Empty packaging that has contained dangerous goods requires careful handling and proper disposal procedures. As a professional driver, understanding how to manage these materials safely is an important part of your responsibilities under ADR regulations.
Not As Empty As You Think
Even when packaging appears empty, it’s important to remember that residual amounts of dangerous substances often remain. These residues can still pose significant hazards, whether from flammable vapours in “empty” fuel drums or traces of corrosive chemicals in cleaning product containers. This is why empty packaging must be treated with the same level of care as full containers until properly cleaned and certified as safe.
Legal Requirements
Under ADR regulations, uncleaned empty packaging must be closed as securely as when it was full and display the same hazard labels and UN numbers. The transport document should mark these as “EMPTY UNCLEANED” or “EMPTY PACKAGING WITH RESIDUE OF…” followed by the details of the last contained substance. This ensures that emergency responders know what hazards might be present if there’s an incident.

Cleaning Procedures
Before disposal or recycling, packaging must be properly cleaned and certified as safe. This often involves:
- Thorough washing with appropriate cleaning agents
- Neutralisation of any remaining chemical residues
- Removal of all hazard labels once certified clean
- Documentation of the cleaning process
Only facilities authorised to handle dangerous goods waste should carry out these procedures. As a driver, you should never attempt to clean hazardous packaging yourself unless specifically trained and authorised to do so.
Disposal Routes
Clean packaging may be recycled through standard waste streams if certified safe. However, packaging that cannot be adequately cleaned must be disposed of as hazardous waste through licensed facilities. Your company’s Dangerous Goods Safety Advisor (DGSA) can provide guidance on appropriate disposal routes for specific types of packaging.
Environmental Considerations
Proper disposal isn’t just about safety; it’s also about environmental protection. Many types of packaging can be recycled if properly cleaned, reducing waste and environmental impact. However, attempting to recycle contaminated packaging can cause serious problems at recycling facilities, so certification of cleanliness is essential.
Final Thoughts
When in doubt about the disposal of any empty dangerous goods packaging, consult your DGSA or safety manager. It’s better to take extra precautions than risk an incident through improper handling. Remember that even empty packaging can pose serious hazards until properly cleaned and certified; treat it with appropriate respect.
By following these guidelines and your company’s specific procedures, you can ensure that empty packaging is handled safely and disposed of responsibly, protecting both people and the environment.