Dangerous Goods Risk Assessment: Step-by-Step UK Guide

If you handle, store or move dangerous goods, you’re balancing safety, legal compliance and business continuity every day. Fires, toxic releases and reactive incidents don’t just harm people and the environment; they also trigger costly downtime, seizures of freight and enforcement action. Yet many assessments fall short—out‑of‑date inventories, unclear SDS information, forgotten non‑routine tasks, and transport paperwork treated separately from workplace controls.

The fix is a structured, evidence‑based risk assessment that connects the dots between what you use, how you use it, who is exposed and what can go wrong—then applies proportionate controls. This guide shows you how to build a defensible assessment for UK operations, aligned to COSHH and DSEAR for workplaces and the Carriage of Dangerous Goods/ADR, RID, IMDG and IATA rules for transport, so your controls protect people and pass scrutiny.

You’ll get a clear, step‑by‑step method: define scope and legal duties; build your inventory and gather SDS; classify substances (UN class, packing group, CLP, WELs); map activities and exposure routes; develop credible scenarios; rate risks; apply the hierarchy of controls; add transport‑specific checks (packing, marking, labelling, documentation, segregation, security); plan emergency response; verify competence and DGSA coverage; document with a practical template; implement and track actions; review and update; and handle special cases like lithium batteries and infectious substances. Let’s start.

Step 1. Define your scope and UK legal duties (COSHH, DSEAR, CDG/ADR, RID, IMDG, IATA)

Start by fixing the boundaries of your dangerous goods risk assessment and the regulations it must satisfy. Be explicit about what’s in scope and which legal frameworks apply to workplace use/storage versus off‑site transport.

Scope the operation: locations, processes, tasks, modes (road/rail/sea/air), quantities, containers, contractors and interfaces.
Lifecycle coverage: delivery, storage, transfer, use, cleaning, maintenance, waste and transport.
Assumptions/exclusions: list any, with justification, so reviewers understand limits.

Your core workplace duties sit under COSHH (identify hazardous substances, assess exposure, control risks, inform/train, record if you have 5+ employees, and review) and, where there’s fire/explosion potential, DSEAR. For transport you must meet the Carriage of Dangerous Goods (CDG) Regulations and the modal rules: ADR (road), RID (rail), IMDG (sea) and IATA (air). If activities span workplace and carriage, ensure the assessment demonstrates compliance with both sets of duties and the controls join up.

Step 2. Build your dangerous goods inventory and collect safety data sheets (SDS)

Build a single inventory as the backbone of your dangerous goods risk assessment. Walk the site, check purchase orders and talk to users to capture everything you bring in and anything generated by work (for example welding fume, wood or silica dust, vapours), across all tasks, shifts and locations. Obtain current Safety Data Sheets from suppliers for every substance.

Identification: Product/mixture name and supplier; SDS version/date, emergency details.
Location/containers: Storage/usage location; container type and capacity.
Quantities: Quantity on site and typical throughput.
Use/generation: How used or generated (sprayed, cutting, cleaning, waste).
Hazards: Hazards from label/SDS; CLP pictograms; any WELs.
Transport IDs: Where relevant, UN number and proper shipping name.

Step 3. Classify substances and identify hazards (UN class, packing group, CLP, WELs)

With your inventory complete, classify each substance so hazards are unambiguous for workplace use and for carriage. Use UN data to meet transport rules and CLP data to meet COSHH; don’t mix them up. Capture workplace exposure limits (WELs) and hazards generated by the process (for example dusts, fumes or vapours). This turns SDS details into actionable inputs for your dangerous goods risk assessment.

UN classification: UN number, proper shipping name, class/division and packing group, plus any subsidiary hazards.
CLP classification: signal word, hazard statements and pictograms; flag sensitisers, carcinogens and reprotoxins if stated.
Exposure limits: record any WELs to guide monitoring and control selection.
Process‑generated hazards: list dust, fume, vapour, mist or gas arising from tasks.

