Preparing dangerous goods for road transport in NSW is not just about packing a box and attaching a label. It is a legally regulated process under the Australian Dangerous Goods Code, and the person who prepares the goods — the consignor — carries significant legal responsibility for getting it right.
This guide explains the key obligations of consignors in NSW, what “preparing dangerous goods for transport” actually involves, and who needs formal training in this area.
Who Is a Consignor?
Under the NSW Dangerous Goods (Road and Rail Transport) Act 2008, a consignor is defined as the person or business that consigns goods for transport — that is, the person who prepares the goods and hands them over to the carrier. This includes:
- Manufacturers who dispatch DG products from their facility
- Distributors and wholesalers who pack and label DG for dispatch
- Retailers dispatching DG to customers
- Any business that arranges for DG to be collected and transported by a carrier
Importantly, the consignor does not have to physically drive the vehicle — they are the party responsible for the preparation of the goods before transport. This means that office staff, warehouse supervisors, and logistics coordinators who arrange DG shipments are consignors under the law, even if they never touch the goods directly.
What Does “Prepare for Transport” Mean?
Preparing dangerous goods for road transport covers a series of specific steps that must be completed correctly before the goods can be lawfully loaded onto a vehicle:
1. Classification
Correctly identifying the DG class, division, packing group, and UN number for the goods being transported. This must align with the ADG Code classification for the specific substance.
2. Packaging
Using approved packaging that meets the ADG Code requirements for the specific class and packing group. Not all containers are suitable for all DG — the packaging must be rated and approved for the goods it contains.
3. Labelling
Attaching the correct dangerous goods labels to each package. Labels must show the correct DG class diamond, UN number, and proper shipping name. Incorrect or missing labels are a common infringement trigger.
4. Marking
In addition to labels, packages must be marked with the proper shipping name, UN number, net quantity, and consignor details as required by the ADG Code.
5. Segregation
Ensuring that incompatible DG classes are not packed together or placed in proximity. The ADG Code segregation table governs which classes can and cannot be co-loaded.
6. Consignment Note
Completing a dangerous goods consignment note with all mandatory fields — UN number, proper shipping name, class/division, packing group, quantity, and emergency contact information. This document must travel with the goods and be available in the driver’s cab throughout the journey.
7. Emergency Procedure Guide (EPG)
The consignor is responsible for ensuring that the appropriate Emergency Procedure Guide is available for the driver. The EPG provides first-response guidance for the specific DG being carried and must be accessible in the cab.
Consignor Liability Under the Chain of Responsibility
The Chain of Responsibility (COR) provisions of the Heavy Vehicle National Law explicitly include consignors as a party who can be held liable for transport incidents. This means that if a packaging failure, labelling error, or incorrect consignment note contributes to an incident on NSW roads, the consignor faces potential liability — not just the driver or the transport company.
COR penalties for businesses can reach $3 million for corporations. Individual liability for consignors can include fines up to $300,000 and imprisonment in the most serious cases.
Who Needs the Prepare for Transport Course?
The Prepare for Transport of Dangerous Goods course at Kells Safety Centre (RTO 91528) is designed for:
- Logistics coordinators and dispatch staff who arrange DG shipments
- Warehouse supervisors responsible for outbound DG consignments
- Compliance officers in businesses that regularly ship DG
- Operations managers responsible for transport compliance
- Any employee whose role involves preparing DG for transport, labelling, or completing consignment notes
The course is not just for drivers. In many businesses, the people with the most exposure to consignor liability are office and warehouse staff — not the truck driver who picks up the load.
What Does the Course Cover?
The Prepare for Transport course at Kells covers all aspects of the consignor’s obligations under the ADG Code, including:
- DG classification and the ADG Code structure
- Approved packaging requirements by class and packing group
- Correct labelling and marking — what each label must show and where it must be placed
- Completing the dangerous goods consignment note correctly
- Segregation and compatibility requirements
- Emergency Procedure Guide requirements
- COR obligations and consignor liability
- NSW Dangerous Goods (Road and Rail Transport) Act requirements
Frequently Asked Questions
Is the Prepare for Transport course the same as the DG Licence?
No. The DG Licence (TLILIC0001) is for drivers who transport dangerous goods by road. The Prepare for Transport course is for consignors — the people who pack, label, and prepare DG for transport. Drivers who also act as consignors (for example, owner-operators who pack their own loads) may benefit from completing both.
How long does the Prepare for Transport course take?
The Prepare for Transport of Dangerous Goods course at Kells Safety Centre is a one-day course, delivered face-to-face at Wetherill Park (Western Sydney) and Wollongong. Participants receive a Statement of Attainment upon successful completion.
Does the course cover all DG classes?
Yes — the course covers the full range of DG classes under the ADG Code, with practical emphasis on the classes most commonly transported by road in NSW including Class 3 (flammable liquids), Class 5.1 (oxidisers), Class 6.1 (toxic substances), Class 8 (corrosives), and Class 9 (miscellaneous).
Is the consignment note the same as a bill of lading?
No. A bill of lading is a general freight document used in commercial transport. A dangerous goods consignment note is a specific document required by the ADG Code for all placard loads of DG transported by road. It has mandatory fields that a standard bill of lading does not include.
