Do I need a Dangerous Goods Safety Adviser (DGSA)?

By Tim Hourahine, Director and Principal DGSA, DGSA Solutions Limited · Updated 11 October 2026 · Applies to carriage by road in Great Britain under ADR 2025 and the CDG Regulations 2009

The short answer. If your business consigns, packs, fills, loads, unloads or carries dangerous goods by road as part of its main or secondary activity, ADR 1.8.3 requires you to appoint a DGSA, unless an exemption applies. Plenty of smaller operations do qualify for an exemption, but it has to be worked out against your actual loads and activities. It should never be assumed.

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Who has to appoint a DGSA

Under ADR 1.8.3.1, an undertaking whose activities include the carriage of dangerous goods by road, or the related packing, filling, loading or unloading, must appoint a DGSA. In Great Britain, this is enforced through the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (the CDG Regulations).

That covers more businesses than many people expect:

Carriers and haulage operators who move dangerous goods by road.
Consignors, meaning the business that hands the goods over for carriage. Consignor-only businesses were brought into the requirement, with a transitional period that ended on 31 December 2022.
Packers and fillers, including contractors who pack dangerous goods for a manufacturer.
Loaders and unloaders, including warehouses and distribution centres that load vehicles with dangerous goods.

A business that only receives dangerous goods, with no consigning, packing, loading or carrying of its own, is not caught in the same way.

When you might not need one

ADR 1.8.3.2 sets out exemptions. In broad terms, you may not need to appoint a DGSA if:

Your loads stay below the small-load thresholds in ADR 1.1.3.6. The quantity of dangerous goods on each vehicle is calculated in points by transport category, and you only qualify if you never go over the threshold.
Dangerous goods are not your main or secondary activity, and you only occasionally carry or handle them in low-risk circumstances. A construction company that sometimes collects drums of fuel for its own sites is a typical example.

GOV.UK guidance also notes that dangerous goods moved in limited quantities, short distances inside an enclosed site, or in private vehicles may fall outside the requirement.

Be careful with exemptions. They depend on the exact goods, the quantities carried and how often you do it. A business that qualifies for the small-load exemption today can lose it the day a single bigger load goes out, or when a second type of dangerous goods goes on the same vehicle. The calculation needs to be repeated, not assumed.

Questions to ask yourself

Do we consign, pack, fill, load, unload or carry dangerous goods by road?
Is that a main or secondary activity of the business, or genuinely occasional?
What is the largest quantity of dangerous goods that goes on one vehicle, and what transport category is it?
Do we ever mix different dangerous goods on the same vehicle?
Do we handle hazardous waste that is classed as dangerous goods for transport?

If you can't answer these with confidence, that is usually the sign that you need advice before relying on an exemption.

What a DGSA actually does

The role is set out in ADR 1.8.3.3. A DGSA is responsible for:

Monitoring compliance with the rules on carriage of dangerous goods across the business.
Advising the business on carriage of dangerous goods.
Preparing an annual report for management on the business's activities in the carriage of dangerous goods.
Checking procedures for identifying goods, the equipment used, training of staff, emergency procedures, and the use of subcontractors.
Investigating and reporting on accidents, incidents and serious infringements.

Appointing a DGSA does not shift legal responsibility away from the business. The DGSA advises and monitors, and the business still has to act on the advice.

Who can be your DGSA

The DGSA can be a member of your own staff or an external consultant. Either way, they must hold a valid DGSA vocational training certificate for the classes and mode of transport they advise on. The certificate lasts five years and is renewed by passing an examination.

Watch the explainer video

I cover the main points in this short video, including what can happen if you need a DGSA and haven't appointed one.

This video uses a digital avatar of Tim Hourahine. The script and content were written and reviewed by Tim. Watch on YouTube · Full playlist

Common questions

What happens if I need a DGSA and don't have one?

Failing to appoint a DGSA when one is required is a breach of the CDG Regulations and can lead to enforcement action by the enforcing authorities. It can also leave you exposed if there is an incident, because you will be unable to show you took the requirement seriously.

Can one of my own employees be the DGSA?

Yes, provided they hold a valid DGSA certificate for the right classes and have the time and authority to do the job properly. Many smaller businesses appoint an external DGSA instead, because training and keeping an employee qualified is not always practical.

Does answering my question make you my DGSA?

No. Ask The DGSA answers individual questions. It does not appoint us as your DGSA and does not cover the monitoring and annual report that an appointed DGSA provides. If you need a formal appointment, email us for a quote.

Does this apply to sea, air or rail?

This page covers carriage by road in Great Britain. Other modes follow different rules, such as IMDG for sea and IATA for air. Ask The DGSA does not cover those through this service.

Not sure where you stand?

Tell us what you carry, in what quantities and how often, and you'll get a written answer referenced to ADR 2025, from £18. If it turns out you need more than an answer, we'll say so.

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Sources and further reading

This page is general information. It is not legal advice and does not replace advice on your own circumstances.