Dangerous Goods Note: What the Driver Must Be Handed

Ask a carrier for \u201cthe DGN\u201d and you may get either of two documents, because the term is applied to both the multimodal export declaration and the road transport document. They are not interchangeable, and the one the driver legally needs is decided by ADR rather than by the freight forwarder's template.

What is a dangerous goods note, and is it the same as an ADR transport document?

No, and the difference decides what you hand the driver. A Dangerous Goods Note is the multimodal export document used where the journey includes a sea leg: it carries the shipper's declaration and, for a container, the packing certificate. On a road movement within or across Europe, the governing document is the transport document required by ADR 5.4.1.

A sender shipping a container of paint through a port needs the first. A sender putting the same paint on a van to Manchester needs the second. A sender doing both on one consignment needs both, and the road document has to be right even when the ocean paperwork is already done.

In everyday use "DGN" gets applied to either, which is why asking a carrier for "the DGN" produces inconsistent answers. The reliable question is: what does ADR 5.4.1 require for this load, and separately, does a sea leg bring a multimodal declaration into play?

What must the ADR transport document show?

Ten particulars, and ADR 5.4.1.1.1 prescribes the order they appear in — the sequence is not a formatting preference.

Extra information attaches to some classes. Class 1 explosives and class 7 radioactives have their own requirements, as do gases, flammable solids, organic peroxides and infectious substances; for gas mixtures the composition has to be given. Fireworks under UN 0333 to UN 0337 need the classification assigned by the relevant competent authority stated on the document. See ADR for how the classes work and UN numbers for the codes themselves.

Special rules also cover wastes, salvage packagings, empty uncleaned packagings, date-expired IBCs, multi-compartment tanks, elevated-temperature substances and substances stabilised by temperature control. Empty uncleaned packaging is the one that catches people: it is not cleanly exempt, and ADR 5.4.1.1.6 still imposes documentary requirements on it.

Does everything have to be on one document?

No — and that is deliberate. ADR does not require all the information to sit on a single document, because a vehicle collecting from several consignors could not comply if it did.

A multi-drop load therefore legitimately travels with several transport documents, one per consignor. What matters is that the set covers everything on board, and that the driver can produce it. Under the CDG Regulations the carrier commits an offence by travelling with non-compliant documentation even though providing it is the consignor's duty, so in practice the driver is the last line of defence.

That has a commercial consequence worth naming. A properly trained driver will recognise a non-compliant document and may be under pressure to accept it anyway. If your paperwork is routinely queried at collection, the problem is upstream of the driver.

What language does the document have to be in?

The language of the forwarding country, plus English, French or German if one of those is not already used. For a GB consignor shipping within the UK, English satisfies both limbs at once.

On an international movement the document may legitimately arrive in a language your driver does not read, which is exactly why ADR 5.4.1.1.1 prescribes the order of the particulars. A driver who knows that the UN number comes first and the tunnel code last can verify a Polish or Italian document without reading the prose.

Instructions in writing — the emergency information card — are a separate requirement and not part of the transport document at all. They travel with the crew rather than with the consignment, which is a distinction worth keeping straight when auditing a vehicle.

When can you move dangerous goods without carrying the document?

On a GB domestic journey below the small-load threshold, the requirement to carry documentation is disapplied — except for explosives and radioactives. But the consignor's duty to furnish the carrier with it still applies.

That second sentence is the one senders miss. The relief is about what has to be in the cab, not about whether the paperwork has to exist. A consignor who provides nothing because "we are under the threshold" has not met its obligation, and the carrier is left unable to demonstrate what it is carrying if anything goes wrong.

The threshold itself is set by transport category, not packing group, in column 15 of Table A. Transport category 2 is 333 kg or litres; category 3 is 1000 litres. Packages meeting the limited quantities criteria are not counted towards it — see limited vs excepted quantities for how the three reliefs interact.

What goes on the vehicle rather than on the paperwork?

Marking and placarding are not synonyms even though they are used as such. Vehicles carrying packages take a plain orange plate front and rear; only class 1 and class 7 packages additionally require hazard diamonds on both sides and the rear. Orange plates must be removed when no dangerous goods are on board, and a plated empty vehicle is itself a defect.

What about instructions in writing, and the fire extinguisher?

Instructions in writing are the emergency information the crew carries, and they are a separate requirement from the transport document. They are not interchangeable: a vehicle can hold a perfect transport document and still be non-compliant because the written instructions are absent or in the wrong language.

Below the small-load threshold the surviving obligations are short but real: general driver training under ADR 1.3.2 with a record kept under ADR 1.3.3, one 2 kg dry powder fire extinguisher or equivalent under ADR 8.1.4.2, and proper stowage under ADR 7.5.7. What is not exempted is still required, which is the sentence HSE's own guidance uses and the one most often overlooked.

Above the threshold the full crew and vehicle requirements apply, including the ADR driver qualification. That step change is why the transport category of a load, rather than its weight in isolation, drives the cost of moving it.

Who is responsible when the document is wrong?

Potentially everyone in the chain. ADR assigns obligations separately to the packer, filler, loader, consignor, carrier and unloader, and the CDG Regulations make all participants responsible. Where enforcement has to pick, the test applied is who was best placed to ensure compliance with the provision in question.

In practice that means a consignor cannot discharge its duty by blaming the carrier's driver, and a carrier cannot discharge its duty by blaming the consignor's paperwork. Both are exposed, which is why the sensible arrangement is to agree the document format once rather than per load.

Unloader obligations were added to ADR in 2011 and are the ones least often designed into a process, because the receiving site frequently has no dangerous goods function at all. If your consignments are delivered into a warehouse that has never been told it has duties under ADR 1.4.3.7, that gap belongs to you rather than to your carrier.

Roadside enforcement of dangerous goods carriage in GB sits with DVSA. HSE is a competent authority for the CDG Regulations and publishes the guidance this page is drawn from, but it does not license or accredit hauliers — there is no such thing as an accreditation from it to carry dangerous goods, so treat any offer of one as a warning sign about the rest of the proposal.

What does T&C Logistics need from you before a hazardous collection?

The transport document, complete, before the vehicle arrives — not drafted at the loading bay. We hold ADR competence across classes 2, 3, 4, 5, 6, 8 and 9. We do not carry class 1 explosives and we do not carry class 7 radioactives, so those two are outside what we can quote on at all.

If the load is below the small-load threshold we would still rather have the document than rely on the relief, because it is the only record of what is on the vehicle. Our hazardous goods page sets out the classes and handling, and individual items are covered on aerosols, paint and solvents and gas cylinders.

Where the waste stream is hazardous as well as the transport, both regimes apply at once and you will also need a hazardous waste consignment note. Send us the UN numbers and quantities and we will tell you which documents the job needs before anything is booked.