Shippers: Daily pickups or occasional collection? Traceability of information.

Traceability of Information Prior to a Daily Pickup or an Occasional Collection

The regulation for the transport of dangerous goods in France is governed by the decree of May 29, 2009, known as the 'TMD decree'. This text notably incorporates the International Agreement on the Carriage of Dangerous Goods by Road (ADR).

The ADR Regulation

The ADR regulation concerns all actors in the logistics and transport chain for dangerous goods:

• The shippers,
• The packers,
• The loaders / fillers,
• The carriers,
• The recipients,
• ...

The ADR regulation defines prescriptions concerning:

• the classification of goods,
• the manufacture and use of packaging,
• shipping, loading procedures,
• team training,
• vehicle approval,
• ...

The Responsibilities of the Shipper

In accordance with chapter 1.4 of the ADR regulation, the shipper must in particular:

• Ensure that the goods are classified and authorized for transport,
• Provide the carrier with traceable information and details required by the regulation,
• Use compliant and correctly labeled packaging and containers,
• ...

Traceability of Information Provided to the Carrier

"Hello? For tomorrow, I have 2 pallets to pick up" - The request to the carrier must be made in writing to ensure the traceability of information transmitted to the carrier. Therefore, phone requests are not acceptable.

The carrier must receive a written request that will allow them to plan and assign an ADR-trained driver with a suitable and equipped vehicle for your collection.

If the carrier does not have the necessary information, they cannot provide a satisfactory response to your needs.

If the carrier arrives for the collection with a driver and a non-compliant truck, you also risk being in violation when handing over the goods if you do not perform an appropriate ADR check.

Daily Pickup or Occasional Collection - What's the Difference?

Often, if it is not a daily pickup, the shipper makes a formal occasional collection request in writing, by email. Some carriers allow the shipping document to be filled out online. This saves time for the carrier whose routing management software will optimize trips based on data provided directly by the shippers.

When the carrier comes to your site every day for a pickup and takes what is ready, often, the shipper does not make a prior written request. They simply prepare the dangerous goods declaration which they give to the driver when they arrive. In some cases, pallets to be collected are left in lockups, ready to be picked up at night, for example.

As a Shipper, Can My Responsibility Be Engaged?

The shipper's responsibility can be engaged in several cases:

• Depending on the type and mass of dangerous goods in the vehicle, the shipment can benefit from the partial exemption of 1.1.3.6. The driver will not need to be ADR certified.
• The shipper must also ensure the proper placarding of the truck when it leaves the site, and the ADR equipment of the truck, based on the goods you handed over to the driver.

The ADR control checklist is therefore essential to trace the compliance of your shipment.

The list of ADR equipment varies depending on the transported goods. The absence of information transmission to the carrier could lead to inadequate vehicle equipment.

These points are the responsibility of the driver but also of the shipper's responsibility.

The shipping request must therefore mention all the necessary information depending on the type of shipment (Excepted Quantity, Limited Quantity, UN Codes, hazard classes, number of pallets, gross weight, net weight, ...)

Conclusion

The carrier relies solely on the information transmitted by the shipper. In case of dispute, the lack of traceability of information previously transmitted will exonerate the carrier from the shipper.

Whether for occasional shipments or daily pickups, send your collection requests in writing to your carriers.

CHAVANON Conseil, Your Dangerous Goods Expert

No matter your position in the logistics and transport chain, CHAVANON Conseil supports you in regulatory audits, ADR and Securing training, and the management of your human, technical, and environmental risks.

Questions? contact@chavanon-conseil.fr

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