ADR 2025: Key Updates for Asbestos Waste Transport

Download: Asbestos Waste - Amendments to ADR Regulations

The ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road) regulations governing the transport of asbestos waste are set to change, with new provisions coming into force from 1st January 2025. These changes are expected to impact procedures for businesses involved in the handling and transportation of asbestos waste and will require compliance with stricter safety and documentation standards.

Below is a detailed breakdown of the key changes.

Key Updates in ADR 2025 for Asbestos:

• Special Provisions (Part 3, Section 678):
  • Previous: This section dealt with the transport of asbestos waste, typically limited to specific conditions and the nature of containment.
  • Updated: Waste contaminated with free asbestos must only be transported directly between the site of generation and a final disposal facility, with no unloading or transferring of the container-bag permitted during intermediate storage. The regulation outlines specific categories of asbestos waste, including:
    • Solid waste from roadworks, such as asphalt milling contaminated with free asbestos;
    • Soil contaminated with free asbestos;
    • Objects, like furniture, contaminated with free asbestos from damaged structures;
    • Large materials from damaged structures that cannot be packed in accordance with the UN number 2212 or 2590. Waste under these provisions must not be mixed with other hazardous or non-hazardous waste, and each shipment must be considered a full load. This waste must be transported under strict conditions, ensuring hazardous emissions of asbestos fibres do not occur.
  • Impact: These provisions impose much stricter control over the transportation process for asbestos-contaminated waste. The specificity of waste types, combined with prohibitions on mixing and intermediate transfers, is likely to impact both operational logistics and cost for companies handling asbestos waste.

• Documentation (Part 5, Section 5.4.1.1.4):
  • Previous: There were general requirements for asbestos waste documentation, mainly focused on dangerous goods classification.
  • Updated: When transporting asbestos waste under Special Provision 678, transport documentation must now include the specific statement: “Carriage under special provision 678.” In addition, the following documentation must accompany the transport:
    • A technical data sheet from the manufacturer or distributor detailing the dimensions and maximum mass of the container-bag used for transportation.
    • A copy of the unloading procedure as per Special Provision CV38, if applicable. The inclusion of these detailed documents ensures transparency in waste handling and compliance with the stringent requirements for asbestos transport.
  • Impact: These documentation changes add another layer of administrative responsibility to ensure compliance with the updated regulations. Failure to include the correct documentation may result in penalties, delays, or the waste transport being halted altogether.

• Carriage, Loading, Unloading, and Handling (Part 7, Sections AP12 and CV38):
  
  • Previous: The focus was on general handling and securing of asbestos waste during transport.
  • Updated: Significant changes have been introduced regarding how asbestos waste must be packaged and handled during transport:
    • Asbestos-contaminated waste must be transported in "container-bags," which are required to have two liners—an inner liner made from dust-tight materials (e.g., polyethylene or polypropylene) to prevent the release of respirable asbestos fibres, and an outer layer with a zipper system to ensure the mechanical integrity of the bag during handling and transportation.
    • The container-bag must be loaded inside a bulk compartment with rigid metal walls. The walls must be high enough to completely contain the container-bag, and the container-bag must not be handled outside of this compartment once loaded.
    • For large asbestos-contaminated objects or construction waste that cannot be packed per the UN number 2212 or 2590, the container-bag must be placed inside a second bag of the same type. The total weight of asbestos waste in the container-bag cannot exceed 7 tonnes.
    • Special unloading procedures must be followed to avoid damage or tearing to the container-bag during unloading. This includes ensuring that the load compartment has no sharp edges and that the outer surfaces of the container-bags are decontaminated after filling.
  • Impact: These changes create stricter packaging and handling requirements aimed at minimising the risk of asbestos fibre release during transit. Businesses involved in transporting asbestos waste will need to invest in compliant container-bags and ensure that their processes meet these updated requirements. This may also impact cost, as more stringent inspections and specialised packaging will be needed.

Key Dates:

• Effective Date: These changes will come into force on 1st January 2025.
• Grace Period: There is a 6-month grace period, making 1st June 2025 the final deadline for full compliance.
• UN Advisory Date: The United Nations advisory for these regulations is expected in November 2024, so businesses may start seeing articles about this shortly.

Full List of Amendments:

The Inland Transport Committee’s Working Party on the Transport of Dangerous Goods has released the full list of amendments adopted at its 111th to 114th sessions. These amendments will come into force on 1st January 2025, following standard ADR update procedures.

HSE Response:

We have shared these updates with the Health and Safety Executive (HSE). However, they were unaware of the changes related to asbestos waste handling under ADR. They are currently reviewing the amendments, and we will provide further updates as more information becomes available.

Next Steps:

At present, there is no further information available, but we will continue to monitor developments and update this article as more details emerge.