UN 1965 in ADR: Liquefied gas transport between class 2.3 and § 23 GGVSEB

The search 23 1965 dangerous goods leads to one of the most common UN numbers in European road traffic: UN 1965 Hydrocarbon gas, liquefied, n.o.s., colloquially known as liquid petroleum gas or LPG. The entry is in Table A of Chapter 3.2 ADR, the European Agreement concerning the International Carriage of Dangerous Goods by Road. The Dangerous Goods Ordinance for Road, Railway and Inland Waterway Transport (GGVSEB) and the Dangerous Goods Transport Act (GGBefG) also apply to shippers and carriers in Germany.

This article classifies the UN 1965 classification, describes the obligations for shipping, packaging and transport and shows where CIVAC's compliance platform and Officer-as-a-Service gives structure to the tasks of the dangerous goods officer. The focus is on ADR 2025 as the current legal status and the typical audit questions of a regular inspection.

The UN number 1965 is a so-called collective item. It combines various mixtures of liquefied hydrocarbon gases, especially propane, butane, propene and butene, as well as their mixtures. The abbreviation n.a.s. stands for not otherwise stated and signals that a more specific UN number could exist, but the collective number is deliberately chosen here. In practice, UN 1965 is the most common entry for commercial liquefied petroleum gas (LPG).

In Table A of Chapter 3.2 ADR, UN 1965 is classified in Class 2, classification code 2F. The F stands for flammable gas. Class 2 is not assigned to the packaging group; instead, the ADR regulates the permissible pressure vessels, tanks and packaging instructions. Danger labels are model 2.1 (flammable gas), in a red diamond with a black flame.

The exact composition does not have to be shown in the transport document, but the trade name of the gas, the associated UN number and the official name for transport do have to be shown. In the case of unrefined mixtures, the addition Mixture B, C, A0 or A often occurs, derived from the vapor pressure behaviour. The correct entry is one of the mandatory checks of the Dangerous Goods Officer.

The central legal framework is the ADR in its current version. The GGVSEB of June 17, 2009, last amended by regulation of February 5, 2024, also applies to national transport in Germany. Section 9 GGVSEB names the obligations of the shipper, packer, filler, carrier and recipient. The Dangerous Goods Officer Ordinance (GbV) specifies which companies must appoint a dangerous goods officer.

Subsection 1.3 ADR applies to the training of other responsible persons, and the ADR training certificate according to Chapter 8.2 ADR applies to vehicle drivers. The obligation to submit an annual report from the dangerous goods officer results from subsection 1.8.3.3 ADR and must be kept for at least five years according to GbV § 8. In addition, the Portable Pressure Equipment Ordinance and the Product Safety Act regulate requirements for pressure vessels.

Violations can be punished with fines of up to 50,000 euros per individual offense according to the catalogue of fines for dangerous goods of the relevant countries. In the event of intentional or dangerous violations, there is also a risk of criminal or regulatory consequences in accordance with Section 326 of the Criminal Code and Section 130 of the OWiG. Deadline expires as soon as we become aware of it.

According to § 1 GbV, companies whose activities include the transport of dangerous goods or the associated packaging, loading, filling or unloading are obliged to place an order. For UN 1965 in larger quantities, such as tank trucks or palletized shipping goods in pressure vessels, the ordering requirement usually applies. Exemptions according to § 2 GbV apply to companies that only transport exempt quantities according to subsection 1.1.3 ADR.

The dangerous goods representative must be appointed in writing, with an appointment certificate, description of tasks and reporting line to the management. The appointment certificate, signed, filed, verifiable. He must have completed training in accordance with GbV § 4 and passed an examination at a chamber of commerce and industry. The certificate is valid for five years and can be extended through refresher training.

In companies with a complex mix of quantities, it is worth combining the role with neighboring representatives, such as the Hazardous Substances Officer. Both roles can be managed separately or, in smaller structures, by one person with two certificates. The reporting obligation remains separated on a role-by-role basis.

The transport document according to Section 5.4.1 ADR must contain at least: the UN number 1965, the official name hydrocarbon gas, liquefied, n.o.s., the class 2, the classification code 2F, the number and description of the packages, the total quantity in liters or kilograms, the name and address of the sender and the recipient as well as a tunnel restriction identifier. For tanks, the tank code from the associated tank instructions is also added.

The labelling of the packages follows Chapter 5.2 ADR. The UN number, the official name, the danger label 2.1 and the manufacturer and test marks must be affixed to pressure vessels. Tanks and large containers bear orange plaques with the Kemler number 23 at the top and UN 1965 at the bottom. The Kemler number 23 means flammable gas. Here is the probable origin of the search 23 1965 dangerous goods: the orange plate on the tanker.

