Contents
In brief
- ADR Chapter 1.3 training applies to everyone whose duties concern the carriage of dangerous goods, including temporary workers and subcontractors.
- It has three parts: general, function-specific and safety. Added to this is security awareness (Chapter 1.10).
- Training takes place before the person takes on the duties. Until then, a new person may work only under the direct supervision of someone trained.
- ADR does not say how many years should pass before repeating the training, but it does require periodic refresher training.
- The person running the training confirms it in writing, and the employer keeps the records.
Who does Chapter 1.3 training cover?
Chapter 1.3 of ADR concerns persons employed by participants in the carriage whose duties concern the carriage of dangerous goods.
The Polish Act on the transport of dangerous goods (the Act) goes further than ADR 2025. Article 14(1) requires training for persons employed by a participant or performing tasks on its behalf. An agency worker packing paint on the loading bay during the season is subject to training just like a permanent warehouse employee.
In 8.2.3, ADR gives examples of such persons: employees of the carrier or consignor, personnel who load or unload, staff of forwarding and shipping companies, and drivers who take part in the carriage without holding an ADR certificate. The last case covers, for example, the driver of a van carrying cylinders under the 1.1.3.6 exemption.
| Job | Responsible under ADR for | Focus of function-specific training |
|---|---|---|
| Warehouse employee picking orders | choice of packagings, packages | marking and danger labels, damaged packagings |
| Packing employee | packing, limited quantities (LQ) | packing instructions, LQ limits, the LQ mark |
| Forklift operator, loading | loading and securing | mixed loading prohibitions, securing, checking the vehicle before loading |
| Dispatch or customer service | transport document | data in the transport document, instructions in writing for the driver |
| Goods-in | unloading | checking packages, what to do about a leak |
| Carrier's dispatcher | choice of vehicle and driver | vehicle equipment, ADR certificates, orange-coloured plates |
Training does not cover people who have nothing to do with dangerous goods. An accountant issuing an invoice for a fuel delivery does not need Chapter 1.3 training. A sales employee who enters the UN number into the system and prints the transport document does.
Chapter 1.3 training and the ADR driver course
These are two different duties. The driver of a vehicle carrying dangerous goods holds a driver training certificate (the Act calls it an ADR certificate), issued after a course and an examination under Chapter 8.2. The certificate is valid for 5 years (ADR 8.2.2.8.2).
Chapter 1.3 expressly refers to Chapter 8.2 for the training of vehicle crew and to section 1.8.3 for the training of the adviser. Chapter 1.3 training is for everyone else. It does not end with a state examination or a certificate issued by an authority. The employer organises and documents it.
What does Chapter 1.3 training consist of?
ADR divides training into three parts (1.3.2). The scope of each depends on the responsibilities and duties of the person concerned, so one programme for a whole plant rarely works.
General awareness training (1.3.2.1)
Employees must be familiar with the general requirements of the rules on the carriage of dangerous goods: classes, UN numbers, the role of the transport document and marking, the duties of the participants. This is the common base for the whole shift.
Function-specific training (1.3.2.2)
This is the most important part and the one most often neglected. It must correspond directly to the employee's duties. A packer learns on the packagings they pack and on the goods you actually ship. If the carriage also involves sea or air transport, the employee must know the requirements of those modes.
Safety training (1.3.2.3)
Employees learn about the hazards posed by the dangerous goods they work with, safe handling and emergency response procedures. The scope depends on the risk: training around acetylene cylinders looks different from training around cartons of aerosols in limited quantities.
Security of dangerous goods (1.10.2)
Chapter 1.3 training and refresher training must also include security awareness, that is, preventing theft or misuse of the goods (1.10.2.1). If the company carries high consequence dangerous goods and has a security plan, employees must know that plan as far as it concerns their duties (1.10.2.2). The employer keeps records of this training in the same way as the others (1.10.2.4).
When to train and how often to repeat the training
The first training takes place before the person takes on the duties (ADR 1.3.1, Article 14(1) of the Act). Until they have completed it, a new person may perform tasks not covered by training only under the direct supervision of a trained person. In practice, this means a new warehouse employee does not pack orders of dangerous goods alone in the first week.
ADR does not set the frequency of refresher training. It only says that training must be periodically supplemented to take account of changes in the regulations (1.3.2.4). The Act says the same in Article 14(1) and likewise gives no number of years.
In my view, the regulations themselves set a sensible rhythm: ADR changes every two years. The current edition has applied since 1 January 2025, and the next amendments are due to enter into force on 1 January 2027. Refresher training with each new edition of ADR is the minimum. In addition, I train whenever an employee changes job, a new product appears or a new method of dispatch is introduced.
