Security requirements for moving dangerous goods by road and rail
Updated 7 August 2024
Introduction
If you transport dangerous goods by road or rail or offer that service, you must comply with international regulations, namely the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and the International Carriage of Dangerous Goods by Rail (RID).
Security provisions were enacted from 2001 to prevent terrorist incidents and protect the general population, and are established in chapter 1.10 of ADR and RID. In Great Britain, these security provisions are applied through the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09, as amended).
The purpose of the dangerous goods security regime is to reduce the possibility of dangerous goods being seized by criminals or terrorists on the road or rail network.
Chapter 1.10 forms the basis of the Department for Transport’s (DfT) Land Transport National Security Division (LTNSD) security compliance programme.
Read separate guidance about British derogations, transitional provisions and exceptions.
While there are no regulatory requirements for consignors and carriers to inform the DfT of the carriage of ‘high consequence dangerous goods’, DfT would encourage you to contact the LTNSD to request an inspection under chapter 1.10: landsecurity@dft.gov.uk.
The Health and Safety Executive for Northern Ireland (HSENI) are responsible for implementation of the international regulations in Northern Ireland under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (Northern Ireland) 2010.
The competent authority for the transport of Class 7 (radioactive material) is the Office for Nuclear Regulation (ONR). Specific advice on the secure carriage of radioactive material should be obtained from the ONR. Participants in the carriage of Class 7 are encouraged to contact them to request the relevant inspection: contact@onr.gov.uk.
Please note that businesses that handle, process or transport dangerous goods on a regular basis must appoint a dangerous goods safety adviser (DGSA). The DGSA and company staff should be properly trained, as per the requirements of ADR 1.3 and 1.8.3.
Enquiries regarding the security of dangerous goods can be made via email: dangerousgoods@dft.gov.uk.
This guidance quotes ADR. For carriage by rail the requirements under RID apply.
Contact the Office of Rail and Road (ORR) for any questions on the transport of dangerous goods by rail: contact.pct@orr.gov.uk.
Security measures
Dangerous goods are assigned to different classes and divisions according to the hazards they present. Read separate guidance on classes of dangerous goods.
The security requirements are split into 2 levels:
- a general level of requirements applicable to all dangerous goods
- additional provisions for ‘high consequence dangerous goods’ (HCDG)
HCDG are defined in RID and ADR 1.10.3.1 as those with the potential for misuse in a terrorist incident and which may, as a result, produce serious consequences such as mass casualties or mass destruction (whether to infrastructure, the environment or the economy) or, particularly for Class 7, mass socio-economic disruption.
All dangerous goods shall only be offered to carriers or organisations that have been appropriately identified. Temporary storage sites must be properly secured, drivers and crew must carry means of photographic identification, and security awareness training must be provided.
For HCDG, you need to create, adopt, implement and comply with a transport security plan.
On the GOV.UK home page for this guidance, you can find a:
- security plan template
- security risk assessment template
- driver advice sheet
Approach to compliance
The scope of the security regime covers the entire journey taken by the dangerous goods, from consignor to consignee, by road or rail. This may include consignors, carriers or those offering carriage, manufacturing sites, terminals, multi-modal sites, or any other qualifying location.
Compliance monitoring is conducted through a programme of announced inspections at company premises, carried out by the LTNSD to assess compliance with the mandatory aspects of chapter 1.10 of RID and ADR.
The Department for Transport, as competent authority, has the right to entry to undertake unannounced covert inspections, deriving from Section 19 of the Health and Safety at Work Act 1974 and Part 3 of the Railways Act 1993.
Scope of applicability
Chapter 1.10 does not apply to the carriage of limited quantities and of loads below certain levels, depending on the substance being carried. Further information can be found in ADR 1.1.3.6.3 and 3.4.
You should always refer to your DGSA to confirm whether ADR 1.10 is applicable.
Graphic 1 - flowchart showing if high consequence dangerous goods rules apply
Accessible text version of graphic 1
1. Is it a small load / limited quantity according to 1.1.3.6.3 / 3.4?
Yes: Chapter 1.10 is not applicable.
No: Chapter 1.10, sections 1.10.1 and 1.10.2 are applicable. Go to question 2.
2. Is the substance high consequence dangerous goods? (Table 1.10.3.1.2)
Yes: The complete chapter 1.10, including section 1.10.3, applies.
No: Only sections 1.10.1 and 1.10.2 of chapter 1.10 are applicable.
You should always refer to your DGSA to confirm whether ADR 1.10 is applicable.
