Guidance

ADR instructions in writing and use of electronic documentation

Updated 23 November 2023

Providing ADR instructions in writing

The carrier has to provide ADR instructions in writing (ADR 5.4.3) to the vehicle crew. This means that the full 4-page model, regardless of how many classes you carry, must be provided as it is a single entity.

You may add an additional page if you wish to do so, but it must not be inserted into the body of the 4-page model. Any further information that you wish to provide to the vehicle crew must be provided on a separate page.

If the vehicle crew is non-English speaking, you must provide the instructions in writing in a language they will understand.

Download versions in different languages from the UNECE website.

Amending ADR instructions in writing

You cannot amend the instructions in writing, as the statements have been agreed and translated into other languages.

You cannot replace the dashes with numbers as this could imply there is a mandatory sequence of actions. Some of these actions may not be required on every occasion.

You can add your company or trade association logo and it will be accepted in Great Britain as long as the logo does not obscure the text or its layout. However, we do not know how other countries’ enforcement authorities will treat such changes. If you operate internationally, we suggest you do not add logos.

Reproducing ADR instructions in writing

In Great Britain, you do not have to reproduce the instructions on 4 pieces of paper. The instructions can either be printed on 4 pieces of paper or on 2 pieces front and back.

The ADR regulations state that the instructions in writing must be able to be read and understood by the vehicle crew, but it does not prescribe the paper size to use. British enforcement authorities as a minimum will accept all 4 pages printed on 2 sides of A4, front and back, as long as the required text and symbols are legible.

Displaying ADR instructions in writing

If you are carrying dangerous goods, you must carry instructions in writing in the cab, where they must be readily available.

Before each transport operation, the carrier should ensure all vehicle crew understand the instructions in writing. We suggest this should include checking all vehicle crew know where they are kept.

If you are not carrying dangerous goods, we suggest you put the instructions in writing in the glove box or out of sight.

If you take instructions in writing out of the vehicle, remember to give them back to the vehicle crew the next time the vehicle is used to carry dangerous goods.

Use of electronic documentation

The use of electronic devices to display ADR documentation such as the transport document or instructions in writing is permitted.

ADR 5.4.0.2 states that the use of electronic documentation as an aid to, or instead of, paper documentation is permitted, as long as the information within the electronic documentation is that which is required by Chapter 5.4.

Additionally, ADR 5.4.0.3 states that when using electronic documentation, the consignor must be able to give the information to the carrier as a paper document should it be required.

Other ADR member states may interpret ADR differently, so for international journeys, we advise you to use the paper version, at least for the instructions in writing.

Access to electronic documentation

ADR transport documents must always be easily available to roadside inspectors and emergency services. This is so they can quickly identify the type of dangerous goods being carried in the vehicle.

If you are carrying the transport document on an electronic device, you should make sure the device is fully charged. Drivers should aim to be able to show the document within 2 minutes of being asked for it.

In the event of an accident, emergency services may need to access the electronic device without the driver. Therefore, the device must not be locked with a personal identity number (PIN), or any other locking system.

You may also want to carry a paper copy of the ADR transport document as a backup.

If the electronic documentation is not retrievable due to network coverage issues or the electronic device is unreliable, then this would not be compliant with the requirements of ADR. You could also download the electronic documentation to the device before starting your journey.

Summary of process

1. The consignor provides electronic documentation to the carrier in the sequence required by ADR Chapter 5.4 and is ready to provide a copy in paper format should it be required.

2. The carrier may choose to transfer electronic documentation to the vehicle crew’s electronic device. If the electronic device or network coverage is unreliable, it is suggested the carrier provide the information to the vehicle crew in a paper format.

3. The vehicle crew provides electronic documentation at roadside checks and to emergency services in the event of an accident.

4. If the driver is incapacitated and the documentation is only available via an electronic device, the device must not be PIN-locked.

Equipment

The list of equipment states that a drain seal is required if carrying goods with danger labels 3, 4.1, 4.3, 8 or 9. ADR does not specify what a drain seal is. We suggest the following options:

• strong plastic sheeting, held in place by sand, sandbags or by using a shovel to put soil or similar over the sheet
• specially made drain seals, which are available commercially

British enforcement authorities will accept a ‘sausage’ of absorbent material that is sufficient in size to place around a drain opening to absorb/divert any spillage. Commercially available ‘spill kits’ often include such items.

The list of equipment states that a collecting container is required if carrying goods with danger labels 3, 4.1, 4.3, 8 or 9. The container does not need to be UN-approved. The container can range from a bag to a bucket, so long as it is capable of dealing with a spillage. The container should not soften or be damaged by the substance to be carried in it.

The equipment required for certain classes states that a shovel is required for goods with danger labels 3, 4.1, 4.3, 8 or 9. ADR does not specify any requirements for a shovel, but it should ideally be made of plastic and have upturned sides.

The additional guidance table shows that divisions 6.1 and 6.2 have the hazard characteristics ‘risk to the aquatic environment and the sewerage system’.

There is no requirement to carry a drain seal and bucket for divisions 6.1 and 6.2 substances, as well as to prevent leaking substances from getting into the aquatic environment or sewerage system.

While the list of equipment to be carried on page 4 of the instructions in writing is mandatory, pages 2 and 3 are guidance. This guidance serves as a reminder to the driver. It is not intended to correlate with the list of equipment to be carried.

Additional equipment

You may provide additional equipment on your vehicles if you wish, but you should be aware that drivers are not expected to act as quasi-emergency responders and that if extra equipment is provided, drivers should be fully aware of what you expect them to do with it and be provided with full training in its use.

If the training that the driver has received means that, where safe and appropriate to do so, they are able to prevent leakages from getting into the aquatic environment or sewerage system and contain leaks of substances in division 6.1 and 6.2 by using a collecting container and or a drain seal that is laudable.

You should be aware, however, of potential new hazards that may arise. For example, there might be more danger in a driver trying to deal with the leak of a toxic substance or some substances may react dangerously with the material used for the container.

There is no rule about where on the vehicle equipment is kept. You should keep the bucket and other equipment wherever it is convenient and easy for the driver to access. Pre-journey checks should ensure that the right equipment is on the vehicle.

Transporting dangerous goods by rail

This guidance only quotes references to ADR, but the same guidance applies to carriage by rail.

Legal information

This information is based upon the interpretation of the GB competent authority. This guidance note should not be taken as a complete or definitive statement of the law. It is not intended as a substitute for detailed legal or other professional advice based on specific circumstances. The Department for Transport accepts no liability for any loss or damage caused by reliance on the contents of this guidance note. 

In international carriage, competent authorities of other states may have a different interpretation of dangerous goods regulations.