Whether an adviser is required depends on what the company actually does with dangerous goods. Labels such as 'carrier' or 'warehouse' alone do not describe all of its roles.
Start with the roles
ADR covers consigning and transporting dangerous goods and the related packing, loading, filling and unloading. One company may perform several roles. An assessment requires the classification, quantities and packaging of the goods, as well as a description of the operations carried out.
Can the service be external?
Yes. ADR 1.8.3.4 allows a person who is not directly employed by the company to act as adviser, provided they can actually perform the duties. An appropriate, valid qualification covering the transport mode and dangerous goods groups is required. A general offer of consultancy does not in itself confirm an appointment for your particular activities.
Agreement, appointment and notification
These are separate actions. The agreement describes the service and price; a specific qualified adviser is appointed; and information is submitted to the competent authority under the current procedure. Before starting, we agree who is responsible for each action.
What should you prepare for the discussion?
Your company's roles, UN numbers or available product documents, quantities per transport unit, packaging, routes, frequency of activities and existing procedures. If you believe an exemption applies, identify its specific basis. A general description is sufficient for an initial enquiry.
