Additional Guidance on ADR 2025 Regulations for Asbestos Waste

Download: ADR 2025 and the Carriage of UN 2212 and UN 2590

In response to questions raised by the industry following the initial update on the ADR 2025 regulations, the Department for Transport (DfT) has issued further guidance to clarify specific requirements regarding the transport of asbestos waste under UN 2212 (Asbestos Amphibole) and UN 2590 (Asbestos Chrysotile). The additional guidance provides greater clarity on packaging, transportation, and documentation requirements as the industry prepares for these significant changes, effective from 1st January 2025.

Key Takeaways from the Additional Guidance:

Special Provision 678 Clarifications

• The guidance reinforces the importance of ensuring asbestos waste is transported directly from its point of generation to the final disposal facility. No intermediate handling, unloading, or transferring of the container-bags is permitted unless stored without movement.
• The categories of waste subject to these provisions include materials from damaged structures, roadworks waste, and asbestos-contaminated soil. These categories must strictly adhere to packaging and transport regulations to avoid the release of asbestos fibres.

Container-Bag Requirements

• The additional guidance further explains the specifications of container-bags used to transport asbestos-contaminated waste. These bags are not required to be UN-approved but must meet the technical requirements outlined:

1. An inner dust-tight layer made of polyethylene or polypropylene.
2. A robust outer layer, also polypropylene, fitted with a zipper system to prevent the release of asbestos fibres.
3. For larger contaminated materials, double-bagging is necessary to provide additional protection.

• Importantly, the guidance clarifies that the container-bags are single-use only, adding emphasis on mechanical loading for safer handling.

Transport Conditions

• Asbestos-contaminated waste must be transported in rigid containers with high enough walls to fully contain the bags. Additionally, the compartments should be free of sharp edges to avoid tearing the container-bags during loading or unloading.
• The outer surface of the bags must be decontaminated after filling to prevent any asbestos fibre contamination during handling or unloading.

Documentation and Compliance

• The guidance reiterates the importance of proper documentation when transporting asbestos waste under Special Provision 678. Transporters must ensure their paperwork includes the statement “Carriage under special provision 678” and provide:

1. A technical data sheet from the container-bag manufacturer.
2. A copy of the unloading procedure, especially if bulk containers are being used.

• This additional paperwork ensures compliance and transparency during transport and facilitates safer handling of asbestos waste.

What Does This Mean for the Industry?

The additional guidance highlights the complexity and seriousness of the upcoming changes. It stresses the importance of preparing for January 2025 to ensure full compliance with the regulations. These changes affect not only the physical transport of asbestos waste but also the documentation and technical requirements for packaging.

It’s crucial that all companies involved in asbestos waste handling review these updated guidelines to avoid non-compliance and potential penalties. The clarification around packaging, especially the single-use nature of container-bags, means organisations need to re-evaluate their waste management processes and ensure they are using the correct materials for safe transport.

Next Steps

If you have any further questions about the guidance or need clarification, please don’t hesitate to contact us. We are also in the process of organising a webinar to explore these changes in more detail. While the Department for Transport is unable to facilitate this session, we are working with the British Association of Dangerous Goods Professionals (BADGP) to provide expertise for the webinar. Stay tuned for further updates.

For those interested, you can view the full Department for Transport guidance document here.