Date of Report : 15 April 1999
Reporting period : Scheduled Project Output
Author of report : D. Green/P. Sewell/K. Taylor/A.V. Kolik/K. Broersma/G.P. Chugunova

Introduction of a compulsory consignment note for use in the domestic carriage of goods by road in the Russian Federation

1. Background 3
2. Own Account Operations & Exemptions 5
3. Functions and Objectives of the Standard Document 8
4. Costs and Benefits 9
5. Issuing of the Consignment Note11
6. Responsibilities of the Transport Operator13
7. Procedure for Using the Documents14
8. Fraud prevention20

1. Background

• In the consultants document �Report on legal framework � Road Transport Sector in RF� dated April 1998, reference was made to the proposed introduction of a compulsory road transport consignment note to be used in domestic transport. This report develops that proposal. It sets out objectives to be met by such a note. It also contains suggested procedures for its use and comments about its design.

• It is important to note at this stage that the design and implementation of the document will be a difficult and complicated process. It will be essential to discuss these proposals with as many interested parties as possible � especially with operators who may be required to use such a document in the future. It will be advisable to hold a pilot exercise � perhaps in selected regions or using selected operators � in order to check that

• The introduction of such a compulsory road transport consignment note would present an additional administrative burden - primarily on the carrier but also on the consignor and consignee. This is believed to be justified as long as the commercial and enforcement advantages are expected to outweigh the cost. However, to achieve its objectives, the scheme needs to be managed and administered properly right from the start.

• It is proposed that the requirement to use the note should apply equally to own account operators and to hire and reward hauliers. The fact that an own account operation is being undertaken should be indicated on the consignment note. Consideration should be given to providing a detailed definition of own account in the law.

• It is suggested that it will be in the public interest to exempt a number of operations from the compulsory road transport consignment note. The suggested exemptions are listed and discussed in section II.

• Under the existing civil code of the Russian Federation, (Chapter 40 article 785), there is a requirement for contracts of carriage to be evidenced by the existence of a consignment note. The contents of this document are not, however, specified in recent Russian law. The consultants understand that the carrier has no liability in respect of the goods unless a contract is in existence. Where such a contract exists the carrier may be liable for loss or damage and possibly consequential loss. No limits of liability are specified.

• A lack of documentation � confirming the nature of the goods, the parties to the transaction and their individual limits of liability - makes it virtually impossible to insure goods at the present time. It is likely that operators and their customers will wish to introduce insurance of goods in the near future, to avoid significant financial losses in the event of theft or accidental damage. Insurance of goods (in transit) may be required, for example, by European and American trading partners.

• It would be necessary at an early stage to resolve problems concerning the jurisdiction of officials monitoring the scheme. Inspection of records at a company�s premises would be done by the Russian Transport Inspectorate (RTI) and/or Taxation agencies. It is recommended that the tax authorities should also be given access to these documents, because the information refers to commercial business activities for which taxes are due. For example, if the tax authority is investigating the affairs of a transport company, they would first check with the road transport association or document-issuing body to find out the numbers of the consignment notes issued to that operator. When the inspectors visit the operators premises, they can ask to see either an unused consignment note or a record of a transport job being completed, with a corresponding entry for the carriage charge in the accounts, for each of the consignment notes.

• Checks at the roadside are performed by the GIBDD, part of the Internal Affairs Ministry. It is likely that GIBDD would levy an appropriate fine if the documents were incorrect or missing. For the scheme�s full potential to be realised, it is essential that this information is also passed to RTI and the tax authorities (see also section IV on �Costs and Benefits�).

• Consignment notes will also be of use to the tax authority in a different way. If an investigation was being made into the financial affairs of a factory or an importer, the inspectors could first visit the offices of transport companies which supply or move finished goods. The transport company will have a record of every item that has been moved in and out of the factory in its consignment notes. The tax inspectors can check if there is any record of the factory paying for these items in the accounts.