Step 4. Map activities, people and exposure routes, including non-routine work

Now connect each substance to real work. Walk the job: where it’s received, stored, decanted, used, cleaned up and shipped. For a robust dangerous goods risk assessment, capture who is present, what they do, how exposure could occur, and for how long, across all shifts and locations.

Map tasks and locations: receiving, transfer/decanting, mixing, sampling, loading/unloading, cleaning, waste handling.
People and groups: operators, maintenance, cleaners, lab staff, drivers, contractors, visitors and anyone nearby (public interface).
Exposure routes: inhalation, skin/eye contact, ingestion, injection; note aerosols, splashes and contaminated surfaces.
Frequency/duration and scale: how often, how long, quantities handled, shift patterns.
Plant/conditions: open vs closed systems, LEV/ventilation, indoors/outdoors, confined spaces.
Non‑routine work: breakdowns, changeovers, shutdowns, tank cleaning, spill response, decommissioning.

Record this per substance–activity pair to feed scenario building and risk rating next.

Step 5. Identify credible incident scenarios and check existing controls

Turn each substance–activity pair into a small set of credible “what could go wrong” scenarios. Focus on realistic loss-of-containment, ignition and exposure events (including transport interfaces) rather than extreme hypotheticals. For each scenario in your dangerous goods risk assessment, note the initiating event, conditions that make it worse, and plausible consequences for people, property and the environment.

Decanting spill: hose/valve failure during transfer.
Vapour ignition: static discharge around flammable liquids.
Incompatible mix: acid and caustic stored or disposed together.
Over‑pressure: blocked venting on drums/IBCs.
Gas release: cylinder knock‑over or valve shear.
LEV failure: aerosol/fume exposure during spraying or cutting.
Hot work adjacent to solvent use: fire/flashback.
Confined CO2 build‑up from dry ice: asphyxiation risk.

Now test what already controls those scenarios and whether evidence shows they work. Verify design, maintenance and behaviours, not just paperwork.

Engineering: closed transfer, segregation/bunding, earthing/bonding, LEV; examine and test LEV at least every 14 months by a competent person.
Systems: labelling, storage plans separating incompatibles, access control, permits to work, housekeeping and “vacuum don’t sweep” for dust.
Monitoring: checks against any WELs; alarms/meters where used.
People: training/briefings for operators, contractors and drivers.
Emergency: spill kits, eyewash/showers, drills and call‑out details.

Step 6. Evaluate likelihood and consequence to rate each risk

With credible scenarios defined, convert them into ranked risks using evidence, not guesswork. Base likelihood on frequency and duration of the task, amount handled, potential for exposure (inhalation/skin), the presence of ignition sources, and reliability of controls; use monitoring data, WELs, maintenance records and incident/near‑miss history. Base consequence on health effects (acute/chronic from SDS and any WEL exceedance), fire/explosion potential under DSEAR, environmental harm and off‑site impact. Use a simple matrix (for example 3×3 or 5×5): risk = likelihood x consequence, and consider both most‑likely and worst‑credible outcomes.

Set clear criteria: define qualitative anchors for likelihood and consequence relevant to your operation.
Score inherent risk: rate before controls to reveal raw exposure.
Assess control assurance: note integrity of LEV, containment, segregation, earthing, training.
Score residual risk: rate after existing controls; flag any High/Intolerable items.
Prioritise actions: use the residual rating to drive control selection in Step 7 and deadlines.
Record evidence and assumptions: cite SDS sections, WELs, tests, inspections and data used.

Step 7. Select controls using the hierarchy: eliminate, substitute, engineer, administer, PPE

Use your residual risk ratings to choose proportionate, evidence‑based controls. Apply the hierarchy from most to least reliable, using SDS guidance, WELs and task reality, and document why each choice is suitable within your dangerous goods risk assessment.

