ADR 1.3 Instruction: Duties, intervals, evidence

According to Section 1.3 of the ADR Convention (Accord européen relatif au transport international des marchandises Dangereuses par Route, implemented in Germany by GGVSEB and GbV), all persons whose activities concern the transport of dangerous goods must be trained in the requirements before they act independently. This not only affects drivers, but also loaders, fillers, packers, shippers, recipients and dispatchers. According to 1.3.1 ADR, the training is task and responsibility-related, the documentation according to 1.3.3 ADR must be kept for at least five years and must be presented to the responsible authority upon request. In the event of a violation, there is a risk of a fine according to Section 10 GGVSEB as well as personal consequences for the dangerous goods officer and the management according to Section 130 OWiG.

In practice, the 1.3 instruction is one of the most frequently complained about obligations during inspections by the Federal Office for Logistics and Mobility (BALM, formerly BAG) and the trade inspectorate. Updates are often missing, the topics are too general or the confirmations of participation cannot be assigned. This article describes what a 1.3 training must include, how you document it, at what intervals you repeat it and how CIVAC's compliance platform and Officer-as-a-Service keeps the evidence in the workspace auditable. The appointment certificate, signed, filed, verifiable.

Section 1.3.1 ADR formulates the training obligation for everyone whose area of ​​responsibility includes the transport of dangerous goods. This goes far beyond the driver with an ADR certificate according to Chapter 8.2. Specifically affected are clients, shippers, packers, loaders, fillers, carriers, unloaders, recipients as well as all people who deal with dangerous goods in the warehouse, in scheduling, in receipt or in distribution. Colleagues from sales who accept orders and colleagues from customer support who provide information over the telephone are also subject to the obligation as soon as their activities affect the dangerous goods process. The GbV supplements the requirements for dangerous goods officers with their own training according to 1.8.3 ADR.

The 1.3 training does not replace the ADR certificate according to Chapter 8.2 for drivers. It stands independently from this duty and applies to everyone else involved. According to Section 9 GbV, the company's dangerous goods officer is responsible for implementation. If no representative has been appointed, the external representative takes on this task, for example in the Officer-as-a-Service model. In the workspace, CIVAC maintains an overview of the people who require 1.3 training, according to the roles and locations stored. You can find an overview of the CIVAC role on the Dangerous Goods Officer page. This makes it clear who was last trained, when, and which topics were part of the instruction. The appointment certificate, signed, filed, verifiable. When new employees are hired or existing employees change their role, the system automatically suggests appropriate 1.3 training and blocks approval for dangerous goods-related activities as long as proof is not available. This not only documents compliance, but also enforces it operationally, which generates significantly higher detection rates than pure HR checklists.

According to 1.3.2 ADR, the instruction is divided into three components. Firstly, general awareness: those involved should be familiar with the general regulations for the transport of dangerous goods. This includes terms, classes, packaging groups, labelling, labelling and the basic principles of ADR. Secondly, the task-related training: Those involved must know the regulations that apply to their activity, such as the shipper, the regulations for securing loads and stowage, the shipper, the regulations for packages, transport documents and safety data sheets, and the filler, the regulations for tank containers and portable tanks.

Third, the safety training: It includes measures to avoid risks, what to do in an emergency, first aid, fire fighting and security. The content of the training is based on the specific dangerous goods properties of the materials processed in the company, the packaging materials used and the transport routes. A pure PowerPoint presentation on “general ADR basics” does not meet the requirement. The BAG inspectors specifically check whether the trained content matches the actual activity. A template for each function (shipper, loader, filler, recipient, dispatcher) is available in the CIVAC Workspace, which the external dangerous goods officer supplements with your substance and transport-specific content. Others run compliance like a filing cabinet. We run it like software. This makes the instruction appropriate in depth without having to build each training course from scratch. The templates are updated centrally with every ADR amendment (most recently in 2025) and are propagated into each client's training portfolio. This well-maintained template library is one of the reasons why medium-sized companies without their own dangerous goods department achieve comparable audit maturity with the Workspace as large corporations with dedicated compliance teams.

The ADR itself does not specify a fixed repetition cycle in 1.3.2.4, but requires a refresher at regular intervals and when regulations change. German practice and the federal states recommend a cycle of two years; many companies work with an annual refresher. The ADR is updated every two years (most recently ADR 2025), so that refresher training makes sense with each new version at the latest. In addition, event-related training is mandatory: when changing tasks, using new hazardous substances, near misses, abnormalities in internal audits or new official instructions.

