A dangerous goods safety adviser (Tehlikeli Madde Güvenlik Danışmanı, TMGD) is a certified expert who has passed the examination of the Ministry of Transport and Infrastructure (Ulaştırma ve Altyapı Bakanlığı) and monitors whether a company's consigning, packing, loading, filling, carriage and unloading of dangerous goods comply with ADR and the regulations. Most companies holding a dangerous goods activity certificate (TMFB) must start using an adviser's services within 30 days of obtaining the certificate.
What is the legal basis for the TMGD?
ADR 1.8.3 requires every undertaking that consigns, carries, packs, loads, fills or unloads dangerous goods to appoint at least one safety adviser, and allows contracting parties to grant exemptions for small quantities. In Türkiye this framework is applied through the Regulation on the Carriage of Dangerous Goods by Road (Tehlikeli Maddelerin Karayoluyla Taşınması Hakkında Yönetmelik, Official Gazette 18.06.2022, No. 31870); a comprehensive amendment was published in the Official Gazette of 6 February 2025 (No. 32805). The service can be provided by a TMGD employed by the company itself or by an authorised dangerous goods safety advisory organisation (TMGDK).
Which companies must have an adviser?
The obligation is directly linked to the dangerous goods activity certificate (TMFB). Carriers obtain a TMFB regardless of quantity. Companies that received, consigned, packed, loaded, filled or unloaded 20 tonnes or more of dangerous goods in the last calendar year must also obtain a TMFB. Those handling Class 1 goods other than 1.4S, or Class 7 goods outside the scope of ADR 1.7.1, must obtain the certificate regardless of quantity. For consignees and unloaders, operations carried out under the ADR 3.3, 3.4 and 3.5 exemptions are not counted towards the 20-tonne threshold.
| Company profile | TMFB | TMGD service |
|---|---|---|
| Carrier whose vehicles listed on its authorisation certificate have a total minimum capacity of 50 tonnes or more | Required | Required |
| Carrier only, total minimum capacity below 50 tonnes | Required | Not required |
| Consignee only, or tank-container/portable tank operator | Required | Not required |
| Consignor, packer, loader, filler (20 tonnes or more per year) | Required | Required |
A company obtaining a TMFB for the first time and subject to the advisory obligation must start receiving the service within 30 days. Because the TMFB is issued per address, each branch, warehouse and site is assessed separately.
What are the adviser's duties?
- Monitoring compliance with dangerous goods legislation and advising management
- Preparing the annual activity report; the report is submitted via e-Devlet within the first four months of the following year
- Preparing an accident report following the model in ADR 1.8.5.4 for accidents meeting the criteria in ADR 1.8.5.3 that occur during packing, filling, loading, unloading or carriage; the report is submitted to the Ministry within 30 days of the accident
- Ensuring that staff receive training under ADR 1.3 before starting work and every two years
- Preparing a security plan under ADR 1.10.3.2 where required
- Drawing up written procedures, instructions and checklists and keeping them up to date
- Checking that the regulations are observed when selecting subcontractors and that the required documents and equipment are on board the vehicle
The regulation also defines the amount of service: at least 18 hours per month for each TMFB. The adviser visits the company at least once a month according to a plan notified to the Ministry in advance, and each visit is confirmed on e-Devlet by the 15th of the following month. The information and documents underlying the activity assessment report are kept for five years.
How do you become a TMGD?
- Complete TMGD training at a training organisation authorised by the Ministry.
- Sit the examination held by the Ministry of Transport and Infrastructure.
- Successful candidates receive a certificate valid for five years. Under ADR 1.8.3.16, if the adviser passes a renewal examination in the final year, the certificate is extended by another five years from its expiry date.
- The company assigns the adviser to its TMFB via e-Devlet.
If an assignment ends, the company must assign a new adviser within 15 days, or within 30 days if the termination was made by the Ministry.
Common mistakes
- Preparing an accident report only for accidents involving injuries; property and environmental damage are also covered. What to do at the scene is explained in ADR accidents and spills.
- Appointing an adviser on paper but not keeping visit records
- Overlooking the need for a separate TMFB and adviser when a new warehouse is opened
In dangerous goods (ADR) transport, the carrier's TMFB and adviser assignment are among the first documents requested before a contract is signed.