Instruction according to ADR 1.3: Contents, deadlines, evidence legally secure

The instruction in accordance with Chapter 1.3 ADR applies to all persons involved in the transport of dangerous goods. The obligation is anchored in Section 1.3.1 ADR as well as in Section 8 of the Dangerous Goods Officer Ordinance (GbV) and Section 6 of the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways (GGVSEB). Anyone who loads without documented instruction risks fines of up to 5,000 euros according to Appendix 7 GGVSEB and personal liability of the management according to Section 130 OWiG.

The scope of obligations is broad and extends from the dispatcher to the shipper to the shipping clerk. This guide shows who exactly needs to be trained, which three modules the training must include, how long the repetition period lasts and which form of proof is valid before BAG control and audit.

The central regulation is Section 1.3.1 ADR: All persons whose area of ​​responsibility relates to the transport of dangerous goods must be instructed in accordance with their responsibilities and tasks. The scope of application includes road (ADR), rail (RID), inland shipping (ADN) and, accordingly, air (IATA-DGR) and sea (IMDG Code).

Nationally, the obligation is specified in Section 6 GGVSEB and assigned to the supervision of the dangerous goods officer in Section 8 GbV. The dangerous goods officer monitors the implementation of the training and documents the training evidence in the annual report in accordance with Section 8 Paragraph 5 GbV.

The obligation applies regardless of whether the company transports dangerous goods according to the exemptions according to Section 1.1.3.6 ADR (1000 point rule) or fully. Even in the case of exemptions, the obligation to provide instruction remains to a reduced extent.

The entrepreneur is responsible within the meaning of Section 2 Number 14 GGVSEB. The management can delegate operational implementation, but retains organisational responsibility in accordance with Section 130 OWiG. Anyone who does not collect the mandatory circle systematically risks fines and personal liability in the event of damage.

CIVAC displays the mandatory circle as a role inventory in the workspace. The dangerous goods officer receives a verifiable overview of which employees need to be instructed in which module and with what deadline.

Section 1.4 ADR conclusively defines those involved in the transport of dangerous goods. In particular, senders, packers, loaders, fillers, carriers, unloaders and recipients are obliged to provide instruction. In addition, there is the owner of the tank container or portable tank and the operator of a tank wagon.

Specifically, in practice this applies to: clerks in shipping who create waybills and transport documents, dispatchers who plan tours, warehouse employees who put together shipping units, forklift drivers who load, as well as employees in goods receiving who unload or sign off on receipt of goods.

Managers are also included Obligatory circle as far as they give instructions on how to handle dangerous goods. Managing directors and branch managers are often overlooked, but according to Section 9 OWiG, they are parties to liability and therefore need to be instructed.

Drivers with a valid ADR certificate according to Chapter 8.2 ADR are not included in the mandatory group, as they have completed their own, more extensive training. Drivers without an ADR certificate, for example for exemption transport, fall under 1.3 again.

In the CIVAC Workspace you maintain a training matrix by name for each location and each function. The matrix links person, task, module and deadline. Anyone who changes location automatically inherits the appropriate deadline, new employees appear in the follow-up with a target date.

Section 1.3.2 ADR divides the instruction into three modules, which must be taught in total. Module 1 is the general introduction with the basic regulations of the ADR, the classes, the labelling, the danger labels and the obligations of those involved.

Module 2 is the task-related training. It conveys the knowledge required for the specific activity. A packer learns the packaging instructions P001 ff., a shipper learns how to secure loads in accordance with Section 7.5 ADR, and a dispatcher learns the prohibitions on mixed loading in accordance with Section 7.5.2 ADR.

Module 3 is safety training. It covers the risks and dangers of the substances to be transported, the correct behaviour in the event of an accident, first aid measures, the use of protective equipment in accordance with 8.1.5 ADR and firefighting with the means to be carried.

For substances in class 7 (radioactive substances), a radiation protection module is added in accordance with 1.7.2.5 ADR. For Class 1 (explosives) and Class 6.2 (infectious substances), there are increased task training requirements.

CIVAC maintains 490 ready-to-use audit templates, including training plans according to the three modules, participant lists, knowledge tests and training certificates. The appointment certificate, signed, filed, verifiable also applies to the training documentation of the dangerous goods officer.

The initial instruction must take place before starting work. Until the training has been completed, the person concerned may only carry out tasks relevant to dangerous goods under the supervision of a trained person. The interim solution must be documented in the training plan.

Section 1.3.2.4 ADR does not specify a fixed repetition period. A regular refresher that takes changes in the regulations into account is required. In practice, a two-year rhythm has been established, which corresponds to the entry into force of the ADR amendments on January 1st of odd-numbered years.

Event-related instructions are required when changing activities, introducing new substances or packaging, after near-accidents and after complaints from BAG, professional associations or property insurers. The reason and the content must be documented.

The annual safety training according to Chapter 1.10 ADR must be distinguished from the general 1.3 training. It concerns substances with high risk potential and trains those involved in protection goals against unauthorized use. Both duties are listed separately in the training plan.

In the CIVAC Workspace, each training entry automatically triggers the next deadline. The resubmission takes effect 90, 30 and 7 days before expiry. The auditor calls, the evidence is ready. because the deadline list is updated daily with the personnel base.