• Exemptions

• The consultants suggest that consideration should be given to exempting the following vehicles and operations:

1. Small vehicles

2. Goods which are part of a consignment carried under alternative rules for documentation

The Government may wish to consider exempting certain categories of goods transport operations in order to avoid introducing unnecessary, bureaucratic complications. This would concern the following types of operators or vehicles:

• Railway, tramway and metro operators
• Vehicles involved in snow clearance, gritting and salting of roads and airports
• Vehicles involved in repairs to water, gas, sewerage, telephone, communal heating and electrical systems
• Vehicles involved with highway construction maintenance and control
• Vehicles used by medical services e.g. ambulances, hospital supplies
• Vehicles used by the Police, Fire Department and military
• Vehicles used in emergencies or rescues
• Vehicles used by Federal and Local Government for non-commercial purposes

• Radio and television broadcasting
• Emergency breakdown vehicles
• Vehicles undergoing road tests for technical development, repair or maintenance purposes
• Postal services (and maybe private carriers carrying letter and small parcels similar to those carried by the post office�such as DHL and TNT�conditional upon the same information that is noted on the consignment note being recorded elsewhere)
• Non commercial carriage of goods for the personal use of the driver or his family e.g. moving household
• Vehicles used for training drivers
• Vans transporting cash / credit cards / bank documents / precious metals in transit � banks keep comprehensive records and it is not safe to stop these vehicles for checks.

In general these proposed exemptions relate to activities performed by federal or local government bodies. In most cases the transport operations of these businesses do not make a direct charge to customers. In some cases their work is so important and unpredictable (e.g. repairs to water supply and metro systems) that it is not feasible to maintain detailed financial plans and records of journeys taken.

The functions and objectives of the consignment note fall into three areas:

1. relating to official procedures and controls
2. meeting commercial requirements
3. safety related matters.

1. Official Procedures and Controls

• To provide a control mechanism to ensure that operators of goods vehicles hold the appropriate licence
• To provide an audit trail of road transport operations for taxation purposes
• To enable the collation of transport statistical data, if required.

2) Commercial Functions and Objectives

• To provide evidence that goods had been consigned to a carrier
• To provide evidence that goods had been received in good condition by a consignee
• To enable the collection of carriage charges and other costs
• To provide evidence of a loss for insurance purposes, if required.

• To indicate in the case of special goods such as dangerous substances or temperature controlled foodstuffs, technical details relating to the special considerations necessary in respect of such goods.

The cost of operating the �consignment note� scheme will be an important consideration. The consultants have not, at this stage, carried out a detailed cost analysis but this must be carried out at an early stage, as soon as further consideration is given to actually implementing the scheme.

The major benefits will be improved compliance with licensing and taxation requirements, which will accrue to the State.

The major costs�in respect of buying the documents (to cover the cost of printing and a small profit for the distributor/seller), checking and keeping records�will rest with the transport operator.

However, apart from enabling private law claims and the insurance of cargo, the scheme offers a potentially large indirect benefit to the �bona fide� goods carrier.

Law abiding operators face unfair competition from illegal operators who avoid paying tax, do not maintain their vehicles properly and may not take proper care of their customers property. This competition reduces the income of legal operators, reducing their ability to invest in new vehicles.

It is often difficult for the Russian Transport Inspectorate and Tax authorities to find illegal operators.

If it were compulsory for an operator to hold an operators licence before he could obtain standard �consignment note� documentation and the carriage document was examined at a normal roadside check together with the drivers licence, it would be more difficult to operate illegally. A truck driver not able to show a valid consignment note may be the tip of a larger iceberg of tax evasion and black market trading. If the records of consignors and consignees were open to inspection and they were required to document how goods were delivered and received, it may be a deterrent to the use of illegal operators.

V. Issuing of the Consignment Note

• It is proposed that the consignment note system be under the overall control of the Ministry of Transport but that day to day control might be passed to the Russian Road Transport Union (RRTU), now being formalised. The delegation of powers must be covered by a formal detailed agreement between the organisations.