Eliminate: remove the substance or step altogether, or avoid generating the hazard.
Substitute: choose a safer chemical or form (for example, water‑based in place of isocyanate paints; pellets instead of dusty powders).
Engineer/contain: enclose and use closed transfer; install LEV hoods/booths to capture fume, mist or vapour; examine and test LEV at least every 14 months by a competent person.
Change the process: lower temperatures to cut vapour, minimise quantities, and automate repetitive handling.
Systems of work: restrict access; plan storage/segregation (keep acids and caustics apart); use correct containers and labelling; permits for non‑routine work.
Cleaning/housekeeping: spill kits ready; “vacuum, don’t sweep” for dust; plan waste storage and disposal.
Information and training: brief workers and contractors on hazards, exposure limits, controls, PPE and emergency actions.
PPE (last line): select and maintain specific items per SDS (for example, glove material, RPE filter type); use with other controls, not instead of them.

Step 8. Add transport-specific compliance checks (packing, marking, labelling, documentation, segregation, security)

Once workplace risks are controlled, make sure your dangerous goods risk assessment also proves you can legally move the goods. Map each shipment leg and apply the correct modal rules so loads aren’t rejected at the gate or stopped en route. Build these checks into your assessment and pre‑dispatch process.

Confirm mode and rules: Identify each leg and apply the right code — ADR (road), RID (rail), IMDG (sea), IATA (air) — alongside UK CDG duties.
Packing compliance: Follow the relevant packing instructions; verify packaging compatibility, closures and quantity limits per package.
Marking and labelling: Apply the correct UN number, proper shipping name and hazard labels; ensure marks match the documentation.
Documentation: Complete required dangerous goods transport documents for the mode and keep details consistent with labels and SDS.
Segregation and stowage: Check compatibility/segregation requirements and load plans; keep incompatibles apart across packages and load units.
Security: Where applicable under ADR/RID, implement a security risk assessment and plan for high‑consequence loads, and brief drivers on security measures.

Step 9. Plan emergency response and security measures for spills, fire and toxic release

Your dangerous goods risk assessment isn’t complete until credible scenarios translate into a rehearsed emergency plan and proportionate security. Base plans on SDS guidance and your scenarios (spill, vapour ignition, gas release, incompatible mix). Make it obvious who does what, how to raise the alarm, what kit to use, how to isolate the hazard, and when to evacuate and call the emergency services. Build in security measures that deter theft/misuse and protect information about consignments.

Roles and alarms: name incident leads, deputies and first‑aiders; define alarm/evacuation routes and muster points.
Immediate actions: stop work, make safe (isolate power, close valves), shut down ventilation if required, cordon off and restrict access.
Spill/fire kit: provide and maintain absorbents, neutralisers, inert media, extinguishers, eyewash/showers; choose “dust‑free” cleanup methods (vacuum, not sweeping).
Information at hand: SDS, inventory, site plan, WELs and contact numbers available to responders and the fire service.
Decontamination and waste: safe collection, labelling and disposal of cleanup residues.
Training and drills: brief workers and contractors on emergency actions; practise and log drills; correct gaps.
Security controls: restrict access to stores and loading areas, verify drivers, protect documentation, and for ADR/RID where applicable maintain a security risk assessment and plan with driver security briefings.

Step 10. Verify controls and competence (inspection, testing, monitoring, training, DGSA)

Controls only work if they’re maintained, measured and used by competent people. Build verification into your dangerous goods risk assessment so you can prove controls are effective and staff are capable.

Inspect and test controls: examine containment, storage and ventilation; ensure LEV is examined and tested at least every 14 months by a competent person, with defects fixed.
Monitor exposure vs WELs: sample when indicated; keep results and trigger reviews if limits are approached or exceeded.
Health surveillance: provide where required and share collective results with workers.
Information and training: brief staff and contractors on hazards, controls, PPE and emergency actions; train correct use of controls and PPE; maintain a training matrix and refreshers.
DGSA oversight: where required under CDG/ADR, appoint a DGSA to review consignments, documentation, incidents and security arrangements.
Records and assurance: retain test certificates, monitoring data, training logs and corrective actions to demonstrate ongoing control.

Step 11. Document the assessment with a practical template and an action plan

Make your dangerous goods risk assessment audit‑ready and usable. COSHH requires you to record your assessment if you have 5+ employees, and it’s good practice even with fewer. Keep it concise, evidence‑based and version‑controlled, with sign‑off and a next review date. One template should cover workplace controls and carriage requirements so nothing falls through the gaps.