Complying with the regulations
This part of the guidance quotes chapters of the ADR about the secure transport of dangerous goods and provides DfT’s advice on the quoted rules.
Chapter 1.10
Security provisions
Note: For the purposes of this chapter, security means measures or precautions to be taken to minimise theft or misuse of dangerous goods that may endanger persons, property or the environment.
1.10.1 General provisions
1.10.1.1 All persons engaged in the carriage of dangerous goods shall consider the security requirements set out in this chapter commensurate with their responsibilities
Advice
Chapter 1.10 refers to any person engaged in the carriage of dangerous goods, and includes administrative personnel, contractors, and agency staff.
Contractors may create new vulnerabilities and expose organisations to a greater ‘insider’ threat than they would face if relying on directly recruited staff. Contractors, including transport service providers, should undergo the same pre-employment screening processes with their own employees; responsibility for implementing these checks will rest with the contractor. They should be able to demonstrate, from their records, that they have carried out these checks.
1.10.1.2 Dangerous goods shall only be offered for carriage to carriers that have been appropriately identified.
Advice
If your company subcontracts dangerous goods movements to another haulier or courier, or any other relevant service provider, you must ensure that they are compliant, including evidence of a security plan, where necessary, and that the plan is reviewed and tested regularly. Additional checks may include checking security and recruitment policies, staff training, and drivers’ documents, including their ADR vocational qualification.
Rail freight operating companies hold a safety certificate issued by the ORR and this can form part of the appropriate identification process.
1.10.1.3 Areas within temporary storage terminals, temporary storage sites, vehicle depots, berthing areas and marshalling yards used for the temporary storage during carriage of dangerous goods shall be properly secured, well-lit and, where possible and appropriate, not accessible to the general public.
Advice
Temporary storage includes stops made necessary by the circumstances in a journey, as well as changes to the mode of transport. Areas used for the temporary storage of dangerous goods must be secured. This means that they should be controlled by a combination of physical barriers, security equipment, procedures, and staff vigilance.
For the purposes of ADR & RID, parking or necessary short stops (for example ‘tacho breaks’) during a journey are not considered temporary storage, subject to Regulation 7 of CDG09.
Additional fencing or patrols may be considered around areas where vehicles or trains are kept when loaded with HCDG. Sites shall be well-lit and illumination should complement other security equipment such as CCTV and enable security patrols to be conducted effectively. Regular checks should be carried out to ensure that security equipment is functioning correctly, and signage should be in place to define areas with unauthorised access.
Reasonable steps should be taken to ensure unauthorised access to dangerous goods is prevented. Additional consideration should be given to shared access sites.
All good physical security regimes should be based on the 3D principle – deter, detect and delay.
- deter – the overt physical and electronic security measures that might deter a would-be intruder
- detect – alarm systems, with visual (CCTV) verification, to detect the presence of an intruder
- delay – physical security measures that delay the intruder long enough to allow a response force to attend
Many sites will incorporate perimeter security fencing to meet health and safety requirements, as well as security requirements, however this guidance recognises that perimeter fencing might not be applicable in all cases. It is important to remember that the implementation of security measures should be pragmatic, proportionate and sustainable.
More information about physical security measures is available at the following websites:
1.10.1.4 Each member of a vehicle crew shall carry with them means of identification, which includes their photograph, during carriage of dangerous goods.
Advice
Photographic identification must be carried at all times during carriage. It may be appropriate for all staff working in terminals to be issued with photo ID passes. It is recommended that random spot checks of visiting drivers and crew members’ photo ID passes are carried out. Staff should challenge persons on site who are not familiar or not wearing a pass.
1.10.1.5 Safety inspections in accordance with 1.8.1 and 7.5.1.1 shall cover appropriate security measures.
Advice
All security equipment and devices installed on vehicles must be in working order and checked regularly.
1.10.1.6 The competent authority shall maintain up-to-date registers of all valid training certificates for drivers stipulated in 8.2.1 issued by it or by any recognized organization.
Advice
All records need to be made available to the competent authority upon request.
1.10.2 Security training
1.10.2.1 The training and the refresher training specified in chapter 1.3 shall also include elements of security awareness. The security refresher training need not be linked to regulatory changes only.
Advice
A suitable training programme should be implemented and provided to all employees involved in dangerous goods transport operations.
Please refer to the dangerous goods security training guidance, especially the matrix on page 7.
You should also consider mandatory cybersecurity training for all employees based on the current threats to UK businesses. Please refer to the National Cybersecurity Centre (NCSC) for further guidance.
Training should ideally be a mixture of e-learning, classroom and practical.