• It will be important that documents (consignment note) are readily available in all the regions of Russia. Non�availability will offer an excuse for avoiding the system. It is also important that the design of the document and the rules relating to its use are the same throughout Russia. Operators must be confident that their documents will be valid and understood by officials wherever they go and there must not be unfair price competition between the issuing authorities.

Therefore it is suggested that:-

• the Russian Road Transport Union (RRTU) will arrange for:

1. the printing of documents and
2. the bulk supply to each Licensed Issuer

• If there are logistical problems in distributing documents which have been printed centrally throughout Russia, it may be possible to allow regional printing by several companies. If this was done, it would be essential to develop systems of monitoring as the opportunity for fraud and accidental error in the allocation and recording of unique numbers would be multiplied. It may be possible for authority to be given for printing and for document reference numbers to be allocated by electronic transmission.

• RRTU will be subject to audit and overall control by the Ministry of Transport. Regional Associations must be given the opportunity to comment and, if necessary, make complaints about the scheme to the RRTU and the Ministry of Transport. It is recommended that regular � perhaps quarterly � liaison meetings be scheduled and that there be a system for calling emergency meetings.

• RRTU will sell batches of numbered documents to Regional Associations, who will in turn be licensed to sell them to operators if they are able to demonstrate that they can meet precise standards which will be laid down in a written contract. The contract must specify that:
• the Association will issue documents only to Carriers who have signed a supply contract with the Regional Association. This will include legally binding declarations that they hold an Operator�s Licence, they will honestly fill in the notes giving details of the parties and the goods, and that the various parts of the document will be given to the consignor and consignee.
• The operators licence of each applicant must be checked and the number must be noted.
• A record must be kept of the unique numbers of the documents issue.
• The fee income must be recorded in the Licensed Issuer�s/Association�s accounts. The RRTU will not be able to refuse a licence to a Regional Association which is properly constituted, able to meet RRTU requirements and was a signatory to the necessary contract. It will be illegal to issue documents without the correct contract being in place.
• The Licensed Issuer/Regional Association must not refuse to sell or obstruct the sale of documents to non-members. It will not be in their interests to do so, as a profit will be made on the sale of every document. However, there may be a temptation to impede supply in the hope of receiving a membership subscription. It is suggested that this risk would be reduced if the RRTU was given the task of investigating thoroughly any such complaints.
• RRTU officials should be able to inspect the Licensed Issuer/Regional Associations to check that the correct issuing procedure has been followed. An inspector may terminate the authority of an organisation to issue and sell documents if it fails to observe the rules.

• There must be an appeal mechanism � perhaps to the Transport Inspectorate, the Minister of Transport or a Court - if a Regional Association believes it has been unjustly refused the right to issue documents. The first consideration in such a situation would be to ensure continuity of supply to local operators. Disruption would be caused if a Regional Association was suddenly prevented from issuing documents. It would take time to set up a new issuing system under a different authority. Therefore, in the event of problems, a better solution may be to place the Regional Association�s issuing system under the temporary personal control of the local chief of the Transport Inspectorate until the system is functioning correctly. Revocation of the Regional Association�s licence would be a last resort.

• It will be some time before regional associations exist in all regions of Russia. One way of issuing documents in these areas would be to licence the RRTU to do so, providing controls were the same as for Regional Associations. As the RRTU will be located in Moscow, it may be necessary to delegate the powers to issue documents to local organisation � perhaps the Road Transport Inspectorate � in those regions where no Association exists.

• The Licensed Issuer will be required to pay a small fixed fee for each document to RRTU. The fee will be reclaimed � together with a small fixed profit margin � from the carrier. The price at which the document is sold to the licensed issuer and the price which may be charged to customers will both be fixed by the RRTU, but the Minister of Transport must have the power to intervene if he feels that the price set is excessive. The price must be low to avoid the introduction of a substantial financial burden to operators. The aim is to improve systems of commerce, not to make a vast profit and not to covertly introduce a new tax.

