transport & storage
Transport Legislation Update
ARCA & ATaC NEWS
Wrapping of large items Many readers will be aware that for many years we have been concerned that the requirements of CAR 2012, regulations 16 & 24, and the ACOP (529 & 530) are not compatible with the ADR/CDG Regulations. ADR states that all UN2212 and UN2590 fibrous asbestos must be transported in UN-tested packaging while the CAR regulations and supporting ACOP prohibit the unnecessary breaking up of asbestos waste and requires large items, such as lengths of lagged pipe, to be wrapped twice in polythene instead. This could cause problems with enthusiastic enforcement officers, but more worryingly, could give insurers a reason to refuse to pay out in the event of a claim. We recently instigated a meeting with the HSE, the Dept. for Transport and ARCA to explain this issue and discuss possible solutions with all key stakeholders simultaneously. Our proposal that the DfT issue an Authorisation to permit the wrapping of large items was agreed. A copy is available at https://www. gov.uk/government/publications/carriage-ofdangerous-goods-authorisation-465 Although we requested that the Authorisation be valid for several years, the
DfT was only prepared to grant it until 31st January 2017, while ARCA (with our guidance) attempts to source suitable UN-tested packaging for items too large for currently available packaging.
What do you have to do differently now? Not much, continue to wrap large items of fibrous waste twice and secure with tape as described in the Authorisation, then fix a UN bag on the package. However, you must now carry a copy of the Authorisation on your vehicle. Please note that this Authorisation can only be used by HSE licensed asbestos removal contractors and waste carriers, registered with the Environment Agency, Scottish Environment Protection Agency or National Resources Wales, who subsequently transport waste packaged in this way, to transfer station or landfill.