1.10.2.2 Security awareness training shall address the nature of security risks, recognising security risks, methods to address and reduce such risks and actions to be taken in the event of a security breach. It shall include awareness of security plans (if appropriate) commensurate with the responsibilities and duties of individuals and their part in implementing security plans.
Advice
The security awareness training must cover all the topics listed above. DfT have produced a training film ‘Lockdown’ to assist with delivering dangerous goods security training. This can be used to supplement the operator’s in-house training material and copies are available on request.
Email: landsecurity@dft.gov.uk.
Additional security training can be obtained from external training suppliers or other government departments including the:
- National Protective Security Authority(https://www.npsa.gov.uk/)
- Action Counters Terrorism (ACT) e-learning developed by NaCTSO
- information sharing platform, ProtectUK
1.10.2.3 Such training shall be provided or verified upon employment in a position involving dangerous goods transport and shall be periodically supplemented with refresher training.
Advice
We recommend completing security refresher training annually. Training should be regularly reviewed and updated in line with evolving security threats. The refresher training schedules should be clearly defined and evidenced.
1.10.2.4 Records of all security training received shall be kept by the employer and made available to the employee or competent authority, upon request. Records shall be kept by the employer for a period of time established by the competent authority.
Advice
Since 13 November 2023, employers must keep staff training records for a minimum of 6 years from the date of training, and make the records available to the employee or competent authority on request.
1.10.3 Provisions for high consequence dangerous goods
Note: In addition to the security provisions of ADR, competent authorities may implement further security provisions for reasons other than safety during carriage (see also Article 4, paragraph 1 of the Agreement). In order not to impede international and multimodal carriage by different explosives security marks, it is recommended that such marks be formatted consistent with an internationally harmonized standard (e.g. European Union Commission Directive 2008/43/EC).
1.10.3.1 Definition of high consequence dangerous goods
1.10.3.1.1 High consequence dangerous goods are those which have the potential for misuse in a terrorist event and which may, as a result, produce serious consequences such as mass casualties, mass destruction or, particularly for Class 7, mass socio-economic disruption.
Advice
In conjunction with the DGSA, the company should establish if the substances are classified as ‘high consequence dangerous goods’, and ensure correct handling and that security measures are applied.
1.10.3.1.2 High consequence dangerous goods in classes other than Class 7 are those listed in Table 1.10.3.1.2 below and carried in quantities greater than those indicated therein.
Advice
Participants should refer to this table, and those it references, to confirm if the dangerous goods are classified as high consequence.
For carriage of Class 1, additional requirements may be necessary under Regulation 7 of CDG09. Refer to HSE guidance and regulations for additional information.
Table 1.10.3.1.2: List of high consequence dangerous goods
Class | Division | Substance or article | Tank Quantity (l) c | Bulk Quantity (kg) d | Packages Quantity (kg) |
---|---|---|---|---|---|
1 | 1.1 | Explosives | a | a | 0 |
1 | 1.2 | Explosives | a | a | 0 |
1 | 1.3 | Compatibility group C explosives | a | a | 0 |
1 | 1.4 | Explosives of UN Nos. 0104, 0237, 0255, 0267, 0289, 0361, 0365, 0366, 0440, 0441, 0455, 0456, 0500, 0512 and 0513 | a | a | 0 |
1 | 1.5 | Explosives | 0 | a | 0 |
1 | 1.6 | Explosives | a | a | 0 |
2 | Flammable, non-toxic gases (classification codes including only letters F or FC) | 3000 | a | b | |
2 | Toxic gases (classification codes including letters T, TF, TC, TO, TFC or TOC) excluding aerosols | 0 | a | 0 | |
3 | Flammable liquids of packing groups I and II | 3000 | a | b | |
3 | Desensitized explosives | 0 | a | 0 | |
4.1 | Desensitized explosives | a | a | 0 | |
4.2 | Packing group I substances | 3000 | a | b | |
4.3 | Packing group I substances | 3000 | a | b | |
5.1 | Oxidizing liquids of packing group I | 3000 | a | b | |
5.1 | Perchlorates, ammonium nitrate, ammonium nitrate fertilisers and ammonium nitrate emulsions or suspensions or gels | 3000 | 3000 | b | |
6.1 | Toxic substances of packing group I | 0 | a | 0 | |
6.2 | Infectious substances of Category A (UN Nos. 2814 and 2900, except for animal material) and medical waste of Category A (UN No. 3549) | a | 0 | 0 | |
8 | Corrosive substances of packing group I | 3000 | a | b |
a Not relevant.
b The provisions of 1.10.3 do not apply, whatever the quantity is.