Does your team prepare dangerous goods for transport? The Prepare for Transport course at Kells covers all consignor obligations under the ADG Code. Enrol in the Prepare for Transport Course
Key Takeaways
- Consignors — the people who prepare DG for transport — carry significant legal liability under NSW law and the COR provisions
- Preparation includes classification, packaging, labelling, marking, segregation, consignment notes, and EPG provision
- Getting any of these steps wrong creates infringement risk and COR liability
- The Prepare for Transport course at Kells Safety Centre (RTO 91528) covers all consignor obligations in a one-day face-to-face format
Step-by-Step: The Consignor’s Pre-Transport Checklist
Before any dangerous goods consignment leaves your site in NSW, the consignor must complete the following steps. This checklist is drawn directly from ADG Code 7.9 requirements.
- Classify the goods correctly — identify the correct UN number, class, subsidiary risk, packing group, and proper shipping name using the ADG Code dangerous goods list
- Select compliant packaging — use only packaging that meets the ADG Code specification for the UN number and packing group. Check packaging markings for the UN performance specification mark
- Label packages correctly — apply the correct class diamond label and any subsidiary risk labels. For limited quantities, apply the LQ mark. Ensure labels are legible and durable
- Determine if it is a placard load — use ADG Code Table 1.3 to calculate whether your consignment exceeds placard threshold quantities. If it does, a placarded vehicle and a licensed DG driver are required
- Prepare the consignment note — complete a dangerous goods consignment note containing all mandatory information including UN number, proper shipping name, class, subsidiary risk, packing group, quantity, and emergency contact details
- Provide emergency information — provide the driver with the relevant Emergency Procedure Guide (EPG) or ensure the vehicle carries emergency information for all DG classes being transported
- Confirm the driver holds a current DG licence — if the load is a placard load, confirm the driver holds a current Dangerous Goods Driver Licence (TLILIC0001) issued by the NSW EPA before the vehicle departs
Common Consignor Mistakes That Lead to Enforcement Action
NHVR officers and NSW EPA inspectors see the same consignor errors repeatedly. The most common:
- Missing or incomplete consignment notes — especially missing emergency contact numbers
- Incorrect UN number or proper shipping name on the consignment note
- Packages with no label, the wrong label, or a label from an old edition of the Code
- Placard load dispatched without confirming the driver holds a current DG licence
- Emergency Procedure Guide not provided to or carried by the driver
- Segregation not checked — incompatible DG classes mixed in the same consignment
Frequently Asked Questions
Does a consignor need to be trained in dangerous goods?
Yes. NSW WHS legislation and the ADG Code require anyone who prepares dangerous goods for transport to be competent in doing so. The Prepare for Transport of Dangerous Goods course at Kells Safety Centre (RTO 91528) is the nationally accredited training for consignors. It covers classification, packaging, labelling, consignment notes, and emergency information requirements in full.
What must a dangerous goods consignment note contain?
Under ADG Code Chapter 11, a dangerous goods consignment note must contain: the consignor’s and consignee’s name and address; the proper shipping name; UN number; class and subsidiary risk; packing group; total quantity (by mass or volume); number and type of packages; emergency contact name and 24-hour phone number; and a declaration that the goods are properly classified, packed, marked, and labelled. Missing any of these elements is a breach.
What is a placard load?
A placard load is a quantity of dangerous goods that meets or exceeds the threshold quantities in ADG Code Table 1.3. Once a consignment is a placard load, additional requirements apply: the vehicle must display DG placards, the driver must hold a current Dangerous Goods Driver Licence (TLILIC0001), and the vehicle must carry an Emergency Information Panel (EIP). Consignors must calculate whether their consignment constitutes a placard load before dispatch.
Can a consignor use any packaging for dangerous goods?
No. Dangerous goods must be packed in packaging that has been tested and approved to the performance specification required by the ADG Code for the relevant UN number and packing group. Packaging must carry a UN performance mark. Using non-compliant packaging — including reusing damaged packaging — is a breach of the ADG Code and can result in enforcement action against the consignor.
What is Chain of Responsibility and how does it apply to consignors?
Chain of Responsibility (COR) provisions in the Heavy Vehicle National Law mean that consignors, loaders, and receivers share legal responsibility for heavy vehicle safety compliance — not just drivers and operators. If a consignor dispatches a dangerous goods load with an incomplete consignment note, incorrect labelling, or without confirming the driver holds a DG licence, the consignor can face prosecution and significant penalties even if they were not in the vehicle. COR liability is why consignor training is not optional.
How long must consignment notes be kept?
Under ADG Code requirements, consignment notes must be retained by the consignor for a minimum of 2 years from the date of the consignment. Transport operators must also retain their copies. These records may be requested during audits or investigations following a dangerous goods incident.
For regulatory guidance, refer to Safe Work NSW and the National Heavy Vehicle Regulator (NHVR).
Kells Safety Centre (RTO 91528) delivers the Prepare for Transport, DG Licence, DG Awareness, and full transport safety course suite at Wetherill Park and Wollongong. View All Training Courses
