Pharmaceuticals — dangerous goods hide in the cold chain
A pharma warehouse ships more than medicines — ethanol and isopropanol for production, samples on dry ice, clinical waste on the return run. GDP auditors check the temperature, the road inspector checks ADR. We keep both worlds consistent.
Dry ice is almost free under ADR — yet 5.5.3 still demands ventilation and marking, and few people know it.
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 6.2UN 3373, BIOLOGICAL SUBSTANCE, CATEGORY B
Category B samples — trials, diagnostics
LQ 0
Class 9UN 1845, Carbon dioxide, solid
Dry ice — cold chain shipments
Class 3UN 1170, ETHANOL
Ethanol — production, disinfection, extraction
LQ 1 L / 5 L
Class 3UN 1219, ISOPROPANOL
Isopropanol — cleanrooms, surface disinfection
LQ 1 L
Class 6.2UN 3291, CLINICAL WASTE, UNSPECIFIED, N.O.S. or
Clinical waste — return logistics
LQ 0
Class 7UN 2915, RADIOACTIVE MATERIAL, TYPE A PACKAGE, non-special form, non fissile or fissile-excepted
Radiopharmaceuticals — nuclear medicine deliveries
LQ 0
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 ethanol travels three ways — litre bottles go as LQ with the diamond, a pallet of canisters may fit under 1.1.3.6, and an IBC for production 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.
Packer
Follows the packing and mixed-packing conditions and, when preparing packages for carriage, the marking and labelling requirements.
Loader
Checks packagings for damage before handing over, observes the mixed-loading prohibitions and the separation from foodstuffs.
Unloader
Compares the transport document with what actually arrived before unloading — returns and clinical waste flows included.
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
Ethanol shipped without the entry or an untrained packer — 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
GDP — Guidelines 2013/C 343/01
Good distribution practice for medicines. Chapter 9 is transport — temperature and security requirements ride on top of ADR duties, not instead of them.
Medicines code — Directive 2001/83/EC
The community code on medicinal products. Wholesale licences cover the whole supply chain — carriage is part of that chain, not an afterthought.
Radiation safety — Directive 2013/59/Euratom
Basic safety standards for ionising radiation. Radiopharmaceuticals travel as class 7 — nuclear medicine logistics answers to two regimes at once.
The industry in numbers
Is this about you?
If even one line matches your operation — it is worth a conversation.
- Samples leave by courier on dry ice, and nobody marks the box
- Ethanol and isopropanol arrive at production in canisters and IBCs
- Return runs collect clinical waste as if it were ordinary rubbish
- The GDP audit is passed, and nobody in the company closes the ADR questions
- Nobody in the company is formally appointed as the safety adviser
Our solutions
The cold chain is audited under GDP — ADR deserves the same discipline, a system instead of luck.
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 consultantMedicines are not dangerous goods — why does ADR concern us?
Finished medicines mostly are not, but the flows around them are — solvents for production, dry ice under samples, clinical waste on the way back. The regime is set by classification, not by the industry sign on the door.
The courier says dry ice is no problem — is that true?
On the road it is nearly exempt, but the duties of 5.5.3 remain — ventilation of the vehicle and marking of the package. The consignor answers for both, and the same parcel in the air network lives under far stricter rules.
We passed the GDP audit — is ADR covered by that?
No. GDP governs the quality of distribution, ADR governs the safety of carriage — different authorities, documents and training. Compliance in one does not transfer to the other.
Where do we start?
Send the list of everything that leaves your site — we prepare the cargo instruction with the transport document entry from €50 per document and show which regime each flow falls into. From there the subscription from €50 plus €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.