Dangerous goods transport in New Zealand is governed by a specific land transport rule, and it reaches many businesses that do not consider themselves in the dangerous goods trade. Paint, aerosols, adhesives, LPG, fuel, pool chemicals, lithium batteries and many cleaning products are all captured.
The obligations fall on the consignor as well as the carrier, and consignors are the ones most often unaware they have any.
Classification
Dangerous goods are classified into classes reflecting the nature of the hazard — explosives, gases, flammable liquids, flammable solids, oxidising substances, toxic and infectious substances, radioactive material, corrosives, and a miscellaneous class that includes lithium batteries.
Classification determines everything downstream: packaging, marking, documentation, quantity thresholds and segregation. It comes from the safety data sheet and the UN number for the substance, and getting it wrong invalidates the rest of the chain.
Lithium batteries deserve particular mention. They are captured, the rules differ by battery type, state of charge and whether they are packed with or contained in equipment, and the volume of e-commerce shipping means a great many businesses handle them without realising the requirements.
What the consignor must do
- Classify correctly and identify the UN number, proper shipping name, class and packing group.
- Use approved packaging appropriate to the class and packing group, in good condition.
- Mark and label packages with the correct class labels and identifiers.
- Provide documentation to the carrier — the dangerous goods declaration identifying what is being carried, in what quantity, with emergency information.
- Not consign incompatible goods together where segregation rules apply.
- Tell the carrier. Handing dangerous goods to a carrier without declaring them is both an offence and how drivers and emergency responders get hurt.
What the carrier must do
- Carry the documentation in the vehicle, accessible to emergency services.
- Placard the vehicle where quantities exceed thresholds.
- Segregate incompatible goods in the load.
- Ensure the driver holds the required endorsement where applicable.
- Carry required equipment including fire extinguishers appropriate to the load.
- Secure the load and use suitable vehicles and equipment.
Driver requirements
Drivers carrying dangerous goods above threshold quantities require a D endorsement on their licence, obtained through an approved course and subject to renewal.
Below the thresholds, an endorsement may not be required, but the driver still needs to know what they are carrying, what the risks are and what to do in an emergency. That is a health and safety obligation regardless of what the transport rule requires.
Thresholds and the domestic exemption trap
Quantity thresholds determine when the full requirements apply. Below them, reduced requirements operate.
The trap is aggregation. A business carrying several different dangerous goods, each individually below a threshold, may exceed the aggregate limit. Businesses running service vans with fuel, gas cylinders, aerosols and solvents on board frequently exceed thresholds without any single item looking significant.
Interaction with hazardous substances rules
Transport rules cover goods in transit. Once the goods arrive and are stored or used at a workplace, the hazardous substances regulations apply — inventory, safety data sheets, certified handlers, location compliance certificates and so on.
A business that gets the transport right and ignores the storage side, or the reverse, is only half compliant. The two regimes use similar concepts and different thresholds, which is a common source of confusion.
Emergency response
Emergency response information must accompany the load, and the driver must know where it is and what it says. In an incident, the documentation is what tells Fire and Emergency what they are dealing with before they approach.
Businesses should also have their own procedure for a spill or incident in transit, including who to notify and what not to do.
Practical guidance
- Audit what you actually send and receive against the classification rules — most businesses find something they did not realise was captured.
- Get the safety data sheets and read the transport section, which gives the classification directly.
- Train the people who pack and dispatch, not just drivers.
- Check aggregate quantities on service vehicles.
- Confirm your freight forwarder or courier accepts what you are sending — many decline certain classes, and undeclared consignments are how goods end up abandoned or fined.
- For air and sea freight, further and stricter international rules apply on top.
NZTA publishes the dangerous goods rule and guidance material, WorkSafe publishes hazardous substances information, and the EPA publishes substance classifications — all free.
General information only, not legal advice. Confirm requirements with NZTA.
