ADR Training for 1.1.3.4, 1.1.3.6, LQ and EQ

Question asked to Palen

Revised on Nov 7, 2026

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ake skolenia vodicov su pozadovane pri preprave nebezpecnych veci podla 1.1.3.4 a 1.1.3.6 ? pri podlimitnom mnozstve pri obmedzeneom mnozstve pri vynatom množstve

Conclusion

For the three transport situations you listed, the required driver training is as follows:

Transport regime	ADR driver certificate under Chapter 8.2	Training required
Below-threshold load under 1.1.3.6	No	Yes: ADR Chapter 1.3 training, tailored to the driver’s duties.
Limited quantities (LQ) under 1.1.3.4 / Chapter 3.4	No	Yes: ADR Chapter 1.3 training, tailored to the driver’s duties.
Excepted quantities (EQ) under 1.1.3.4 / Chapter 3.5	No	Yes: ADR Chapter 1.3 training, except for the very small quantities under 3.5.1.4.
EQ meeting 3.5.1.4 only	No	No Chapter 1.3 training required by ADR, because only 3.5.2 and 3.5.3 apply.

An ADR driver training certificate is therefore not required for a driver operating exclusively under valid LQ, EQ, or 1.1.3.6 below-threshold conditions. However, in the ordinary LQ, EQ, and 1.1.3.6 cases, the driver must still receive and have documented function-specific ADR Chapter 1.3 training. (ADR 3.4.1, Volume 1, page 643; ADR 3.5.1.1, Volume 1, page 647; ADR 1.1.3.6.2, Volume 1, page 9; ADR 8.2.1.1 and 8.2.3, Volume 2, pages 643 and 649)

Decisive facts and assumptions

“Below-threshold quantity” is understood as carriage in packages under ADR 1.1.3.6.2, where the quantity per transport unit does not exceed the applicable threshold in 1.1.3.6.3 or, for mixed transport categories, the calculated limit under 1.1.3.6.4. The transport category is taken from Table A, column (15). (ADR 1.1.3.6.1–1.1.3.6.2, Volume 1, page 9)
“Limited quantities” means that the product is eligible for LQ carriage and that all Chapter 3.4 conditions are met, including the maximum quantity per inner packaging stated in Table A, column (7a). A value of “0” in column (7a) means LQ carriage is not permitted for that entry. (ADR 3.4.1, Volume 1, page 643)
“Excepted quantities” means that the product is authorized for EQ carriage by the code in Table A, column (7b), and that the Chapter 3.5 conditions are met. (ADR 1.1.3.4.3, Volume 1, page 9; ADR 3.5.1.1–3.5.1.2, Volume 1, page 647)

Applicable ADR provisions

1. General training rule: Chapter 1.3

Personnel employed by ADR participants whose work involves dangerous goods carriage must receive training appropriate to their duties and responsibilities. Training must be completed before the employee assumes responsibilities, unless the employee works under the direct supervision of a trained person. (ADR 1.3.1, Volume 1, page 37)

The Chapter 1.3 training consists of:

General awareness training: knowledge of the general requirements governing dangerous goods transport. (ADR 1.3.2.1, Volume 1, page 37)
Function-specific training: detailed training adapted precisely to the employee’s actual functions and responsibilities. (ADR 1.3.2.2, Volume 1, page 37)
Safety training: risks and hazards of the goods, safe handling procedures, and emergency actions, proportionate to the risk of injury or exposure. (ADR 1.3.2.3, Volume 1, page 37)
Periodic refresher training when regulatory changes occur. (ADR 1.3.2.4, Volume 1, page 37)

The employer must maintain training records and provide them to the employee or competent authority upon request. (ADR 1.3.3, Volume 1, page 37)

2. ADR driver certificate: Chapter 8.2

The normal rule is that drivers carrying dangerous goods must hold an ADR certificate issued by the competent authority, confirming completion of approved training and successful examination. (ADR 8.2.1.1–8.2.1.2, Volume 2, page 643)

For personnel involved in road transport, including drivers who do not hold a Chapter 8.2 certificate, ADR 8.2.3 directs that training must be provided in accordance with Chapter 1.3 and adapted to their responsibilities and functions. (ADR 8.2.3, Volume 2, page 649)

Step-by-step application

A. Below-threshold quantities under ADR 1.1.3.6

The exemption is available only when the load remains within the applicable limit for the transport category in Table A, column (15), or within the mixed-load calculation under 1.1.3.6.4. (ADR 1.1.3.6.1–1.1.3.6.2, Volume 1, page 9)
When 1.1.3.6.2 applies, most of Part 8 is not applicable, subject to the listed exceptions. Chapter 8.2 is not among those exceptions; therefore, the ADR driver certificate requirement does not apply to such a transport. (ADR 1.1.3.6.2, Volume 1, page 9; ADR 8.2.1.1, Volume 2, page 643)
Chapter 1.3 is not removed by the 1.1.3.6 exemption. Therefore, the driver must receive Chapter 1.3 training appropriate to the carriage operation. (ADR 1.3.1–1.3.2.4, Volume 1, page 37; ADR 1.1.3.6.2, Volume 1, page 9)

Operational result: no ADR driver certificate; documented Chapter 1.3 training is required.