c A value indicated in this column is applicable only if carriage in tanks is authorized, in accordance with chapter 3.2, Table A, column (10) or (12). For substances that are not authorized for carriage in tanks, the instruction in this column is not relevant.
d A value indicated in this column is applicable only if carriage in bulk is authorized, in accordance with chapter 3.2, Table A, column (10) or (17). For substances that are not authorized for carriage in bulk, the instruction in this column is not relevant
1.10.3.1.3 For dangerous goods of Class 7, high consequence radioactive material is that with an activity equal to or greater than a transport security threshold of 3 000 A per single package (see also 2.2.7.2.2.1) except for the following radionuclides where the transport security threshold is given in Table 1.10.3.1.3 below.
Table has been slightly reformatted to meet legal accessibility requirements. You can see the original table in this ADR document.
Advice
For carriage of Class 7, refer to ONR guidance and regulations.
Requirements are set out in Schedule 2 of CDG09.
1.10.3.2 Security plans
1.10.3.2.1 Carriers, consignors and other participants specified in 1.4.2 and 1.4.3 engaged in the carriage of high consequence dangerous goods (see Table 1.10.3.1.2) or high consequence radioactive material (see 1.10.3.1.3) shall adopt, implement and comply with a security plan that addresses at least the elements specified in 1.10.3.2.2.
Advice
The security plan(s) shall be based on the overall operation of the business, not on individual movements, and tailored to suit the company’s operational activities. It may be more appropriate to implement a security plan for each site or location used during the carriage of HCDG. Plan(s) should reference other plans or documents that may be in place, such as maritime security plans or emergency plans for example.
1.10.3.2.2 The security plan shall comprise at least the following elements:
(a) Specific allocation of responsibilities for security to competent and qualified persons with appropriate authority to carry out their responsibilities;
Advice
All persons involved in dangerous goods security management operations should be listed by role and name in the security plan, with a summary of their responsibilities.
(b) Records of dangerous goods or types of dangerous goods concerned;
Advice
A summary of the types of dangerous goods regularly carried or potentially carried should be included; this could be a table identifying the UN classes. If practical, the UN numbers and shipping names could be listed, identifying which ones are HCDG.
(c) Review of current operations and assessment of security risks, including any stops necessary to the transport operation, the keeping of dangerous goods in the vehicle, tank or container before, during and after the journey and the intermediate temporary storage of dangerous goods during the course of intermodal transfer or transhipment between units as appropriate;
Advice
An overview of the current operation should be included at the start of the security plan to describe its purpose and scope. This will set out the reasons for the plan, as well as how and why it applies to the business and the carriage of HCDG. A regular review will be required to determine any changes to security procedures or arrangements that might be necessary.
An assessment of all security risks applicable to the company’s dangerous goods operations should be included. This comprises:
- journey and vehicle
- risks at site
- cyber and information security
- personnel risks
(d) Clear statement of measures that are to be taken to reduce security risks, commensurate with the responsibilities and duties of the participant, including:
- training;
- security policies (e.g. response to higher threat conditions, new employee/employment verification, etc.);
- operating practices (e.g. choice/use of routes where known, access to dangerous goods in intermediate temporary storage (as defined in (c)), proximity to vulnerable infrastructure etc.);
- equipment and resources that are to be used to reduce security risks;
Advice
The security plan must include these measures which help contribute to transport security. The specific instructions and guidance given to drivers and crew, plus specific measures to be taken in the event of unplanned or unusual circumstances, should be included in this section. You may wish to reference the location of existing company policies and procedures.
Employment checks
Suitable checks should be made of any potential new employees who will be involved in the transport of HCDG. DfT recommends completing DBS checks (basic or enhanced, according to role) for all staff.
Documents should be checked to verify personal identity and right to work status. This should include agency or temporary staff. All checks should be carried out on original documents. A 5-year no-gap employment history is recommended.
Operating practices
The plan should summarise, for instance, how:
- movements are controlled and monitored to ensure security
- any problems with the movements are dealt with, for example security during unplanned stoppages
- road and rail interfaces are managed at intermodal depots
- public access to vehicles or trains has been restricted
Equipment and resources
The security plan statement of measures must also identify and record the equipment and resources deployed, such as:
- CCTV
- lighting
- intruder detection
- access systems
- physical security equipment
(e) Effective and up to date procedures for reporting and dealing with security threats, breaches of security or security incidents;
Advice
DfT recommends implementing an incident reporting procedure or policy, and the subsequent review process.
