Regulations & safety
Do you need a DGSA?
Widely believed to apply only to companies that send dangerous goods. It reaches considerably further — and receiving a tanker is the activity that catches people.
This is the duty that most often surprises a methanol buyer, because the common understanding of it is wrong. The Dangerous Goods Safety Adviser requirement is widely believed to apply to companies that send dangerous goods. It applies to considerably more than that, and it has since the end of 2022.
If your site receives bulk methanol deliveries, you are an unloader of dangerous goods. That may put you in scope for appointing a DGSA, whether or not you ever consign anything.
Key points
- The requirement falls on any undertaking whose activities include consigning, carrying, packing, filling, loading or unloading dangerous goods.
- Unloading was among the activities brought clearly into scope from the end of 2022.
- A site taking bulk methanol deliveries is an unloader. That is the trigger most buyers miss.
- The adviser may be an employee or an external appointment, but must hold a valid vocational training certificate.
- Establish your position before the first bulk delivery, not after an inspection.
The activities that bring you into scope
ADR 1.8.3 requires each undertaking whose activities include the carriage of dangerous goods, or the related packing, filling, loading or unloading, to appoint one or more safety advisers. The consignor role was added to that list from the end of 2022, and the practical effect of the current wording is that the duty reaches well beyond hauliers.
| If you… | You are… | In scope? |
|---|---|---|
| Hand methanol to a haulier for carriage | Consignor | Yes |
| Move methanol in your own vehicles | Carrier | Yes |
| Fill IBCs or drums | Filler / packer | Yes |
| Load packages or containers onto a vehicle | Loader | Yes |
| Receive a bulk tanker delivery and discharge it | Unloader | Yes |
| Receive small packages only, below threshold | Consignee | Depends — take advice |
“We don't transport anything, so DGSA doesn't apply to us” is the sentence to watch for. Unloading is a listed activity. A site that takes a methanol tanker is performing it.
What a DGSA actually does
The adviser's function is to monitor compliance, advise the undertaking on the carriage of dangerous goods, and produce an annual report to management on the undertaking's activities in that area. They must also investigate and report on any accident affecting safety during carriage, loading or unloading.
The appointment can be an employee who holds the qualification, someone with another role in the business who also holds it, or an external consultant. What is not optional is that the person holds a valid vocational training certificate obtained by examination.
Practical steps
- Establish your position honestly. List the activities your site actually performs, including unloading, and check them against the scope.
- Decide internal or external. For most single-site industrial users receiving deliveries, an external adviser on a retainer is proportionate.
- Appoint before the first delivery. The requirement does not begin when someone notices it.
- Use them properly. An adviser who reviews your offloading procedure and your training records before an incident is worth considerably more than one who writes an annual report you file unread.
- Keep the annual report. It is a required record and it is the first thing asked for.
Suppliers are generally well informed here and many will tell you plainly that taking bulk makes you an unloader. Some will not, because it is not their duty and not their risk. Treat the answer as useful input rather than as your compliance position, and confirm it independently.
This page summarises the regulatory landscape so that you know which questions to ask and which duties to check. It is not safety, legal or engineering advice. Work from your supplier's current GB-format safety data sheet, HSE published guidance, and competent advice for your own site and processes.
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