Transporting dangerous goods as tools of trade

Background

The Dangerous Goods (Transport by Road or Rail) Regulations 2018 provide concessions for the transport of certain types and quantities of dangerous goods used by tradespeople and service technicians at work.

The concessions enable tradespeople to transport size-limited quantities of dangerous goods without meeting all of the regulatory requirements that a person engaged in the commercial transportation of dangerous goods must otherwise meet. This is with respect to requirements for commercial transportation of dangerous goods including licencing, vehicle signage and documentation.

This guidance does not apply to any person who transports dangerous goods as a commercial business.

Dangerous goods examples as tools of trade

Examples of dangerous goods used as tools of trade are:

Plumbers

Gas cylinders containing:

• oxygen
• acetylene
• propane
• propylene
• butane
• fuels including gasoline and kerosene
• sealant and waterproofing products containing silicone or corrosives
• drain cleaning products that are toxic or corrosive such as caustic soda

Refrigeration mechanics

• flammable gases
• non-flammable gases

Pest controllers

• pesticides
• herbicides

Painters

• solvent based paint
• solvent based paint products including:
  • thinners
  • lacquer
  • enamel
  • stain
  • varnish

Swimming pool installers and maintenance employees

• pool chemicals including chlorine and acid

Landscape gardeners

• fertilisers
• pesticides
• herbicides

Specialised cleaners

• flammable cleaning products
• toxic cleaning products
• corrosive cleaning products

Contract maintenance technicians

• lubricants
• degreasers
• sealers
• cleaning products

Sales and marketing representatives

Product samples including:

• cleaning products
• toiletries
• cosmetics
• fragrances
• herbicides

Compulsory safety requirements

When transporting dangerous goods as tools of trade, the container of dangerous goods (gas cylinder or jerri can, for example) must be:

• in compliance with the packaging requirements set out in Part 4 of Dangerous Goods (Transport by Road or Rail) Regulations 2018
• appropriately marked
• loaded and unloaded, secured, separated from incompatible dangerous goods and ignition sources, well ventilated during transport and otherwise transported in such a way as ensuring:
  • the container is fit for purpose
  • any risk to people, property or the environment is eliminated (or if elimination is not possible, reduced as far as practicable)

The container of dangerous goods must not be altered or damaged.

Transport limits

The Dangerous Goods (Transport by Road or Rail) Regulations 2018 set out that the maximum load of dangerous goods permitted to be transported as a tool of trade is as follows:

• A load of dangerous goods not containing any Class 2.1 dangerous goods other than aerosols (flammable gas), Class 2.3 (toxic gas) and packing group I (high risk, high danger) is limited to less than an aggregate quantity of 500kg (L).
• A load of dangerous goods that does contain any Class 2.1 dangerous goods other than aerosols (flammable gas), Class 2.3 (toxic gas) and packing group I (high risk, high danger) is limited to less than an aggregate quantity of 250kg (L). Within such a load, Class 2.3 and Packing Group I materials must together form less than an aggregate quantity of 100kg (L) of the total load.

If the dangerous goods exceed these quantities, then the tools of trade exemption does not apply, and you must comply with the commercial transportation requirements of the Dangerous Goods (Transport by Road or Rail) Regulations 2018.  

In addition to overall volume restrictions for the transportation of dangerous goods as tools of trade, the Dangerous Goods (Transport by Road or Rail) Regulations 2018 place further limitations on the volume of dangerous goods that can be transported in an enclosed space or in the passenger compartment of a vehicle. These are:

• No more than a total combined volume of 250kg (L) is permitted within an enclosed space or a passenger compartment, for the following dangerous goods:
  • flammable liquids (Class 3)
  • flammable solids (Class 4)
  • oxidising substances (Class 5)
  • toxic substances (Class 6)
• No more than a total combined volume of 50kg (L) is permitted within an enclosed space or a passenger compartment, for the following dangerous goods:
  • flammable gas (Class 2.1)
  • toxic gas (Class 2.3)
  • packing group I