Transport of Dangerous Goods

• Queen Mary University of London (Queen Mary) sends various hazardous materials by road in the UK, such as laboratory chemicals, biological samples, clinical waste, and radioactive materials. To meet our legal responsibilities under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009), we use a clear and compliant process for each shipment

This webpage summarises what staff need to know and it complements QMHSD_HS_PCY033 CDG Policy.

The Consignment Journey – Carriage of Dangerous Goods.pdf [PDF 232KB]

• Health and Safety at Work, etc Act 1974.
• The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 ("CDG 2009").
• ADR stands for the European Agreement concerning the International Carriage of Dangerous Goods by Road (French: Accord européen relatif au transport international des marchandises Dangereuses par Route).

ADR Classes of Dangerous Goods: There are nine classes, some with sub-divisions, as follows.

Some dangerous goods can also be classified as High Consequence Dangerous Goods (HCDG) and their security is enforced by the Department for Transport (DfT). These are shown in the table below.

• Hazardous laboratory waste collections
• Biological, clinical and Genetically Modified Organisms (GMO) sample transfers between London campuses and to external Institutions in Great Britain
• Radioactive waste and material transfers
• Estates‑related hazardous waste
• Any supply of hazardous substances to external organisations

The consignment is generally undertaken by Schools, Institutes, Estates and Facilities (EAF), our contractors or the Health and Safety Directorate for hazardous wastes. The requirements for this are summarised below:

• Identifying hazards of the materials to be consigned.
• Ensuring correct packaging and labelling. For hazardous waste, the waste carrier may offer advice and resources.
• Providing accurate documentation. This will usually be in the form of a spreadsheet; most Schools / Institutes have this information and associated processes well documented. If you are unsure, contact the Health and Safety Directorate.
• Checking the competence of carriers. In most cases, you will select the Queen Mary preferred suppliers for the carriage of a range of dangerous goods.
• Verifying driver identity and ADR qualifications. The driver should be carrying a specific licence for the carriage of dangerous goods.
• Supervise collection.
• Secure store after collection.
• Consignment notes to be retained for 3 years.

Dangerous goods exempt from ADR. These are materials transported for the purpose of a discrete activity, e.g. a printer carrying paint thinners associated with the job; a hazardous cleaning product transported for the purpose of cleaning equipment carried for a trade. NB This cannot be used to restock, or be used by, another facility, or for any purpose other than the trade or activity to be carried out on arrival at another site, and the return journey.

High consequence dangerous goods (HCDGs). There are additional checks and processes for these materials, including additional training and a security plan.

For all of these, you will be required to have appropriate emergency plans in place and provide the company carrying the dangerous goods with any relevant emergency information they might require, e.g. Queen Mary's authorised emergency contact.

Health and Safety Directorate (HSD)

• Policy: Drafts, consults on the document, and monitors the Policy.
• Monitoring: Monitor the implementation of the Policy.
• Organising and managing hazardous waste collections for laboratory areas.
• Selection and monitoring of the Dangerous Goods Safety Advisor (DGSA).
• Ensuring training of consigners with Schools, Institutes and Directorates.
• Collate, store (where applicable) and monitor non-EAF hazardous waste consignment notes.
• Supervise the collection of dangerous goods from HSD Stores.
• Ensure there is an appropriate security plan in place for hazardous substances; this is particularly important for the transport of HCDGs, including their pre-pick-up storage.

Estates and Facilities (EAF)

• Control the movement of EAF-generated hazardous wastes.
• Manage EAF Dangerous Goods and Hazardous Waste movements.
• Ensure an EAF Competent person is appointed.
• EAF Security are trained for their required duties.

Dangerous Goods Safety Advisor (DGSA)

• Advise on Queen Mary H&S Policy.
• Advise on any dangerous goods consignment.
• Advise on the competence of third-party transport providers.
• Conduct periodic reviews or audits.
• Advise on the Queen Mary Road/Rail Security Transport Plan.

Procurement

• Ensure all carriers engaged in transporting dangerous goods are preferred suppliers or otherwise approved by Queen Mary.
• For carriers who transport HCDGs, ensure they are aware of enhanced duties required by ADR.
• For carriers of hazardous waste, ensure they meet the requirements of the EA and environmental legislation.

Schools / Institutes, Estates and other Directorates that generate consignments that need to be transported and are classified as dangerous goods.

• Collate lists of consignment items for transport.
• Use either HSD stores or School/Institute stores and processes.

For Schools / Institutes with their own hazardous waste stores -

• Ensure there is an appropriate emergency and security plan in place

For staff handling HCDGs. –

• Waste carriers and other dangerous goods transport providers must be approved by applicable regulators, and internally by Queen Mary.
• DGSA advice procured for an HCDG consignment.
• Known driver and is verified by the consignor.
• Consignment documentation is received, checked, signed and retained.

• Ensure receiving areas are adequate to receive and store materials safely and securely.
• Ensure emergency procedures are in place to deal with spillages/releases and loss/theft.
• Provide appropriate training for those involved with the work.
• Providing appropriate personal protective equipment (PPE) during handling.
• This applies both to dangerous goods received from external suppliers or sources and for internal campus movements of dangerous goods.

Biological, clinical samples, pathogens, GMOs and wastes - consignor processes and transport modes– see policy, procedures and guidance at

• https://www.qmul.ac.uk/hsd/a-z/biological/
• https://www.qmul.ac.uk/hsd/a-z/genetically-modified-organisms/

Includes specific procedures for road, air and other modes consignments, and links or details of specific import and export permits when crossing national borders and other legal requirements.

