Which companies need a safety advisor for transport in Slovenia is stated in Article 28 of the Transport of Dangerous Goods Act:
“Legal entities and private entrepreneurs with their registered office in the Republic of Slovenia, whose activity includes:
- transport of dangerous goods by road or rail
- or the packaging associated with such transport,
- loading,
- charging or
- unloading,
must appoint at least one safety advisor for the transport of dangerous goods.”
Let me remind you. Dangerous goods are those that have a specific UN number. For chemicals, the UN number is given in section 14 of the safety data sheet.
Advisor details must be communicated to the ministry responsible for transport no later than 15 days after the appointment. They must also notify the said ministry of any changes within the same period.
Legal entities and private entrepreneurs whose activity involves transport of small quantities of dangerous goods and dangerous goods in limited or exempted quantities (transport under ADR exemptions) by road or rail, or the packaging, loading or unloading associated with such transport, are not required to appoint an advisor.
However, they must be trained to identify dangerous goods and apply ADR exemptions correctly.
I will present these facts in a concrete example.
The Slovenian company took over only small quantities of dangerous goods (up to 1000 kg) and dangerous goods in small packaging units (packaging up to 5 L). On one occasion, they took over products in 20 L packaging in the amount of 6 tons.
They were really unlucky that these products were noticed by an inspector who was reviewing compliance with legislation that was not related to transport at all. As she found a discrepancy (inappropriate packaging), she reported them to the infrastructure inspector. In less than a week, they already had an ADR inspection at the company…
The competent authority may carry out inspections on the consignor, carrier or consignee of dangerous goods or on other legal entities or natural persons engaged in any activity relating to the transport of dangerous goods.
The inspection surveillance started with the following sentences, which were not encouraging:
- you have taken over dangerous goods, and you do not have a safety advisor — fine of up to EUR 4,000,
- dangerous goods are not properly marked, packaging is not appropriate — fine of up to EUR 4,000,
- warehouse keepers who have unloaded dangerous goods are not qualified under ADR — fine up to EUR 4,000,
- a penalty of EUR 200 to EUR 800 is prescribed for the responsible person (director).
Fortunately, the day before the inspector's arrival, we have sorted out what was possible in such a short time:
- We have conducted ADR training,
- we sought all possible exemptions and reliefs,
- we have arranged the transport documents.
The inspector found that the company had taken the matter seriously and has already settled quite a few things. In the end, the company was fined for a minor violation because they took over dangerous goods and did not have a safety advisor appointed. And that applies for acceptances for 2 years ago.
The final fine was EUR 1,000 for the company and EUR 200 for the director (for payment within 8 days this means “half” — EUR 600).
A similar could apply for you if you have taken over or are taking over dangerous goods that are not transported to you as an ADR exemption. Example: if you have taken more than 1000 l (or kg) of dangerous goods packed in more than 5 L packaging.
Let me make a simple conclusion: if a vehicle with open orange plate is brought to or from your yard in Slovenia, you need an ADR advisor. And he is only one phone call away from you.
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