CARRIAGE OF FIREWORKS UNDER ADR
Transporting fireworks under ADR
Firstly, we must be clear that fireworks are classified as explosives, which means that fall under Class 1 Dangerous Goods under ADR. Class 1 Dangerous Goods covers all explosives even down to sparklers. As such, fireworks are prohibited in almost all forms of transport, including shipping companies, ferries, nearly all airlines and it also includes the Channel Tunnel.
In the UK, transport of pyrotechnics or fireworks falls under ADR, and UK’s relevant legislation, the CDG Regulations (Carriage of Dangerous Goods and Use of Transportable Pressure Equipment) Note that ADR only applies when you are transporting fireworks commercially. Private individuals can carry up to 50kg of fireworks, anything over is above the threshold for personal use.
Regular rules & practices under ADR DO NOT apply to the transportation of fireworks – neither does the limited quantities rule apply and nor does the excepted quantities rule apply. Therefore, fireworks & pyrotechnics must be transported under as fully complying with ADR and regulated as such, or transported under the small load exemption.
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Small load exemptions under ADR
The small load limit of transportation under ADR for Class 1 Explosives – fireworks in this case – can vary according to which classification code the fireworks fall under. Our table below lists the Classes you may carry fireworks under, and the small load exemptions for each class.
Anything above the small load limits as stated below falls means your load is above the threshold and therefore will need to be transported as fully regulated, compliant loads under ADR.
|UN Number||Proper Shipping Name||ADR Dangerous Goods Class (Classification Code)||Transport Category||Small Load Limit|
If you’re transporting mixed loads of fireworks, where the transport category is different for each but still under the small load exemptions, you must calculate a “Mixed Load Threshold”. This is because the total of units carried cannot exceed 1,000 units. Please see our table below for reference.
|1||Quantity x 50||A|
|2||Quantity x 3||B|
|3||Quantity x 1||C|
|ABC (maximum of 1,000 units per vehicle)|
If you are transporting fireworks but with mixed transport categories, you must apply the chart above. if your load exceeds the 1,000 unit threshold, full ADR applies.
There are certain specifications and restrictions that apply even if your load falls under the small load exemptions. These are listed below:
- Restrictions in tunnels do not apply
- Only a 2kg Fire Extinguisher is required
- The driver and crew must not smoke, nor open packages
- Photo ID of the driver & crew is not necessary but a transport document is
- The driver must be trained appropriately but doesn’t need to have been given an ADR Vocational Training Certificate
- If you are carrying lighting apparatus, it must be non-sparking
- Supervision requirements may still apply – this does depend if the dangerous goods exceed the amount specified by the listed codes. Even if this is considered a small load, it is still possible.
- Part 9 requirements relating to vehicle construction do not apply
Carriage of fireworks under full ADR
If you are transporting fireworks which are in excess of the exempted quantities as specified above, your load will fall under full ADR and you will have various other requirements and needs. First and foremost, you must have an ADR trained driver for your vehicle, and the associated and necessary transport documentation, placards, labelling and equipment. You are also required to ensure supervision of the vehicle (under ADR 8.5) and a no smoking policy (under ADR 8.3.5) There are still limits of quantities that can be carried – this depends on the classification of the fireworks you’re carrying and the type of transport unit you use. These guidelines are outlined in ADR 220.127.116.11.
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M279 multilateral agreement
If you carry the carriage of UN 0335 and UN 0336 fireworks, the UK has signed an agreement concerning some exemptions.
The multilateral agreement includes an exemption from the provisions of 18.104.22.168 (a), 9.1.2, 22.214.171.124, 126.96.36.199.5, 9.3.3 (second subparagraph) and 188.8.131.52 (second subparagraph) of ADR for the carriage of UN 0335 and UN 0336 loads within proposed limits. On the whole, the carriage of fireworks in the UK is very seasonal and because of the fluctuation in demand, many in the fireworks industry use hired vehicles for transporting explosives. While the hired vehicles meet the technical and safety requirements of EX/II vehicles, the vehicles more often than not do not have a certificate of approval. this is required by section 9.1.3 of ADR. This is usually because the costs and practical difficulties of getting a certificate for the seasonal demand are unviable for the limited use only seasonally. The purpose of the multilateral agreement is to ensure the safe carriage of UN0335 and UN 0336 without compromising the safety standards as set out in ADR.
More specifically, the agreement M279 will only allow mixed loads of UN 0335 and UN 0336 of up to 2500 kg and loads of only UN 0336 up to 7500kg. As such, the transport document must contain the following wording: “Carriage agreed under the terms of ADR paragraph 1.5.1 (M279)” A copy of the Multilateral Agreement M279 must also be carried in the vehicle.
M322 multilateral agreement
The multilateral agreement M322 concerns the carriage of UN 0335 and UN 0336 fireworks. Fireworks UN 0335 and UN 0336 may also be transported in certain quantities, but without needing to meet the requirements of the following sections of ADR: 184.108.40.206 (a), 9.1.2, 220.127.116.11, 18.104.22.168.5, 9.3.3 (second subparagraph), and 22.214.171.124 (second subparagraph).
Drivers must turn off heaters that do not comply with paragraph 126.96.36.199.5 during transportation of the fireworks, when unloading, loading and when handling the class 1 dangerous goods.
The exemption only applies to the following quantities of the class 1 dangerous goods:
Mixed loads of UN 0335 and UN 0336, shall not exceed 2,500Kg.
Loads of only UN 0336, shall not exceed 7,500Kg
Where this does not apply, all other relevant requirements of ADR should be conformed to. The consigner should include the following statement in their transport documents: “Carriage agreed under the terms of ADR paragraph 1.5.1 (M322)” and a copy of the agreement provided must be carried onboard the vehicle.
The agreement is valid until the 19th of August 2024 in the UK unless revoked. Please note that this does not apply to carriage through the Channel Tunnel.
You can view the full Department for Transport Statement Here: Multilateral Agreement M322
Carriage of fireworks for private individuals
As stated earlier in the article, a person transporting fireworks may carry up to 50kg of fireworks as long as they are not being used for commercial use, and they must also have ensured that they have taken all reasonable expected steps to make sure that the way in which the goods are loaded, stowed, carried and unloaded are safe and do not create unnecessary risk or increase the risk significantly to any other personnel. This also includes ensuring that there is no unauthorised access to the class 1 explosive goods that are being carried.
Safety when transporting fireworks
We would like also to remind you of the safety aspects associated with transporting fireworks. If you follow ADR and the rules laid out by the regulations, carriage of class 1 dangerous goods can be carried out very safely and at minimal risk to all personnel concerned.
- Fireworks must remain in their original packaging. this should be optimised for carriage where possible. Fireworks shouldn’t be stored with other items where possible.
- Ensure your vehicle is dry and has ventilation so that any fireworks inside will stay dry. Wet fireworks can destroy a celebration!
- Much like any cargo you transport, fireworks should be packed properly and securely so that they are not left to slide around the van or able to fall from their loaded position.
- Make sure you check the regulations associated with the transportations. Read our blog above for an overview of what you can and can’t do when carrying fireworks.
- Ensure you get specialist advice, either from a DGSA or make sure you are aware of the regulations.
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