljubljana (capital city of Slovenia), which sells special cleaning agents, received a smaller order from Ptuj.

The company does not have its own vans or field sales specialists; therefore, they outsourced the transport of goods to the said location. The transport was taken over by company B, which provides transport of various, also dangerous goods.

Company A prepared the package as instructed by company B. They packed the products in a box and put ADR labels on it.

The next day, the driver from company B took over the package and drove it to Ptuj.

Afterwards, company A was informed that the driver was pulled over by the police due to certain irregularities and imposed a fine in the amount of €10,000 (€3,000 to company A and €7,000 to company B).

What went wrong?

To get to the right answer, company A decided to get a professional opinion. Thus, the matter came to us.

After reviewing the documentation, we found out that ADR provisions were actually violated, but the violation was completely unnecessary.

Why?

If the package had been labelled correctly, the transportation would have been subject to ADR exemptions and most ADR provisions would not have applied.

However, company A followed the general ADR rule for labelling packages although it was not required for their products, let alone useful. Instead of putting a hazard label on the package and ordering an ADR transport, company A should have put a LQ label on the package.

Namely, ADR has certain exemptions based on which some ADR provisions do not have to be followed during the transport.

In this case, the products were packed in relevant, smaller packaging units to which limited quantities exemptions applies (LQ).

An exemption in this case means that all ADR provisions do not have to be considered in the transport but only provisions referring to package labelling. This means that company A should have put a LQ label instead of hazard label on the package and the package would have been correctly prepared for the dispatch.

What can you learn from this story?

Firstly, even if you have only one product packed in smaller packaging units this does not mean that ADR provisions for goods transport do not apply for you.

Secondly, each transport is specific; therefore, you should not rely on general rules that supposedly apply to your products. Just one incorrect label on the carton can cost you €3,000 or even more.

And thirdly, by ordering an ADR transport – even if it is not required (i.e. “just in case”) – you will not be excused from the penalty.

My advice is simple. Do not leave your business to chance as it can turn out very expensive.

If you are not sure about ADR matters, you should ask (your) ADR consultant.

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.com

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