Scope & duties: what’s covered and which laws apply.
Inventory & SDS: substance list with SDS version/date.
Classification: UN data, CLP hazards and any WELs.
Tasks & scenarios: substance–activity pairs and credible events.
Risk ratings: inherent/residual, assumptions and evidence cited.
Controls & assurance: hierarchy applied; inspections, LEV 14‑month tests, monitoring.
Transport checks: packing, marking/labelling, documents, segregation and security plan.
Training & roles: competence matrix, emergency roles, DGSA coverage.
Action plan: action, priority, owner, due date, status, evidence link; escalate any high residual risks.

Step 12. Implement actions, assign owners and track completion

Controls only work when they’re delivered. Move your action plan from the dangerous goods risk assessment into your management system so every task has an accountable owner, resources and a deadline. Link each action to the specific scenario it mitigates and define measurable completion criteria (for example, test results, training records, labelled photos). Give owners the authority and budget to act, and schedule work around shifts and planned shutdowns.

Named owner and deputy: clear accountability to avoid delays.
Due date and priority: aligned to residual risk rating.
Resources: time, budget, materials and any procurement/contractor needs.
Dependencies/permits: prerequisites, isolations and permit-to-work requirements.
Status and evidence: RAG status; attach LEV test reports, monitoring data, photos.
Close-out/sign-off: competent person (and DGSA where required) verifies effectiveness.

Step 13. Review, audit and update after changes, incidents or annually

Treat your dangerous goods risk assessment as a living document. Build a cycle into your system: an at‑least‑annual review plus routine spot audits to confirm controls, transport checks and records match reality. Base decisions on evidence such as LEV examinations, exposure monitoring, training matrices and incident logs; update the assessment, action plan and competence requirements as needed.

Operational change: people, process, substance, equipment or quantity.
Work pattern change: new tasks, locations, storage/packaging or transport mode.
Information change: SDS revisions or updated workplace exposure limits.
Control performance: failures or trends from tests/monitoring/inspections.
Events: incidents, near misses, drills or enforcement findings.

Version‑control, reissue and brief workers and contractors; keep sign‑off records.

Step 14. Address common special cases (lithium batteries, infectious substances, limited and excepted quantities)

Some consignments demand extra scrutiny because their hazards and regulatory triggers are atypical. Add dedicated lines in your dangerous goods risk assessment for these cases, link them to the applicable mode(s) and make sure packaging choices, handling rules and emergency plans reflect the specific risks.

Lithium batteries (Class 9): Risks include thermal runaway, fire, explosion and toxic gases. Control ignition sources, keep away from combustibles, ensure robust fire detection/response, and apply correct classification and modal packing/marking before carriage.
Infectious substances (Class 6) and dry ice: Use sealed containment, restrict access and plan decontamination and waste. Where dry ice (Class 9) is used as a refrigerant, manage CO2 build‑up with good ventilation and avoid confined spaces.
Limited quantities (LQ) and excepted quantities (EQ): These reduce some carriage requirements but not the hazard. Verify eligibility and quantity limits per mode, use the correct marks, keep segregation and safe handling, and maintain workplace controls under COSHH/DSEAR regardless.

Wrap up and next steps

A solid dangerous goods risk assessment connects your inventory, tasks, people and credible scenarios to proportionate controls that stand up to COSHH and DSEAR in the workplace and CDG/ADR, RID, IMDG and IATA in transport. If you’ve mapped activities, rated risks with evidence, applied the hierarchy of controls, built transport checks into dispatch, and rehearsed emergencies, you’re protecting people and keeping shipments moving. Keep it live: verify performance, close actions, and review after change, incidents or at least annually.

If you want confidence your assessment is both practical and compliant, get expert support and upskill your team. Explore flexible training (air, sea, road, rail, lithium batteries, DGSA) and post‑course coaching with Logicom Hub. We’ll help you turn this method into day‑to‑day habits that prevent harm and keep your dangerous goods moving without surprises.