B. Limited quantities under ADR 1.1.3.4 and Chapter 3.4

ADR 1.1.3.4.2 establishes that certain dangerous goods may benefit from exemptions when all Chapter 3.4 conditions for limited quantities are fulfilled. (ADR 1.1.3.4.2, Volume 1, page 9)
Chapter 3.4 states that LQ packages complying with that chapter are not subject to the other ADR provisions, except for the provisions specifically retained. Chapter 1.3 is expressly retained. (ADR 3.4.1(a), Volume 1, page 643)
Chapter 8.2.1 on the ADR driver certificate is not retained in the list of applicable provisions for LQ carriage. Consequently, an ADR driver certificate is not required solely because the driver carries LQ packages. (ADR 3.4.1, Volume 1, page 643; ADR 8.2.1.1, Volume 2, page 643)
Chapter 3.4 does retain ADR 8.2.3. This confirms the requirement for Chapter 1.3 training for personnel, including non-certified drivers, involved in the road carriage. (ADR 3.4.1(h), Volume 1, page 643; ADR 8.2.3, Volume 2, page 649)

Operational result: no ADR driver certificate; documented Chapter 1.3 training is required.

C. Excepted quantities under ADR 1.1.3.4 and Chapter 3.5

ADR 1.1.3.4.3 provides the exemption where the conditions of Chapter 3.5 for excepted quantities are met. (ADR 1.1.3.4.3, Volume 1, page 9)
For ordinary EQ carriage, Chapter 3.5 states that the goods are not subject to other ADR requirements, but specifically retains the training requirements in Chapter 1.3. (ADR 3.5.1.1(a), Volume 1, page 647)
Chapter 8.2 is not retained by 3.5.1.1. Therefore, the driver does not need an ADR driver certificate merely because they carry EQ packages. (ADR 3.5.1.1, Volume 1, page 647; ADR 8.2.1.1, Volume 2, page 643)

Operational result: no ADR driver certificate; documented Chapter 1.3 training is required.

Conditions, exceptions, and alternatives

Special ultra-small EQ exemption: ADR 3.5.1.4

A narrower exemption exists for dangerous goods assigned EQ codes E1, E2, E4, or E5 when all of the following limits are met:

maximum net quantity per inner packaging: 1 mL for liquids or gases, or 1 g for solids; and
maximum net dangerous goods quantity per outer packaging: 100 mL for liquids or gases, or 100 g for solids. (ADR 3.5.1.4, Volume 1, page 646)

For these specific very small EQ consignments, only the packaging provisions of 3.5.2 and the marking provisions of 3.5.3 apply. Chapter 1.3 is not retained. (ADR 3.5.1.4, Volume 1, page 646)

Result for 3.5.1.4: neither an ADR driver certificate nor Chapter 1.3 training is required by ADR for that transport. The 3.5.2 packaging and 3.5.3 marking conditions remain mandatory. (ADR 3.5.1.4, Volume 1, page 646)

Security-related point

Chapter 1.3 training includes the security provisions applicable to the employee’s activity. (ADR 1.3.1, Volume 1, page 37) Under 1.1.3.6, Chapter 1.10 is generally exempted, but the exemption does not apply to high-consequence Class 1 dangerous goods and to the specified Class 7 excepted packages where the activity level exceeds A2. (ADR 1.1.3.6.2, Volume 1, page 9)

No fixed five-year validity for Chapter 1.3 training

A Chapter 1.3 course is not an ADR driver certificate and does not have the Chapter 8.2 certificate cycle. The employer must provide refresher training periodically to reflect regulatory changes and must maintain the training records. (ADR 1.3.2.4 and 1.3.3, Volume 1, page 37)

Uncertainties and limits

The conclusion depends on the transport actually satisfying the selected exemption in full:

For 1.1.3.6, verify the UN number, transport category in Table A column (15), the applicable quantity threshold, and the mixed-load calculation where multiple categories are carried. (ADR 1.1.3.6.1–1.1.3.6.2, Volume 1, page 9)
For LQ, verify eligibility and the LQ maximum in Table A column (7a), together with all Chapter 3.4 packaging, marking, and operational conditions. (ADR 3.4.1, Volume 1, page 643)
For EQ, verify the EQ code in Table A column (7b) and all Chapter 3.5 requirements. The full Chapter 1.3 training exemption applies only to the special micro-quantity case in 3.5.1.4. (ADR 3.5.1.1–3.5.1.4, Volume 1, pages 646–647)

Sources

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