(f) Procedures for the evaluation and testing of security plans and procedures for periodic review and update of the plans;
Advice
ADR requires security plans to be periodically tested and reviewed. DfT recommends doing so on an annual schedule.
Testing may include the following:
- penetration test
- desktop exercise - theft, hijack, protestor activity scenarios
- cybersecurity response exercise
- information security exercise
- unattended item test
(g) Measures to ensure the physical security of transport information contained in the security plan; and
Advice
A summary of measures taken to protect sensitive company information (hard-copy or electronic), including security plans, transport documentation and personnel records, must be included. This may include:
- cybersecurity risk assessment
- cybersecurity training
- access control measures
- archiving and destruction of documents
(h) Measures to ensure that the distribution of information relating to the transport operation contained in the security plan is limited to those who need to have it. Such measures shall not preclude the provision of information required elsewhere in ADR.
Advice
The security plan should advise how the distribution of information on the dangerous goods transport operations is restricted to those who need the information.
Note: Carriers, consignors and consignees should co-operate with each other and with competent authorities to exchange threat information, apply appropriate security measures and respond to security incidents.
Advice
The above note is for all participants engaged in the carriage of HCDG by road and rail. Sources include BTP, Network Rail, ORR, NCSC, NPSA, DfT, Protect UK, CSSC, the Police, DVSA, ONR, trade associations, and DGSAs.
1.10.3.3 Devices, equipment or arrangements to prevent the theft of the vehicle carrying high consequence dangerous goods (see Table 1.10.3.1.2) or high consequence radioactive material (see 1.10.3.1.3) and its cargo, shall be applied and measures taken to ensure that these are operational and effective at all times. The application of these protective measures shall not jeopardize emergency response.
Advice
A summary of measures which could be taken to ensure the security of vehicles includes:
- journey planning
- tracking devices
- double crew
- escort vehicle
- stabling location
- immobilisers
- cargo locks
- isolators
- vehicle CCTV
- vehicle brake locks
- vehicle key control
Drivers should carry a dangerous load card to be used if stopped by an unmarked vehicle.
Note: When appropriate and already fitted, the use of transport telemetry or other tracking methods or devices should be used to monitor the movement of high consequence dangerous goods (see Table 1.10.3.1.2) or high consequence radioactive material (see 1.10.3.1.3).
Advice
A repair and maintenance contract should be in place for all vehicle security equipment and systems.
Tracking systems are widely available for goods vehicles and trailers; fitting such equipment represents best practice when carrying HCDG. It may also be appropriate to consider tracking the freight or container itself if the goods are particularly sensitive or attractive to thieves.
Total operations processing system (TOPS) and global positioning system (GPS) applications are in use on some trains.
1.10.4 The requirements of 1.10.1, 1.10.2, 1.10.3 and 8.1.2.1 (d) do not apply when the quantities carried in tanks or in bulk on a transport unit do not exceed those referred to in 1.1.3.6.3. In addition the provisions of this chapter do not apply to the carriage of UN No. 2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-I) and UN No. 2913 RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECTS (SCO-I).
Advice
For carriage of Class 7, refer to ONR guidance and regulations.
Requirements are set out in Schedule 2 of CDG09.
Useful contacts
Further to this Department for Transport guidance, advice on security and other matters can also be obtained from the following organisations:
DfT Dangerous Goods Unit
DfT Dangerous Goods Inspection Team (LTNS)
List of DGSAs
https://www.gov.uk/government/publications/find-a-dangerous-goods-safety-adviser
Health & Safety Executive (HSE)
National Protective Security Authority (NPSA)
National Counter Terrorism Security Office (NaCTSO)
https://www.protectuk.police.uk/
Loss Prevention Certification Board (LPCB)
Security Industry Authority (Security Officer licensing issues only)
Office for Nuclear Regulation (ONR)
Office of Rail and Road (ORR)
National Cyber Security Centre (NCSC)
British Compressed Gas Association (BCGA)
British International Freight Association (BIFA)
Chemical Business Association (CBA)
Chemical Industries Association (CIA)
UK and Ireland Fuel Distributors Association (UKIFDA)
Logistics UK
National Chemicals Emergency Centre (NCEC)
Road Haulage Association (RHA)
Liquid Gas UK
Fuels Industry UK
https://www.fuelsindustryuk.org/
Tank Storage Association (TSA)
British Association of Dangerous Goods Professionals (BADGP)
Cross-sector Safety and Security Communications (CSSC)
Explosives Industry Group (EIG)
National Vehicle Crime Intelligence Service (NaVCIS)
British Transport Police (BTP)
Network Rail