Have you ever wondered if you need an ADR transport document when doing presentations of your products and therefore carrying cleaners - both in different packagings and of different types - that may represent dangerous goods for transportation?
So do sales representatives need a transport document when going to present machines to potential buyers and also carry cleaners in their car?
For a better understanding of the issue, let’s add some detail. Let’s say they carry with them:
- machines containing industrial batteries (wet, gel or AGM),
- different cleaners you sell in your company. They usually take more samples in 5 or 10 kg canisters. These samples are not necessarily full, as they are used in different presentations.
Is the answer to the question regarding ADR transport documents easier now?
If you don’t know the answer, you are not alone - this is an example that perfectly illustrates the complexity of chemical legislation.
Let’s see the answer.
In such cases, an exemption to ADR, related to the nature of the transport operation, applies.
Pursuant to Section 18.104.22.168 (c), the provisions laid down in ADR do not apply to the carriage undertaken by enterprises which is ancillary to their main activity, such as deliveries to or returns from building or civil engineering sites, or in relation to surveying, repairs and maintenance, in quantities of not more than 450 litres per packaging and within the maximum quantities specified in 22.214.171.124 (up to 1000 points).
However, they must take all measures necessary to prevent the contents from leaking during normal transport conditions.
In such cases, the carriage of cleaners for promotion/presentation purposes is an ancillary activity. This means you do NOT need a transport document since such carriage represents an exemption to ADR.
However, everything is not as simple and straightforward. What does this mean? You should remember the following. For transports undertaken by enterprises for their own supply or for external and internal distribution, this exemption does not apply. In these cases, you DO need a transport document.
So now you know how to handle promotions and presentations.
If you have any more questions regarding ADR, please do not hesitate to ask me. Case studies are the best teachers for understanding theory.