Transporting equipment with operating media overland in Europe used to be no problem in general. However, this is set to change as a result of the new legal regulations. In the future, certain machinery and equipment will be classified as dangerous goods.
When machines become dangerous goods
Will we soon see truck convoys driving around adorned with alarming red warning signs? It probably won’t be that dramatic. Nevertheless, a few things are going to change when it comes to transporting machinery. With effect from January 1, 2023, transporting machinery by land will have to be safer. As is often the case, when things need to be made safer, they also become more complicated.
The basis for this is the new version of the ADR, the Agreement concerning the International Carriage of Dangerous Goods by Road. Unlike the situation for sea and air transport, until now there has been a generous exception granted for European road transport: dangerous goods within machinery or equipment were exempted. However, this convenient exception will soon be removed, with stricter regulations applying to transport by land.
In the future, a declaration will be required for each machine as to whether its interior or its functional elements contain poisonous gases, flammable or corrosive operating supplies and is thus to be treated as dangerous goods. The machine can only set out on its journey once the sender has packaged it in accordance with the requirements on the hazard label.
Dangerous goods or not?
Initially this doesn’t sound particularly complicated, but the problem here is the unambiguous classification of items that contain dangerous goods. Determining which machinery and equipment are affected by the new special regulation – and must therefore be declared as dangerous goods – is not all that straightforward, as you probably suspected. The basic issue: what operating supplies are actually in the machine, and is there even a dangerous goods classification for them?
Defining, declaring, transporting
The good news: every operating supply has a safety data sheet. “The sheet includes information as to whether a dangerous goods classification applies to that operating supply,” explained Alfred Winklhofer in the dangerous goods fact sheets from the Swabian Chamber of Commerce and Industry (IHK). “In this case, the machine filled with this operating supply should also be classified as such, and should be assigned a UN number with corresponding packaging and carriage regulations.”
It is important to note that components such as the computer or control system must also be checked prior to shipping. These could include a lithium battery or a gas-filled cooling appliance.
The next step is to provide the correct declaration for the machine. The company who placed the order for transport is responsible for providing this. “The sender of the machinery containing dangerous goods is obligated to declare the machinery as dangerous goods,” noted Prof. Norbert Müller, publicly appointed and sworn expert for dangerous goods transport, in the sector magazine Produktion.
Explosions in the sorting center
If they fail to do this, they might find themselves in the same position as a particular wholesale butcher who shipped a box of aerosol cans, which abruptly exploded in the sorting center of a parcel delivery company, causing 1.4 million euros in damage. The sender placed the aerosol cans in the box loose and without protective caps, which is prohibited under the packaging regulations in the ADR. The spray nozzles bumped into each other in the box as it jerked along the sorting belt, and propellant escaped. As the cans continued to bump into each other in the box, tiny sparks were produced which ignited the gas. To what extent the wholesale butcher can be held responsible for the damage is up to the court to decide.
Playing it completely safe
As this example shows, the ADR now includes objects that were barely covered by previous dangerous goods legislation. Prof. Müller also points out that there is a risk that smaller companies in particular – including those in mechanical engineering – are not fully aware of this issue.
Comprehensive knowledge of the legal regulations is thus essential to ensuring the continued existence of affected businesses. Ideally, every company should have a dangerous goods officer, who regularly participates in training and information events in keeping with the ADR. This will enable them to keep up to date with the latest requirements for the carriage of dangerous goods, and play it completely safe.
Typical operating supplies that reclassify machines as dangerous goods
- Liquefied petroleum gas
- Fuel oil
- Lithium batteries
- Greenhouse gases
- Hydraulic oil
What to check before machinery is transported:
- What operating supplies are there in the machine?
- What information do the relevant departments have about this (e.g., project management, design, logistics, and dangerous goods officers)?
- What is the correct classification for the machine?
- Are the necessary transport documents present?
- Has the item to be shipped been packaged for carriage in compliance with the regulation?
- Have the hazard labels been attached to the item?