Intervals are automatically reminded in the CIVAC Workspace. As soon as the last instruction was 22 months ago, the dangerous goods officer receives a warning; After 24 months, a second reminder is sent to the HR department. This means that the refresher is not forgotten due to vacation, illness or changes in personnel. In the event of changes to regulations, such as the transition from ADR 2023 to ADR 2025, the system propagates an update of the instruction templates and suggests a training date for all affected persons. The auditor calls, the evidence is ready. When a BAG inspection takes place, it can be seen in seconds who was trained, when, with what content and what refresher is due next, without having to search through folders or paper folders. Internal audits, for example through a group-wide audit or by management within the framework of Section 130 OWiG obligations, can also be carried out from the same inventory. This creates a double benefit: official controls become more relaxed and internal supervisory processes are operated without additional effort. The central inventory can also be cited immediately for ISO/IEC 27001:2022 audits or ISO 9001 audits, which check training evidence within the framework of personnel competence, and significantly reduces the effort. In comparison to fragmented paper folders, the inventory can also be searched and exported retroactively according to any criteria (person, function, location, time slice).

According to 1.3.3 ADR, the training must be documented in writing and kept for at least five years. The documentation must contain the name and position of the person trained, the date of the training, the duration, the content and the name of the trainer. It is also recommended that a signature from the participant confirms that they have taken note of the information, as well as proof of learning success (comprehension question, quiz or short certificate). A mere attendance list is not sufficient because it does not provide evidence of content or learning success.

During inspections, authorities require submission within a period of time, which is usually between 24 hours and seven days. Anyone who only shows loose Excel lists or scattered PDFs will lose the argument and risk a fine according to Section 10 GGVSEB. In the CIVAC Workspace, the documentation is centrally located, versioned and with an audit trail. Each training course creates an entry with participants, date, content, duration, who was taught and learning success. During an audit, the evidence list can be exported with filters. Audit-proof, documented, 1.3.3-ADR-proof. Retention is automatically secured beyond five years when the person leaves the company, so you can provide evidence even after staff changes if past incidents are brought up. The appointment certificate, signed, filed, verifiable. In corporations with several subsidiaries, the documentation can be structured per location and per function, so that a country-specific inspection with different authority traditions can be served without any breaks. The retention obligations are consistently adhered to across the subsidiaries, which represents a significant advantage in cross-border transport and multinational audits and is visibly reflected in the group's compliance maturity. A uniform database is created for internal audits and group guidelines, which flows into reports to management without special separation.

The 1.3 instruction is an obligation of the company; the responsibility for carrying it out lies with the dangerous goods officer according to Section 8 GbV. This person must carry out their own training according to 1.8.3 ADR and their training certificate according to the IHK examination. The order, proof of training from the representative and 1.3 instructions from all employees together form the pile of evidence that a BAG inspection requires. If an element is missing, the stack is considered incomplete, with the corresponding fine consequences according to § 10 GGVSEB.

CIVAC bundles these elements in a workspace. The appointment certificate for the dangerous goods officer is located next to the IHK training certificate, next to the list of trained employees, next to the 1.3 instruction protocols, next to the annual report and next to the dangerous goods specifications. If the representative changes, the inventory moves seamlessly to the new appointment certificate. This is particularly valuable for medium-sized companies that do not have their own compliance department and would otherwise have to rebuild the documentation every time there is a change in personnel. You can find out more about the role and duties in the overview of CIVAC representative roles. Licence the workspace for your internal representatives or have our representatives order it. In both cases, the evidence stack resides in the same system and is accompanied by the same audit trail. An additional advantage is the versioning of the appointment certificate: If the representative's tasks are expanded, for example to be appointed as a fire protection or hazardous substances officer, the order is updated in the same document and documented with a date and signature, without a new file being created. In this way, the historical reference is preserved and the lack of gaps can be proven to the authorities. In combination with the 25 representative roles in the CIVAC portfolio, a stack is created that is managed consistently far beyond dangerous goods, without each role using its own tools.

The most common complaints during BALM and trade inspections can be divided into five categories. First: lack of documentation. There are no written documents or the documents provided are incomplete because the name, date or content are missing. Second: lack of content. The training is too general, only covers the basics of ADR and does not go into the substances actually processed in the company. Third: Wrong group of people. Employees who are demonstrably involved with dangerous goods (e.g. sales, scheduling or customer support) were not recorded.

Fourth: Outdated content. The training does not take into account the latest ADR amendment, such as new special regulations or changed labelling requirements. Fifth: Lack of evidence of learning success. Attendance lists without a test or comprehension question are not considered proof of the required knowledge. In the CIVAC Workspace, all five weak points are addressed: templates for each function with substance and transport-specific content, annual updating of the clause library with every ADR amendment, automated assignment of people via the HR master data, quiz function for proof of learning success and complete audit documentation. Turn reading into an assignment: Anyone who works with Excel lists today should think about switching before the next check comes. A fine cannot be averted retroactively. Even a claim involving personal injury or environmental damage cannot be relieved by subsequent file maintenance. Anyone who works preventatively not only protects the dangerous goods officer and management, but also the entire company from serious consequences. Insurers also reward clean training documentation when assessing business liability and environmental liability, which is reflected in the premium structure and also economically justifies the investment in the workspace. Some insurers actively require proof as a prerequisite for covering more serious risks in the dangerous goods sector.

