On its way from where it is produced to its buyer, a hazardous material often passes through more than one mode of transport: by road from the facility to the airport or port, and from there by aircraft or ship. Each mode has its own rulebook. ADR applies on the road, the IMDG Code at sea, and in the air the ICAO Technical Instructions and the IATA regulations based on them. There are also separate regulations for rail (RID) and inland waterways (ADN).
This article explains how the three main regulations relate to one another and where they diverge. The concepts of number, class and packing group that make up a substance's transport identity were explained in the article on UN 3462.
The common source: the UN Model Regulations
The three regulations were not written independently of one another. The recommendations prepared by an expert sub-committee of the United Nations, known in the industry as the Orange Book because of the colour of its cover, form the common framework of the modal regulations. Hazard classes, UN numbers, packing groups, packaging test criteria and label designs all come from this source. The modal regulations adopt this framework as it is and extend it with additional rules suited to the conditions of their own transport environment.
This common foundation makes things much easier in practice. A substance's class and packing group are the same by road, sea and air; what changes are the quantity limits, document format and marking details attached to that identity. The rules are updated at regular intervals: ADR and the IMDG Code are published in a new edition every two years, and the air transport rules every year. That is why it is important to base shipment preparation on the edition in force.
At the heart of all three regulations is a dangerous goods list sorted by UN number. Each entry in the list sets out, side by side, the proper shipping name, class, packing group, special provisions, packing instruction and quantity limits. Preparation usually begins by reading this entry in the relevant regulation; the entry for the same number may carry different columns in the three books.
The three regulations side by side
| Topic | ADR | IMDG Code | ICAO / IATA |
|---|---|---|---|
| Mode | Road | Sea | Air |
| Framework | Agreement under the UN Economic Commission for Europe | International Maritime Organization (IMO), SOLAS Convention | ICAO Technical Instructions; IATA regulations as industry practice |
| Key document | Transport document, instructions in writing for the driver | Dangerous goods declaration, container packing certificate | Shipper's Declaration for Dangerous Goods |
| Specific topics | Vehicle marking, driver training, tunnel restrictions | Segregation, stowage, emergency response schedules, marine pollutants | Passenger vs. cargo aircraft, state and operator variations |
ADR: road
ADR is the international agreement governing the carriage of dangerous goods by road between its contracting parties; Türkiye is one of them, and the rules are applied through national legislation. The agreement covers not only the packaging but also the vehicle and the people involved. This includes the orange plates on the vehicle, the equipment that must be carried on board, the driver's training certificate and the instructions in writing that describe the steps to take in an accident. Many companies that consign or carry dangerous goods are also required to appoint a safety adviser; in Türkiye this function is known as dangerous goods safety advisory.
IMDG Code: sea
At sea, dangerous cargo travels for weeks alongside other cargo on the same ship, often in the same container. For this reason, the IMDG Code focuses on keeping apart substances that could react with each other and on determining where the cargo is stowed on board. For each substance, the Code gives emergency response schedules for fire and spillage as short codes; a code beginning with F refers to the fire schedule, and one beginning with S to the spillage schedule. The regulation also states separately whether the substance is considered a marine pollutant.
ICAO and IATA: air
In air transport, the binding text is the Technical Instructions of the International Civil Aviation Organization. The IATA regulations are based on these instructions and, because they also include airlines' additional requirements, are the manual consulted in practice. Since pressure and temperature change during flight, packaging must also withstand pressure differentials. Quantity limits are given separately for passenger aircraft and cargo-only aircraft; some substances may be carried only on cargo aircraft, and their packages are labelled accordingly. The restrictions of individual states and operating airlines are also checked separately.
Preparing a multimodal shipment
When a consignment falls under more than one regulation during its journey, the packaging and documents are prepared to meet the rules of every stage. In practice, this means adopting the strictest requirement from the outset. The following questions are answered during preparation:
- Which values does the transport section of the current safety data sheet give for the classification?
- Which modes will the consignment pass through, and what is the quantity limit in each?
- Does the chosen packaging type meet the performance criteria of the strictest mode?
- Do the labels and marks meet the requirements of each mode?
- Is the declaration complete and in the format required by the carrier?
- Are the training records of the people packing the goods and preparing the documents up to date?
- Does the carrier require prior approval or additional checks for acceptance?
For consignments that use dry ice as a refrigerant, the dry ice itself is also subject to the transport rules and, particularly in air transport, is declared as a separate entry. A shipment planned with a cold chain may therefore carry two separate dangerous goods entries in the same package.
Transport information for our product
In the safety data sheet of our powder product, the transport classification is given as UN 3462, Class 6.1, packing group I; the emergency response codes for sea transport are F-A and S-A, and the product is not a marine pollutant. How these values are reflected on the label is covered in the article on GHS06, and the rest of the shipping file in the article on the customs and shipping file.
Because transport rules are updated frequently and may differ between carriers, this article offers a general framework; each shipment is planned separately on the basis of the regulations in force and current documents. Details of our documents are available on the documents page.
