If your company works with chemicals, fuels, gases, paints, or any other goods classified as hazardous, you’ve probably heard of the Dangerous Goods Safety Adviser. In this article, we explain what a Dangerous Goods Safety Adviser is, what they do, which companies are required to appoint one, and when the quantity-based exemption may apply.
What is a Dangerous Goods Safety Adviser?
The Dangerous Goods Safety Adviser is the person who helps the company prevent risks to people, property, and the environment during the transport of dangerous goods and in related operations. This role is regulated in section 1.8.3 of the ADR and, in Spain, in Chapter V of Royal Decree 97/2014.
Its role is to investigate all possible means and promote all necessary actions to ensure that the company complies with regulations and operates under optimal safety conditions, always under the responsibility of the company’s manager (ADR 1.8.3.3).
Which companies are required to have a Dangerous Goods Safety Adviser?
According to ADR 1.8.3.1, any company whose activities include the following must appoint one or more Dangerous Goods Safety Advisers:
- the shipment of hazardous materials by road,
- their transport,
- or related operations such as packaging, loading, filling, or unloading.
You don’t have to be a transportation company. A manufacturer that ships its products to customers, a warehouse that loads trucks, or a company that receives and unloads tanker trucks is also affected.
What Does the Dangerous Goods Safety Adviser Do?
ADR 1.8.3.3 lists its functions, tailored to each company’s operations. These include:
- Verify compliance with the regulations governing the transport of hazardous materials.
- Advise the company on these operations.
- Prepare an annual report on the company’s activities involving hazardous materials.
- Review the procedures for identifying goods, inspecting materials, and loading, unloading, packing, and filling.
- Ensure that staff receive training and that records of that training are maintained.
- Verify that vehicles are carrying the required documents and safety equipment.
- Review emergency procedures and analyze accidents, incidents, or serious violations to prevent them from recurring.
- Verify that a protection plan is in place when the company needs it (1.10.3.2).
In addition, if an accident occurs during transport or during loading, unloading, packaging, or filling operations, the safety adviser prepares an accident report for company management (ADR 1.8.3.6 and Article 29 of Royal Decree 97/2014).
The Annual Report
Each year, the safety adviser prepares a report on the company’s activities involving hazardous materials. The company must submit this report, during the first quarter of the following year, to the competent transportation authority of the autonomous community where it has its tax domicile, and retain a copy for five years (Article 28 of Royal Decree 97/2014). Its content is regulated by Order FOM/606/2018.
Who can be a safety adviser?
This may be the owner or director of the company, an employee designated by the company, or an external individual associated with the company through any form of collaboration (Article 25 of Royal Decree 97/2014). In all cases, this person must hold a valid professional training certificate for road transport (ADR 1.8.3.7), which is obtained through an examination and is valid for five years, renewable upon passing a proficiency test (ADR 1.8.3.16.1).
Before the safety adviser begins his or her duties, the company must notify the autonomous community of the appointment, specifying the facilities where dangerous goods are handled and the areas for which the adviser is designated: packaging, loading, unloading, and transportation (Article 28 of Royal Decree 97/2014).
The Quantity-Based Exemption: 1.1.3.6
Not all companies that handle dangerous goods need a safety adviser. Royal Decree 97/2014 (Article 24) excludes activities that qualify for an exemption under the conditions and quantities specified in the ADR. The ADR (1.8.3.2) lists the quantities that, for each transport unit, do not exceed the thresholds specified in 1.1.3.6, 1.7.1.4, and Chapters 3.3, 3.4 (limited quantities), and 3.5 (excepted quantities).
The most common one is 1.1.3.6. Each type of cargo is assigned a transport category (column 15 of Table A of the ADR), and for each category there is a maximum quantity per transport unit:
| Transport category | Maximum quantity per transport unit |
|---|---|
| 0 | 0 |
| 1 | 20 |
| 2 | 333 |
| 3 | 1,000 |
| 4 | Unlimited |
The quantity is measured in kilograms (net mass) for solids and liquefied gases, and in liters for liquids; for compressed gases, it is measured by the container’s water capacity.
If goods of different categories are being transported in the same vehicle, the quantity of Category 1 goods is multiplied by 50, that of Category 2 goods by 3, and that of Category 3 goods by 1, and the total must not exceed 1,000 (1.1.3.6.4).
For example, 200 liters of a Category 2 product and 300 kilograms of a Category 3 product: 200 × 3 + 300 = 900. It does not exceed 1,000, so that shipment is eligible for the exemption.
Two important points to note:
- This applies only to transport in packages. 1.1.3.6 does not apply to tanks or bulk shipments, even if the quantity is small.
- It is calculated per transport unit. If your company makes shipments that sometimes exceed the threshold, the exemption does not apply to those shipments.
That is why it is important to review the company’s actual operations: what goods it handles, how they are transported (packages, tankers, bulk), and what quantities are loaded onto or unloaded from each vehicle.
Calculate your specific case using our 1.1.3.6 calculator
Do you need a Dangerous Goods Safety Adviser?
At ADR Area, we’ve been serving as external Dangerous Goods Safety Advisers since 2015. We review your operations, provide a no-obligation assessment of whether you’re required to have one, and—if so—we’ll handle the role: appointment, annual report, staff training, and site visits.