The tunnel restriction identifier for UN 1965 is (B/D). This means: Carriage prohibited in tunnels of categories B, C, D and E for tanks, in tunnels of categories D and E for packages. Anyone planning tunnel routes checks this before scheduling.

UN 1965 may be transported in pressure vessels in accordance with packaging instruction P200 ADR: cylinders, large cylinders, pressure drums and bundles of cylinders with certified valves. The materials and minimum test pressures can be found in the respective table in P200. Pressure vessels must be tested in the test cycles according to Table T-50 ADR, usually every ten years, with an additional intermediate test after five years for non-stainless steel.

Tank transport takes place in permanently connected tanks, demountable tanks, tank containers or MEGCs (multi-element gas containers) with tank code PxBN(M) or comparable. The maximum permissible filling in percent by volume results from subsection 4.3.3.2.5 ADR and the density at reference temperature. Overfilling is safety-critical and a classic complaint during inspections.

CIVAC provides 490 ready-to-use audit templates, including checklists for pressure vessel tests, tank files and filling protocols. Test deadlines for each pressure vessel can be managed centrally in the workspace, with a reminder function 90 days before expiry. Others run compliance like a filing cabinet. We run it like software.

Persons who are involved in the transport of dangerous goods without being a vehicle driver must receive functional training in accordance with subsection 1.3 ADR. The training includes general instruction, function-specific training and safety training. The training certificates must be kept for at least five years and presented to the responsible authority upon request.

Drivers of vehicles that are subject to the marking requirement require the ADR training certificate in accordance with Chapter 8.2 ADR (colloquially known as the ADR certificate). For UN 1965, the advanced tank course is also required if tank transport takes place. The certificate is valid for five years and can be extended with a refresher course.

In practice, supervisors regularly check two points: Is the training evidence available by name, with a training plan and list of topics? And does the training match the actual function performed? A general warehouse logistics briefing does not replace the packer’s ADR-specific training. Training matrix, resubmission and evidence can be maintained centrally in the CIVAC workspace.

The dangerous goods officer prepares an annual written report on the company's activities in the area of ​​dangerous goods transport. Contents according to subsection 1.8.3.3 ADR include: type and quantity of dangerous goods transported, overview of training measures, internal controls carried out, deficiencies identified and suggestions for improvement, records of incidents and accidents.

The report must be retained for at least five years and presented to the responsible authority upon request. In UN 1965, the quantities are typically in tonnes per year per packaging form, separated into tank and package transport. The overview of defects requires honesty: a smoothed list without findings appears implausible and regularly leads to further inspections.

In the CIVAC workspace, the annual report can be created as a linked document with data from ongoing transport operations. The reporting structure follows a template included in the 490 audit templates. Licence the workspace for your internal representatives or have our representatives order it if ordering via external representatives is more efficient.

Anyone who packs or transships UN 1965 for transport is simultaneously operating a hazardous materials handling area in accordance with GefStoffV and a fire protection-relevant area in accordance with the respective state building regulations. The interaction with the fire protection officer and the environmental protection officer is mandatory, not optional.

At the occupational safety interface, TRGS 407 and TRGS 510 apply for storage of liquid gas pressure vessels as well as DGUV rule 100-500. The risk assessment according to Section 5 ArbSchG must cover the specific risks of fire, explosion, suffocation in sinkholes and frostbite in the event of leaks. For larger systems, the Major Accident Ordinance becomes relevant, with obligations according to the 12th BImSchV and appointment of a major incident officer.

CIVAC maps these interfaces in the same workspace, with common audit templates and a reporting line to management. The auditor calls, the evidence is ready. Audit-proof, documented, ADR-proof.

Anyone who ships, fills, transports or unloads UN 1965 is responsible. The dangerous goods officer is the person who carries this responsibility operationally and documents it to management. Anyone who expects a regular inspection in the next few months or has to prepare the annual report for 2026 has to decide between two paths.

Path one: You have a certified dangerous goods officer and need the methodology. Licence the CIVAC workspace for your internal representatives and use the 490 audit templates, the training matrix and the report template. Path two: The position is not filled or the hourly capacity is not sufficient. Have a dangerous goods officer appointed via Officer-as-a-Service, with an appointment certificate within 2 working days.

If you would like to be specific, write to info@civac.de or use the contact form. You will receive an initial assessment of the obligation to order according to the GbV and the choice of model within one working day. Turn reading into an assignment.