A medium-sized chemical company with three production sites and a central shipping warehouse: 220 people are subject to 1.3, of which 80 are drivers with an additional ADR certificate, 30 loaders, 25 fillers, 20 dispatchers, 65 dispatchers and sales employees. Before the introduction of the workspace, the documentation effort was three employee days per quarter. With templates, automated reminders and central storage, the effort fell to half a day per quarter, and the proof rate rose from 78 to 100 percent.

A logistics service provider with eight branches and 600 employees: The central challenge was the heterogeneity of the locations. Each branch had its own training practice, some used Power Point, others external training providers, and others no structured training. After introducing uniform templates and central storage, the documentation gap no longer occurred during the next BAG inspection. A third case: A manufacturer of lithium-ion batteries with sales throughout Europe. The particularly strict regulations of UN 3480 and 3481 must be observed here. The workspace integrates the special regulations and trains the employees precisely, which was recognised as seamlessly documented during an inspection in France (TMD) and in Italy (D.M. October 6, 2009). More information about the role can be found on the CIVAC page for the Hazardous Goods Officer. In all three industries, the decisive lever was not the training itself, but rather the central, versioned storage and automated reminders. Licence the workspace for your internal representatives or have our representatives order it. In the pilot phase, we deliver a target/actual comparison of your current training landscape and a migration scheme that does not interrupt ongoing training and cleanly adopts existing evidence. The pilot phase is typically completed within four to six weeks and results in a roll-out plan for all locations.

A 1.3 instruction typically lasts three to five hours for the general topics, and the task-related training takes one to four hours, depending on the activity. External training providers charge 80 to 250 euros per participant for standard training, while tailor-made in-house training costs between 1,200 and 3,500 euros per day plus travel costs. There are also follow-up costs for refreshing every two years and for documentation maintenance. Anyone who commissions an external dangerous goods officer in the officer-as-a-service model typically receives the 1.3 training as part of the monthly package, which ranges between 350 and 1,800 euros, depending on the number of locations and participants.

The CIVAC SLA of two working days for initial documents also applies here: If you commission a 1.3 training with documentation today, the first draft will be available within two working days. The training itself is offered in webinar form, on site or as self-paced e-learning with quizzes. Licence the workspace for your internal representatives or have our representatives order it. In both models you get the same documentation quality and audit trail. For a medium-sized company with 100 to 300 employees subject to 1.3, the total savings compared to a pure law firm with classic training support is typically in the range of 40 to 60 percent per year. Audit-proof, documented, 1.3.3-ADR-proof. In addition, there is the avoidance of fines and reputational damage, which are difficult to quantify mathematically, but in practice often represent the greatest leverage because they multiply immediately in the event of damage. The workspace also makes it possible to maintain training for several representative roles (hazardous goods, hazardous substances, fire protection, occupational safety) in a uniform mechanism, so that synergies are created between the roles and duplication of work is avoided.

CIVAC's compliance platform and officer-as-a-service represents 1.3 training as a connected mechanism consisting of a person register, training templates, training protocols, audit trail and reminder system. 490 ready-to-use audit templates, 25 available representative roles and 93 controls according to ISO/IEC 27001:2022 are interlinked in such a way that the dangerous goods obligations are managed consistently alongside other compliance areas such as data protection, information security and occupational safety. The data has EU data residency and is hardened against an ISO 27001:2022 certified ISMS. Your internal dangerous goods officer uses the workspace licence, the officer-as-a-service model provides you with an external representative including an appointment certificate within two working days.

Licence the workspace for your internal representatives or have our representatives appoint them. Both models provide the same stack of evidence: appointment certificate, proof of training of the representative according to 1.8.3 ADR, 1.3 instruction protocols, specifications, annual report and audit trail. Turn reading into a mandate.: Write to info@civac.de or use the contact form on civac.de. You will receive an initial assessment of your current documentation, a gap analysis compared to the ADR 2025 requirements and a suggestion on how the next refresher training can be organised efficiently. The appointment certificate, signed, filed, verifiable. The auditor calls, the evidence is ready. The transition from an existing training provider to the workspace can also be organised in a structured manner: We take over the historical evidence, classify it according to function and date and integrate it into the new system so that there are no gaps and ongoing operations are not interrupted. This means that the first audit after migration is not a risk, but rather a consciously planned milestone in a clearly documented compliance program. It is also possible to connect to existing HR systems or learning management solutions, so that no double data maintenance is required.