Radioactive materials, sources and waste – policy, procedures and guidance at https://www.qmul.ac.uk/hsd/a-z/radiation-ionising/.

Includes specific procedures for road, air and other modes consignments, links and/or details of specific import and export permits when crossing national borders and other legal requirements (note – not all procedures are visible on webpage – contact the Radiation Protection Officer (RPO) if you do not have access).

Consignors of dangerous goods, including hazardous wastes, must be able to demonstrate competence in the areas outlined below, and their competence must be recorded on the CPD system. This can be supplemented by training on the knowledge required and the overall process at Queen Mary. Training will align with the relevant requirements of ADR.

• Can differentiate dangerous goods; hazardous wastes; HCDGs.
• Can describe the key steps of the process and describe their role in the process.
• Can identify the correct action if unexpected or prohibited items become apparent during the process.
• Can describe the action to be taken in the event of a minor incident and a major incident.
• Can describe the roles of the stakeholders in the Queen Mary Process.
• Can describe the security requirements related to the consignment of dangerous goods, and the additional requirements in place for HCDGs.
• For any staff and salaried postgraduate researchers involved in consigning HCDGs, they must be aware of the Road/Rail Transport Plan - a confidential document that deals specifically with HCDGs. Access to this restricted document will be provided to relevant staff or postgraduate researchers. For this group of staff and postgraduate researchers, two-yearly refresher training is generally required, and training records are retained for 6 years. Note - undergraduate and masters / taught postgraduate students should not be involved in HCDG consigning.

• Class 1 explosives (prohibited from being consigned by Queen Mary)
• Class 2 & 2.3 Toxic gases
• Class 4.1 desensitised explosives (prohibited from being consigned by Queen Mary)
• Class 6.1 Toxics (PG1 Highly Toxic).
• Class 6.2 Category A Infectious Substances.
• Class 7 Radioactive materials, sources and wastes (above specified thresholds).

• Emergencies: Contact Security on 020 7882 3333 (x3333 from a Queen Mary phone).
• Other incidents: Report via MySafety

Regulators

• Office for Nuclear Regulation (ONR) which regulates aspects including the transport of radioactive wastes. Home | Office for Nuclear Regulation
• Department for Transport’s (DfT) Land Transport National Security Division (LTNSD) security compliance programme relates to the consignment, security, and transport of High Consequence Dangerous Goods (HCDG). Department for Transport - GOV.UK
• Health and Safety Executive (HSE) enforce CDG. HSE: Information about health and safety at work
• The Environment Agency (EA) enforce the transport and disposal of hazardous wastes. Environment Agency - GOV.UK

Codes and standards for different modes of transports

• CDG – Legislation that dealt with the transport of dangerous goods in the UK, enforced largely by the Health and Safety Executive (HSE) and the Police.
• ADR - EU legislation, adapted from UN requirements and adopted into UK legislation via CDG.
• IATA - The International Air Transport Association (IATA) is an international set of standards on all aspects of commercial flights, including the carriage of dangerous goods.
• IMDG - The International Maritime Dangerous Goods (IMDG) Code. It is an international set of standards on many aspects of maritime activities, including the carriage of dangerous goods.

Queen Mary policies, procedures and guidance

Queen Mary CDG Consignor Policy: QMHSD_HS_PCY033 CDG Policy

Biological, clinical samples, pathogens, GMOs and wastes - consignor processes and transport modes– see policy, procedures and guidance at

• https://www.qmul.ac.uk/hsd/a-z/biological/
• https://www.qmul.ac.uk/hsd/a-z/genetically-modified-organisms/

Radioactive materials, sources and waste – policy, procedures and guidance at https://www.qmul.ac.uk/hsd/a-z/radiation-ionising/.

Terms relating to groups and classes of materials and items.

• Dangerous Goods - Term used for goods classified as dangerous to transport under ADR.
• Hazardous waste - Term used in environmental legislation for wastes, many of which can also be dangerous goods, for items and substances where their movement and disposal are strictly regulated.
• Hazardous substances - Term used for substances used, stored, and processed in the workplace, e.g. use of laboratory chemicals in research. Usually related to health hazards. E.g. carcinogen. This classification adopts the EU Model via UK legislation. This also includes biological samples and associated packaging, including agents to retain cold temperature, e.g. dry ice.
• Dangerous Substances - Term used for substances used, stored, and processed in the workplace, e.g. use of laboratory chemicals in research. Usually related to physical hazards, e.g. flammability.
• HCDG - High consequence dangerous goods, including explosives. Relates to security and the prevention of crimes such as terrorism.
• Consignment of Dangerous Goods - Identifying hazards, packaging, marking, labelling, and providing documentation ready for transport.

Specific roles

• Consignor of dangerous goods – Organisation (includes individuals employed by the organisation) that consigns dangerous goods for transport on UK roads (also applies to other modes of transport such as air).
• DGSA - Dangerous Goods Safety Advisers (DGSAs) help prevent the risks involved in the carriage of dangerous goods. This includes risks to people, property, and the environment. There are specific requirements related to competence to fulfil this role.

For advice and assistance at Queen Mary

• HSD Contacts contact the H&S Manager / Advisor for your Faculty / PS or the subject lead.
• All HSD staff can be contacted via the HSD Helpdesk.