Asbestos waste and ADR 2025
ADR 2025: asbestos waste by road
ADR 2025 treats asbestos waste according to whether it is bound so that respirable fibres cannot escape during transport, or contains free asbestos that could release hazardous quantities of fibres. The change to pay particular attention to is Special Provision 678, which allows certain kinds of free-asbestos waste to be carried in bulk under specified conditions.
1. Decide whether ADR applies
Under Special Provision 168, asbestos fixed or immersed in a binder—such as cement, plastic, asphalt, resin or mineral ore—is outside ADR if hazardous quantities of respirable fibres cannot escape during carriage. Certain manufactured articles can also be outside ADR when packed so that fibres cannot escape.
HSE cautions that waste which could release hazardous quantities of respirable fibres should be transported as dangerous goods. It gives asbestos cement sheets as an example of bound waste and insulation board as an example of fibrous waste. HSE asbestos guidance · ADR 2025
2. Classify free-asbestos waste
Where free asbestos can present a fibre-release hazard, the relevant ADR entries are:
- UN 2212, ASBESTOS, AMPHIBOLE — Class 9, Packing Group II. This covers amosite, tremolite, actinolite, anthophyllite and crocidolite.
- UN 2590, ASBESTOS, CHRYSOTILE — Class 9, Packing Group III.
The waste description and UN number must be based on the asbestos type and what is actually being transported. The former names “blue asbestos”, “brown asbestos” and “white asbestos” should not replace the current proper shipping names. HSE asbestos guidance
3. Normal route: package the waste
If using the normal packaged-goods route, the Dangerous Goods List specifies P002 packaging and special provision PP37. PP37 permits 5M1 bags; all bags must be carried in a closed vehicle or container, or inside a closed rigid overpack. ADR 2025, packing provisions
HSE describes certified UN packaging, often double-bagged, for fibrous asbestos waste. For large items that cannot be put into normal UN packaging without disturbing the material, HSE describes secure double wrapping in heavy-gauge polythene with suitable dangerous-goods identification. The wrapping must remain intact throughout handling and transport. HSE asbestos guidance
4. New ADR 2025 option: Special Provision 678 bulk carriage
SP 678 is not a general permission to carry asbestos waste loose. It permits certain free-asbestos waste to be carried under ADR Chapter 7.3, subject to its conditions. The waste must:
- Travel from where it was generated to a final disposal facility; intermediate storage is allowed only if the container-bag is not unloaded or transferred.
- Fit one of the listed categories: specified roadworks waste; contaminated soil; contaminated objects from damaged buildings; or specified building and construction waste that cannot be packaged under the applicable P002 instruction because of its size or mass.
- Be kept separate from other asbestos waste and from any other hazardous or non-hazardous waste.
- Be carried as a full load.
The special provision also requires the transport document to meet ADR 5.4.1.1.4. It must include “Carriage under special provision 678”, the required dangerous-goods description and a description of the waste. It must be accompanied by the container-bag technical data sheet showing dimensions and maximum mass, and, where applicable, the unloading procedure required by CV38. ADR 2025 SP 678 and documentation provisions · ADR 2025 summary of changes
For some specified waste categories, ADR requires container-bags to be placed inside a second container-bag of the same type. The Chapter 7.3 provisions also address the container-bag design and precautions against puncture or tearing; CV38 includes checks on the load compartment and unloading arrangements. Confirm the precise requirements for the waste category and loading method before using this route. ADR 2025, Chapter 7.3
5. Marking, documentation and training still matter
The SP 678 bulk route has its own document requirements. Under the normal packaged route, ADR requirements for package marks and labels, transport documents, vehicle or container placarding, orange plates and driver qualifications depend on the shipment and applicable exemptions.
HSE notes that the ADR load-limit exemption thresholds are 333 kg for UN 2212 and 1,000 kg for UN 2590 for the relevant transport categories. Exceeding the applicable threshold affects which provisions apply; being below it should not be treated as a blanket exemption from safe packaging, handling or function-appropriate dangerous-goods training. Check the current ADR rules and the actual load, including any mixed load. HSE asbestos guidance