Hello, I am employed by a waste management company who insist that I do not need to hold an ADR Licience , nor do I need to mark and indicate the carrying of waste asbestos on containers or vehicles ( closed container , but quantity can be Tonnes ). I have argued that the vehicles DO need to be marked if within scope ), and that if a Form HWCNO1v111 ( Hazardous Waste Consignment Note ) has been filled out in order to collect waste, the driver must hold an ADR Licience in order to legally carry it on the companies behalf , are you able to offer CLEAR Clarification Please ■■?
I can only explain the ADR stuff…
ADR Chapter 3.3 contains this Special Provision (SP) relating to asbestos:
SP 168
Asbestos which is immersed or fixed in a natural or artificial binder (such as cement, plastics, asphalt, resins or mineral ore) in such a way that no escape of hazardous quantities of respirable asbestos fibres can occur during carriage is not subject to the requirements of ADR. Manufactured articles containing asbestos and not meeting this provision are nevertheless not subject to the requirements of ADR when packed so that no escape of hazardous quantities of respirable asbestos fibres can occur during carriage.
It’s quite possible that the company are correct about your concerns regarding ADR because if the asbestos you carry meets the above, then it’s not subject to ADR.
If the asbestos you carry does NOT meet the above, then it might be subject to ADR depending on the name of the type of the asbestos and some other info that I might need to ask you for.
For now, do you know the name of the type of asbestos please?
Hi Dave, Thanks for your reply, Unfortunatley the “Type” varies fron job to job and in the main I believe that the company in question try to stay " legal" ( but only when carrying large quantities).
My argument with them is that . If they raise a Envirioment Agency Consignment note Form HWCNO1v111 and they expect me to sign such a note I can only do so if I am ADR qualified ( Which I a am ) . “They” are increasingly using Non ADR Trained agency Drivers and expecting them to sign the Consignment notes regardless ?
Thanks again
X2li:
Hi Dave, Thanks for your reply, Unfortunatley the “Type” varies fron job to job and in the main I believe that the company in question try to stay " legal" ( but only when carrying large quantities).
Hi X2li,
In order that I can give you a good answer, please say whether the asbestos meets the conditions above in ADR SP168?
It’ll probably be a “yes” or a “no” 
X2li:
My argument with them is that . If they raise a Envirioment Agency Consignment note Form HWCNO1v111 and they expect me to sign such a note I can only do so if I am ADR qualified ( Which I a am ) .
Wherever did you get that idea?
I’m asking this because I’ve never heard of such a requirement, so a quote from the relevant legislation would help me to understand it please.
X2li:
“They” are increasingly using Non ADR Trained agency Drivers and expecting them to sign the Consignment notes regardless ?
Thanks again
Now we’re back to SP 168, because I can’t give you any better answer than it might be perfectly legal.
Just because something requires a Hazardous Waste Note doesn’t necessarily mean that the consignment needs to be carried as an ADR regulated load.
Asbestos is usually divided in to two groups, Bonded ( white asbestos ) as described in the first bit of Dave’s SP168 attracts an EWC code of 17-06-05 which is out of scope for ADR Regs and other group is Fibrous ( blue or brown asbestos ) described in the last bit of the SP168 attracts an EWC code of 17-06 -01, I carry this under ADR regs using UN no.2212 with class nine placards, someone may be along and tell me I’m wrong but I have been stopped on numerous occasions by VOSA and have not had any problems, hope this helps ps. blue asbestos called crocidolite and brown known as amosite,this is the nasty stuff,Cheer’s Pete
pete smith:
Asbestos is usually divided in to two groups, Bonded ( white asbestos ) as described in the first bit of Dave’s SP168 attracts an EWC code of 17-06-05 which is out of scope for ADR Regs and other group is Fibrous ( blue or brown asbestos ) described in the last bit of the SP168 attracts an EWC code of 17-06 -01, I carry this under ADR regs using UN no.2212 with class nine placards, someone may be along and tell me I’m wrong but I have been stopped on numerous occasions by VOSA and have not had any problems, hope this helps ps. blue asbestos called crocidolite and brown known as amosite,this is the nasty stuff,Cheer’s Pete
Hi Pete,
I can’t speak for EWC codes because they’re outside of my remit, but the rest of what you said about ADR and UN Class 9 is spot-on.
UN 2212 ASBESTOS, AMPHIBOLE, 9, PGII is ADR’s Proper Shipping Name (PSN) for it.
UN 2212 is used for any of the following: amosite, tremolite, actinolite, anthophyllite, crocidolite
The other PSN and entry in ADR’s dangerous goods list for asbestos is:
UN 2590 ASBESTOS, CHRYSOTILE, 9, PGIII