Before a drum of solvent or a box of lithium batteries ever reaches a trailer, the rules have already decided what it must be packed in and what symbols it must wear. Packaging and labelling are the physical layer of dangerous goods control - and the law places them squarely on the supplier’s side of the chain. Understanding that division of responsibility matters to hauliers, because the carrier’s protection at an inspection is largely ‘the consignor’s system was correct, and I checked it’.
The packaging rules start with classification. The UN system assigns each dangerous substance or article a class defining the type of danger, and a packing group - PG I, II or III - grading the level of danger within it. Together, class and packing group dictate how the goods must be packaged, labelled and carried: the inner and outer packaging, the suitability of packaging materials, and the marks and labels the package must bear. A PG I substance - the highest danger - demands the most robust approved packaging; PG III the least. There is no ‘strong box’ judgment call: the packaging type is a function of the classification, and using the wrong one is non-compliance even if the box survives the journey.
The responsibility for this sits with the consignor - the person or business shipping the goods - who is responsible for classifying, marking and packaging the dangerous goods. Equipment gets its own rule: all machinery or equipment containing dangerous goods should be classified for transport using the most appropriate entry in the dangerous goods list, and transport must comply with that entry’s provisions. The generator set with fuel in its tank and the forklift with its battery are not exempt freight; they are classified items with packaging and marking provisions of their own.
Once packed, the package speaks. Packaging must bear the correct labels and markings appropriate for the substance and the package - the hazard diamonds communicating the class, the UN number identifying the substance, the packaging specification marks showing the packaging itself is an approved type, and orientation and handling marks where required. Each element answers a different question for a different reader: the diamond tells the warehouse worker and the firefighter what kind of danger; the UN number lets anyone look up the exact substance; the packaging mark proves the box itself was tested for this duty.
The consignor owns the packaging and labelling duty, but the driver at the collection bay is the last pair of eyes before the goods enter the transport chain. The working checks are practical: do the packages bear the marks and labels the documentation describes - a transport document listing a UN number against packages with no hazard labels is a stop; is the packaging intact and appropriate-looking for the goods - damaged, leaking or obviously improvised packaging never gets waved through; do the quantities and package count match the document; and is anything loaded that is not on the paperwork at all. The driver is not expected to re-classify the chemistry - that is the consignor’s legal job - but ‘it looked wrong and I carried it anyway’ is a position no one wants to explain after an incident.
One growing corner deserves a mention: waste. Waste electricals, returns and recycling loads regularly contain dangerous goods - batteries above all - in unknown condition, and the packaging rules still apply. The provisions for waste batteries include specific packaging requirements designed around damaged and defective cells: strong outer packaging, protection against short circuit and movement. A carrier collecting waste streams should know whether the load is declared as dangerous goods and packaged to the applicable provisions, because ‘it’s only waste’ is exactly the assumption behind the waste-sector fire statistics.
Class and packing group choose the packaging; the consignor must classify, mark and pack correctly; the package must wear the labels and marks that let every handler read its hazard; and the carrier’s collection check is the last control before the load rolls. The system works when each party does its own part - and it fails fastest when the carrier assumes the supplier’s part is none of their business.
Every busy depot eventually faces the awkward pallet: goods that should be declared, arriving with no diamond, no UN number, no matching entry on the paperwork. The rule for that moment is simple and worth writing into the goods-in procedure: unlabelled means undeclared, and undeclared means it does not get loaded until the consignor puts it right. The pressure to wave it through - the trunk is waiting, the customer is chasing - is exactly how carriers inherit consignor offences. A two-minute phone call at the bay, a note on the collection record, and the load leaves when the paperwork and the packages agree. That small piece of stubbornness is the cheapest dangerous goods control a carrier owns.