Section 1.3.3 ADR requires that documentation of the training be kept and retained by the employer. The proof must be presented at the request of the responsible authority, which in Germany is regularly the Federal Office for Logistics and Mobility (BALM, formerly BAG).

Mandatory contents of the proof are: name and function of the person instructed, date of the training, content and modules (1, 2, 3), name of the person giving the instruction, duration in hours and signature of the participant. A general collective list without reference to a module is not sufficient.

The retention period is at least five years in accordance with Section 8 Paragraph 5 GbV in conjunction with Section 257 HGB. If proceedings are ongoing or in the event of a claim, the deadline is actually extended until completion. Recommendation: store all evidence systematically in the personnel file and at the same time with the dangerous goods officer.

Electronic evidence is permitted if authenticity and legibility are ensured for the entire storage period. A qualified electronic signature or an audit-proof workflow with a time stamp are sufficient means.

In the CIVAC Workspace, every proof is saved as a versioned document with a time stamp, module tag and personal reference. The annual report from the dangerous goods officer automatically pulls the data and brings them together in accordance with Section 8 Paragraph 5 GbV. Audit-proof, documented, § 8 GbV-proof.

Even with exemptions in accordance with Section 1.1.3 ADR, the obligation to provide training generally remains, but to a reduced extent. Anyone who transports exclusively according to the 1000 point rule (1.1.3.6 ADR) trains on the calculation, the labelling requirement and the means of transport requirements.

Limited Quantities (3.4 ADR) and exempt quantities (3.5 ADR) are often mistakenly viewed as completely exempt. In fact, the obligation to train those involved in the specific packaging and labelling rules remains.

For substances in class 7 (radioactive substances), Section 1.7.2.5 ADR also applies. Those involved must be trained in the basics of radiation protection, in the activity limits and in emergency measures. The connection to the radiation protection officer must be established.

Class 1 (explosives) and class 6.2 (infectious substances including UN 3373) require increased attention in task training. UN 3373 is widely used in hospital dispatch and is often underestimated in practice.

Special cases are stored as additional modules in the CIVAC Workspace. The training matrix differentiates between basic instruction, safety training 1.10 and special case modules, so that each person completes exactly the module that their task requires.

The Federal Office for Logistics and Mobility carries out operational and roadside inspections in accordance with Section 8 GGVSEB and Directive 95/50/EC. As part of the operational control, the officials check the appointment of the dangerous goods officer, the annual report and the training certificates in accordance with 1.3 ADR.

Typical complaint number 1: no training matrix by name, but only a collective list. Complaint number 2: Evidence without reference to the module, so it is not clear whether the person has received the task-related training. Complaint number 3: expired refresher, often for existing employees in administrative functions.

Complaint number 4: lack of training for new employees. Anyone who only trains new people after weeks runs the risk of fines according to Annex 7 GGVSEB number 1.5 (up to 5,000 euros per violation). Complaint number 5: no security instruction 1.10 for quantities subject to security.

In the event of a fine, the management will be held liable in accordance with Section 30 and Section 130 OWiG. Insurance coverage from traffic liability may be limited in the case of organisational fault. Reputational damage particularly affects companies with major customers in the pharmaceutical and chemical sectors.

CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. In the Officer-as-a-Service model, an appointed dangerous goods officer takes on the annual reporting obligation and training supervision.

A reliable training plan includes six elements: role inventory, module matrix, dates, trainers, knowledge test and evidence. The role inventory lists all functions related to dangerous goods. The module matrix links function and module (1, 2, 3 and special cases).

The dates are bundled in an annual training calendar. The combination of classroom training for Module 1 and Module 3 as well as computer-supported training for the task-related content is recommended. The mix allows greater depth with reasonable effort.

Trainers are usually the dangerous goods officer himself, external training providers or certified internal multipliers. The trainer's qualifications must correspond to the appointment certificate of the dangerous goods officer or be proven by a comparable certificate.

The knowledge test at the end of each training course is not prescribed in 1.3 ADR, but is standard practice. A short test with 10 to 15 questions ensures understanding and is additional proof of the effectiveness of the training in the audit.

The evidence is evaluated as part of the annual report of the dangerous goods officer in accordance with Section 8 Paragraph 5 GbV. In the CIVAC Workspace, the system generates this report from the training data so that the dangerous goods officer does not have to collect everything manually in the last quarter.

If you cannot say in 30 seconds today how many people involved according to 1.3 ADR you currently employ and when the last instruction was, the level of training is not auditable. Start with an inventory: role inventory, last training data, evidence per person.

CIVAC delivers the training plan, the module matrix and the evidence templates in 2 working days. In the Workspace model, you licence the 490 audit templates and carry out the instruction yourself. In the Officer-as-a-Service model, an appointed dangerous goods officer takes over the annual report and training supervision.

Both models use the same pool of templates, the same EU data residency and the same ISO/IEC 27001:2022 certified platform. You decide based on capacity, not platform change. It is also possible to switch between Workspace and Officer-as-a-Service in the current year without data migration.

Others run compliance like a filing cabinet. We run it like software. Instead of Excel lists and email attachments, you receive a versioned training matrix, follow-ups with escalation and an audit export that meets the BAG requirements.

Turn reading into a mandate. Write to info@civac.de or use the contact form on civac.de. We check your role inventory, suggest the right model and provide the training plan within 2 working days.