This post is regarding the changes in ADR 2025 in respect to Limited Quantity Dangerous Goods which now requires ADR Awareness Training.
So the First question is – What is a Limited Quantity ?
Limited quantity dangerous goods are almost anything you can buy over the counter that contains a warning label. Aerosol cans, Lighter fluid , cleaning products and even some batteries. These are moved daily with almost every supermarket chain, general haulage contractor and even the likes of amazon.
This has been a hot subject recently and all were doing is sharing the information so don’t shoot the messenger. The question people want the answer to is do I require ADR Awareness Training?
Well lets look at what is required by law, The Following poster can be seen in every workplace as its a legal requirement.
Employers Responsibilities. This poster is a legal requirement for employers to display which highlights who shares what responsibility.
Part 1 – Ask the question, Is there any risk in carrying compressed aerosol cans or cleaning products. What if they are damaged? Could the driver or loading staff be burned with certain products or asphyxiated in a confined space(like the trailer) when the gases leak?
Part 2 – Its the employers responsibility to communicate this (or provide a competent person) to communicate this to the staff involved.
Part 3 – Put a plan in place to prevent this from happening
Part 4 – Train the staff in relation to the dangers mentioned above.
What now?
So now we know we need to make staff aware of the issues and decide what training should be provided. As much as its a Limited Quantity it is still governed under CDG (Carriage of Dangerous Goods) so I will refer to the CDG website. Do we need ADR Awareness Training though ?
https://www.hse.gov.uk/cdg/manual/exemptions.htm
If you scroll down to number 23 you will find the following text.
23. If a vehicle is carrying under the small load threshold, many of the requirements of ADR are not applicable. The table below summarises the position. Some care needs to be taken, as “what is not exempted is still required”. In most cases the remaining obligations are:
Stow the dangerous goods properly (ADR 7.5.7)
General training for driver (ADR 1.3.2). A record should be kept (ADR 1.3.3)
Carry one 2 kg dry powder fire extinguisher or equivalent (ADR 8.1.4.2)
Notice the highlighted part – General Training for driver reference ADR 1.3.2 ( ADR Awareness Training)
What does ADR 1.3.2 say ?
1.3.2
Nature of the training
The training shall take the following form, appropriate to the responsibility and duties of the
individual concerned.
Our ADR Awareness training courses cover this
1.3.2.1
General awareness training
Personnel shall be familiar with the general requirements of the provisions for the carriage of
dangerous goods.
1.3.2.2
Function-specific training
Personnel shall be trained, commensurate directly with their duties and responsibilities in the
requirements of the regulations concerning the carriage of dangerous goods.
Where the carriage of dangerous goods involves a multimodal transport operation, the personnel shall
be aware of the requirements concerning other transport modes.
“I would say this covers ADR Awareness Training”
1.3.2.4
Commensurate with the degree of risk of injury or exposure arising from an incident involving the
carriage of dangerous goods, including loading and unloading, personnel shall be trained in the
hazards and dangers presented by dangerous goods.
The training provided shall aim to make personnel aware of the safe handling and emergency response
procedures.
1.3.2.4
The training shall be periodically supplemented with refresher training to take account of changes in
regulations.
1.3.3
Documentation
Records of training received according to this Chapter shall be kept by the employer and made
available to the employee or competent authority, upon request. Records shall be kept by the employer
for a period of time established by the competent authority. Records of training shall be verified upon
commencing a new employment.
So now we know as well as the training we need evidence of ADR Awareness Training too?
Lets go back and look at 1.3.3
Documentation
Records of training received according to this Chapter shall be kept by the employer and made
available to the employee or competent authority, upon request. Records shall be kept by the employer
for a period of time established by the competent authority. Records of training shall be verified upon
commencing a new employment.
What does this mean for the employer?
Well in the event of an accident or even a road side check and the competent authority asks for proof of the General Training (ADR Awareness) the employer could be leaving themselves wide open to the Health and Safety Exec (See the first image)
When does this go live ?
Well it already is, It was published in ADR 2025 and these manuals are updated every 2 years. Now the current manual ADR 2023 expires on 30th June 2025.
What to do next ?
We provide ADR awareness courses and what’s more we can offer it as a drivers CPC course which will cover both your record keeping as well as your Driver Training.