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ADR Biocides | April 9, 2020

Recently, the production of hand-cleaning preparations and various disinfectants in the form of alcoholic solutions, gels, wipes, sprays etc. has increased significantly. 

All of these products also need to be transported from production warehouses to various users. 

So, you should consider that many of these products, especially alcohol-based products, are dangerous goods within the meaning of transport regulations. 

Now let's look at an example of an ethanol based hand sanitizer. In order to know how to properly organise the transport, we first need to look at section 14 of the Safety Data Sheet.

This section provides a UN number that tells us what the goods are and what this means for transport. In our case, this is UN 1170 (ETHANOL, SOLUTION), packing group II. This means that in our case the hand-cleaning preparations are considered dangerous goods for transport.

Section 14 also states that the limited quantity for this UN number is 1L.This means that for packages equal to or less than 1L, you can use the ADR 3.4 exemption – transportation of limited quantities (small packaging units).

This information is crucial and should be considered when preparing the products for transport. In this case, the following should be taken into account:

  • The inner packaging must be placed in an outer shipping carton bearing the LQ Label (10 cm x 10 cm in size).
  • Since alcohol-based disinfectants are usually liquid, directional arrows on two opposite sides must be placed on the outer transport carton.

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  • The CLP Label on the outer transport carton is optional because the carton is already ADR-labelled.
  • The outer carton must not weigh more than 30 kg (gross weight).
  • Therefore, the transport of such packages is subject to the ADR exemption and is not a classic ADR transport.

Another question that comes up on its own is "What if the limited quantity (for the 1L example above) is exceeded"?

In this case, the package must be labelled in accordance with the ADR (UN number, ADR Label).The CLP Label must also be affixed to each package. The packaging in which the dangerous goods are packaged must be tested and approved in accordance with the ADR (must bear the ADR code):

tabela1

In this case, you must make a transport document. You can easily use our Chemius program to prepare your transport documents quickly and correctly.

If the calculation of points in the transport document does not exceed 1000, you can use the ADR exemption 1.1.3.6. – transportation of small quantities of dangerous goods. However, if the calculation of points in the transport document exceeds 1000, it is a classic ADR transport.

If you have any questions regarding the transport of your disinfectants, we are at your disposal for further clarification.

  

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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