What ADR 2027 will change in Chapter 1.3
According to the amendments adopted by the UNECE Working Party (document ECE/TRANS/WP.15/274), from 1 January 2027 Chapter 1.3 is due to cover all persons involved in the activities of the participants, not only their employees. The record-keeping duty will also cover these persons. In Poland, Article 14 of the Act already covers persons acting on behalf of a participant, so little will change for companies that train everyone on the loading bay.
How to document training so that it stands up to an inspection
The regulations say three things. The person running the training confirms in writing that the participants have been trained (Article 14(3) of the Act). The employer keeps the records and makes them available to the employee or the competent authority on request (ADR 1.3.3). Records are verified when a new employment starts.
ADR leaves the period for keeping records to the competent authority. The Polish Act gives no such period for Chapter 1.3 training records. I recommend keeping them for the whole of the employee's employment and for at least 5 years afterwards. That is how long the company keeps the adviser's annual report (Article 16(1)(2) of the Act), so training records and reports cover the same period.
The regulations do not impose a form of document. In audits, I most often see attendance lists that do not show what the training was about or who it covered. This is why I recommend that the document includes:
| Item in the document | Why |
|---|---|
| name and job title | training must correspond to the duties of a specific person |
| date and duration | confirms that training took place before duties began |
| scope: general, function-specific, safety, security | shows all parts of 1.3.2 and 1.10.2 |
| programme with a list of topics and goods (UN numbers, classes) | links function-specific training to the actual goods |
| ADR edition used for the training | makes it easier to plan refresher training |
| trainer and their qualifications, for example adviser's certificate number | Article 14(2) of the Act sets out who may run training |
| result of a knowledge check | evidence that the employee has understood the material |
| signatures of the trainer and the participant | Article 14(3): written confirmation of training |
| planned date of refresher training | 1.3.2.4: training is periodically supplemented |
Who can run Chapter 1.3 training?
Article 14(2) of the Act gives two options: a person with a safety adviser's certificate, or a person with the knowledge and education needed for the training to be carried out properly. So your DGSA can run it, but so can an experienced warehouse manager who knows the regulations and can show it.
Training run by the adviser has one practical advantage: the adviser monitors whether employees are properly trained anyway and describes this in the annual report (ADR 1.8.3.3). For more on when a company must have an adviser, see my article does your company need a DGSA.
Most common mistakes in Chapter 1.3 training
- One general session for everyone, with no function-specific part. The packer and the dispatcher get the same material, although they do completely different work.
- A new employee starts work with training "planned for next month" and no direct supervision by a trained person.
- No training for temporary and seasonal workers.
- An attendance list with no programme and no trainer's signature.
- Training to an out-of-date edition of ADR, for example 2019 materials in 2026.
- Goods-in staff do not know what danger labels and the numbers on an orange-coloured plate mean. A good starting point is my article on how to read the ADR orange plate.
Legal basis: ADR 2025 (Polish text: Dz.U. 2025 item 642): Chapter 1.3 (1.3.1, 1.3.2.1-1.3.2.4, 1.3.3), 1.10.2.1-1.10.2.4, 8.2.2.8.2, 8.2.3. Polish Act of 19 August 2011 on the transport of dangerous goods (consolidated text, Dz.U. 2024 item 643): Articles 14 and 107 and Annex 1, item 6.4. ADR 2027 amendments: ECE/TRANS/WP.15/274.
If you want to put training in your plant in order, start with a list of the people who have contact with dangerous goods and match them to the jobs in the table above. I will prepare a programme for your goods and records ready for inspection as part of Chapter 1.3 ADR training.
FAQ
Questions and answers
Can Chapter 1.3 training be done online?
ADR 2025 does not specify the form of Chapter 1.3 training. The Polish Act requires it to be run by a person with an adviser's certificate or with the knowledge and education needed for the training to be carried out properly, and requires training to be confirmed in writing. The function-specific part is in any case best done on the loading bay, using real packagings and documents.
Do temporary agency workers need training too?
Yes. Article 14(1) of the Polish Act on the transport of dangerous goods covers persons employed by a participant in the carriage and persons performing tasks on its behalf. The form of employment does not matter. What counts is what the person does with dangerous goods.
Does training from a previous employer count?
It can, but it needs checking. ADR requires training records to be verified when a new employment starts (1.3.3). Function-specific training relates to particular duties, so for different goods or a different job it usually has to be supplemented.
What is the fine for missing training found at an inspection?
Annex 1 to the Polish Act on the transport of dangerous goods provides for PLN 2,000 for failing to train persons performing tasks related to the carriage of dangerous goods (item 6.4). The fine is imposed by the Voivodeship Road Transport Inspector (WITD) by administrative decision. Legal status: consolidated text of the Act, Dz.U. 2024 item 643.
Legal status: October 2026This article is for information only. It does not replace an analysis of a specific consignment.