Private transport of dangerous goods

Private individuals enjoy a special exemption (in accordance with ADR 1.1.3.1). The other provisions of ADR* do not apply if the dangerous goods are packaged for retail sale and are intended for personal or domestic use and for leisure and sport, and measures are taken to prevent the contents from being released under normal conditions.

For flammable liquids in refillable containers (e.g. fuel canisters), the following also applies: max. 60 l per container and max. 240 l in total. Bulk packaging such as "Intermediate Bulk Containers" (IBC) are not considered to be retail-ready any more than tanks.

In Switzerland, the Ordinance on the Transport of Dangerous Goods by Road (SDR) must also be observed, which further limits previous exemption. The total quantity of dangerous goods that may be carried privately in a transport unit (vehicle plus trailer) is limited to a value of 300 points, similar to the well-known 1000-point rule according to ADR 1.1.3.6 (see link to table in box).

Hazardous goods classification

In order to apply this rule correctly, a private individual must classify his own purchase in terms of dangerous goods law, i.e. know the dangerous goods class, UN number and packaging group (VG) of the purchased goods. In addition, it must be determined to which unit (kilogram or litre) the maximum permissible total quantity refers. For liquid dangerous goods it is liters, for solid dangerous goods or articles it is kilograms. And what about the gas cylinders from the initial example? Here it depends on whether the gas is compressed, liquefied or dissolved. Gas cylinders for the next dive contain compressed gas. So you have to know the capacity of the vessel in litres, which is filled with water. For objects containing explosives (class 1, e.g. fireworks or ammunition), it is the net quantity of explosives in kilograms that counts.

This means that private individuals do not have to read the entire ADR, parts 1 to 3 (a total of almost 1000 pages!) should be sufficient to correctly apply the exemption according to SDR. Since hardly anyone will do this to themselves, the question arises as to whether private individuals will ever reach the point where the 300 points according to the SDR are exceeded.

Case study 1 - Diving trip

Cylinders containing compressed air are classified as UN 1002, classification code 1A. According to Table A, a maximum of 300 l cylinder volume may be carried. Thirty 10-litre diving cylinders should be sufficient for a family diving trip. The carriage of diving equipment is therefore not normally subject to ADR.

Case study 2 - Shooting range

For those who prefer to spend their free time on the shooting range instead of diving, the following case study: Ammunition calibre 7.5 × 55 mm Swiss (Gw Pat 11) is transported here. These are class 1 items, classification code 1.4S. The maximum permissible total quantity is 5 kg, based on the net personal explosive quantity. In the case of the Gw Pat 11, this amounts to 0.0033 kg per shot.¹ The maximum total quantity that is still exempt for a private individual is therefore 1515 shots - more than enough for shooting training.

Case study 3 - Shopping at the hardware store

Back to the example from the beginning of this post. In the DIY store, 5 kg of pool disinfectant (UN 3260, Class 8, VG II), twelve 0.5 l spray cans of clear varnish (UN 1950, classification code 5F), 30 l of paint (UN 1263, Class 3, VG II), two 15 kg lead batteries (UN 2794, Class 8) and ten 50 g lithium metal batteries (UN 3090, Class 9) are purchased. In the trunk there are already eight 10-litre diving cylinders (UN 1002) plus a box of fireworks (UN 0336, classification code 1.4G) with a net explosive quantity of 500 g. This results in a total score of 264.5 for the entire transport (see table).

The rather adventurous purchase from case study 3 shows that as a private individual, the 300 points - and thus the exemption limit - are not normally exceeded. However, anyone who transports larger quantities of dangerous goods as part of an association activity may well be affected.

A question of safety

Apart from legal compliance, the real question is one of safety. Does it make sense that the regulations for dangerous goods do not apply to private individuals? For those who prefer not to observe fish during a dive, but at home from dry land, the following example: An aquarium owner wants to transport a CO2 bottle.

According to ADR, special provision CV36 applies to this transport: "Packages shall preferably be loaded into open or ventilated vehicles or into open or ventilated containers (...)" The SDR requires: "If an exchange of gas between the loading compartment and the driver's cab is not excluded, packages shall be loaded into open or ventilated vehicles or into open or ventilated containers." Private individuals, as we have learned in the previous case studies, are exempt from these rules and are allowed to take the CO2 cylinder into the vehicle - without ventilation. This means that there is a danger to life if the cylinder leaks.

So do private individuals have to take the ADR with them when they go shopping? Hardly - but the manufacturer's instructions for chemical products must be observed, especially the small print on the back of the packaging contains important information. Open questions can be clarified with advice from the specialist dealer. Then nothing stands in the way of safe and legally compliant weekend shopping.