Manufacturing — dangerous goods behind every weld
A factory rarely calls itself a dangerous goods operator. Yet cylinders for the welding bays, acids for the plating line, caustic for equipment washing and solvent waste leaving for disposal are all ADR movements — every delivery and every return run with uncleaned packagings is part of the operation.
Not flammable does not mean not dangerous — argon, nitrogen and CO₂ are Class 2.2, pressure and asphyxiation, and an uncleaned empty cylinder stays dangerous goods on the way back.
This is what you already ship
Typical dangerous goods of the industry — with the real Table A entries. Tap any card to open the full UN page in our reference.
Class 2UN 1001, ACETYLENE, DISSOLVED
Dissolved acetylene — gas welding and cutting
LQ 0
Class 2UN 1072, OXYGEN, COMPRESSED
Compressed oxygen — metal cutting, welding bays
LQ 0
Class 2UN 1006, ARGON, COMPRESSED
Compressed argon — shielding gas for MIG and TIG welding
LQ 120 ml
Class 8UN 1830, SULPHURIC ACID with more than 51 % acid
Sulphuric acid — pickling baths, electroplating
LQ 1 L
Class 8UN 1824, SODIUM HYDROXIDE SOLUTION
Caustic soda solution — degreasing, equipment washing
LQ 1 L / 5 L
Class 3UN 1993, FLAMMABLE LIQUID, N.O.S.
Flammable liquids — washing solvents and their waste
LQ 0 / 1 L / 5 L
Three ways your goods can travel
The same product can go as limited quantities, under the 1.1.3.6 partial exemption or in full ADR — the classification and the packaging decide.
Limited quantities (LQ)
Small inner packagings within the column 7a limit, up to 30 kg gross — the goods travel with the LQ diamond, free of most other ADR provisions (Chapter 3.4).
Partial exemption (1.1.3.6)
Below the transport category threshold per transport unit — no orange plates, no written instructions, no ADR driver certificate (the list in 1.1.3.6.2).
Full ADR
Above the thresholds the goods travel under the full set of rules — transport document, plates and labels, equipment, trained crew and every participant duty.
The same washing solvent travels three ways — one-litre tins go as LQ with the diamond, a pallet of jerricans may fit under 1.1.3.6, and an IBC ships in full ADR with an ADR driver.
Who answers for what
ADR splits the duties among the participants of the carriage. These are the roles your company typically holds — with the exact ADR paragraphs.
Consignor
Hands over only consignments that conform to ADR — classified, authorized, in approved packagings, with the transport documents furnished to the carrier.
Filler
Fills only authorized tanks in sound condition, observes the filling degree, checks the closures for leaks and the marking of the tank.
Packer
Follows the packing and mixed-packing conditions and, when preparing packages for carriage, the marking and labelling requirements.
Unloader
Compares the transport document with what actually arrived before unloading.
For each of these roles the company needs an appointed safety adviser (1.8.3.1) — ours works on subscription.
About the DGSAWhat a mistake costs
A gas cylinder handed over without papers or an unfilled entry — the sums below are what national law charges for it.
Sanctions are national — checks are European
Every ADR country sets its own fines for dangerous goods violations. Roadside checks follow one European standard — Directive (EU) 2022/1999 with a common list of infringements by risk category. Open your country to see the authorities and the exact amounts.
Find your countryAnd beyond the fines
- A vehicle stopped at a roadside check — with your customer waiting for the delivery
- An incident with an untrained crew — and an insurer reading the file closely
- Violations on record — and inspections coming back more often
What the law expects from you
ADR duties come first — and your industry carries its own EU rules on top.
Under ADR
- Classify every product before it is handed over for carriage
- Train everyone who touches dangerous goods (Chapter 1.3)
- Appoint a safety adviser — carriers, consignors, loaders, packers alike
- Mark, document and equip every consignment correctly
EU rules of the industry
REACH — Regulation (EC) 1907/2006
Safety data sheets for everything that enters the shop floor. Section 14 of the SDS carries the transport classification — the starting point of every inbound and outbound flow.
CLP — Regulation (EC) 1272/2008
Pictograms on the jerrican speak for the market, ADR classes speak for the road. Two systems for one product — and they do not match one to one.
Seveso III — Directive 2012/18/EU
Major accident prevention. A site with stocks above the thresholds lives under a second regime on top of ADR — storage and carriage are checked by different authorities.
The industry in numbers
Is this about you?
If even one line matches your operation — it is worth a conversation.
- Cylinders — acetylene, oxygen, argon — travel to your site and back on a regular loop
- Acids or caustic top up your line baths from jerricans or IBCs
- Solvent waste leaves the factory for disposal
- Uncleaned empty packagings sit on the ramp as if they were harmless
- Nobody in the company is formally appointed as the safety adviser
Our solutions
Production must not stop — the ADR side runs on subscription while your lines keep moving.
Cargo instruction with the transport document entry
Classification, the carriage regime and the ready transport document entry — for a specific cargo.
from €50 / document
A consultant on subscription
A certified safety adviser, the appointment notice and the platform — from €50 a month plus €10 per consignment.
ADRplus One
Train the team
Chapter 1.3 courses online, in your languages — at your own pace, with certificates.
Course is being updated
ADR compliance audit
A remote compliance audit with a report — where you stand and what to fix first.
€290
Questions from the industry
Have a different question?
Contact the consultantWe make steel structures, not chemicals — how does ADR concern us?
ADR looks at flows, not at your product. Cylinders, acids, caustic and solvent waste make the factory a participant in carriage — a consignor, loader or unloader with its own set of duties.
The gas supplier does the driving — are we out of the picture?
His run is his zone, yet loading and unloading on your site are yours. And when your own van carries a cylinder to an object or waste to disposal, the carrier is you.
Empty cylinders and packagings — dangerous goods too?
Yes, until they are cleaned. An uncleaned cylinder or IBC with product residues travels under the same rules — the return logistics of packagings belongs to the same system as the deliveries.
Where do we start?
Send the list of gases, chemicals and waste — we prepare the cargo instruction with the transport document entry from €50 per document and show which flow falls into which regime. From there the subscription from €50 + €10 per transport covers the adviser, the platform and the training of your people.
Tell us how your goods move
Within one working day you get a clear answer — what applies to you, what does not, and what it costs to be in order.