• Each document will be allocated a unique reference number, from which it will be possible to trace the supplier and the transport company to which it has been issued. This will enable the tax authorities to check that the carrier has recorded the work and the charge correctly in his accounts.

• It is essential that records are kept of the numbers on the documents issued by RRTU to each Licensed Issuer/Regional Association. Similarly it is essential that each regional association keeps detailed records of the numbers on consignment notes issued to individual road transport carriers. This information may be used for the compilation of statistical data. It may also be used to investigate suspected fraud � for example where an apparently small operator is using a large number of notes. This may be caused by his selling them on the black market.

• Data must be made available to the tax authorities � by regular inspections at the Regional Association�s offices or by the Association sending a regular report to the Tax Office. The Tax Office will be able to identify carriers who are not declaring a source of income to them. Tax officials will also be able to compare the amount of income declared against the number of notes used. To make a valid comparison it will be necessary to visit either the carrier or the consignor to find out what price was charged for the carriage, but an initial study will indicate which operators are most deserving of detailed investigation.

• The chain of responsibility for the issue of consignment notes would be as set out in the organisation chart below.

VI. Responsibilities of the Transport Operator

The carrier�s responsibilities were discussed before, in the context of the preceding sections. In summary, these are:

• To sign a contract with the appropriate agency issuing the consignment note, and to honour its declarations
• To hold a valid operators licence and to produce it when ordering consignment notes
• To use a consignment note for every journey involving the carriage of goods, either on his �own account� or for �hire and reward� (third party)
• To keep unused documents safe, to report loss or theft to the issuer and to use the documents correctly
• To keep proper accounts
• To co-operate with various enforcement officials (RTI, GIBDD inspectors on the road, tax inspectors) concerning the use of the documents.

The procedure for use will depend on the design of the document. Several alternatives are possible, depending upon the type of operation which it is intended to cover. The consultants believe that it will be very difficult to document every single type of carriage operation with one and the same model of document. For particular circumstances, it may be necessary to introduce a 2^nd document, called �Freight List� (see point 2 in this section).

1. In the case of simple delivery of a limited variety of items involving two parties�

for example a building supplies company delivering six steel beams to a site or a chocolate supplier delivering one hundred identical boxes of sweets to a supermarket, it would be sufficient for one document be produced in the form of three attached copies. The paper could be self-copying, avoiding the need to use carbon paper. This is important because if carbon paper is required it can be removed, creating blank sheets. It should be designed so that writing can be by hand, type writer or printer. The document can be filled in by the carrier or the consignor.

It is suggested that each document could include spaces for 10 different items. More than one document could be used per journey � allowing the recording of 20 or more separate items.

The procedure for its use will be as follows:-

• The top copy (and all other copies due to the self copying paper) is filled in and signed by the carrier and consignor. This confirms the identity of the consignor and that the goods have been received by the carrier in good condition. If it is not possible to examine the goods � for example they are contained in sealed boxes � this must be noted on the form.
• The consignor retains the top copy. He will need to produce it in several situations:-
• To justify the payments he has made to the carrier (tax authority / fraud investigation)
• To make a private law claim if the goods are lost or stolen, to prove he gave them to the carrier
• To make a claim on a policy of goods in transit insurance (for the same reason)
• To defend a private law claim from the consignee if the goods do not arrive at all, or are damaged (the carrier has certified that they were given to him in good condition).

• The second and third copies accompany the goods to their destination. They will contain a copy of the consignor�s signature and the carrier�s acknowledgement that the goods were in good condition because the self � copying paper will have reproduced these details.

• The goods will be checked on arrival by the consignee, who will sign the second (and automatically the third) copies. If the Consignee is not able to inspect the goods at the time, this must be noted on the form. The second copy is retained by the driver and is returned to the carriers office as soon as possible � at the end of the journey or the shift. The carrier must keep the completed documents safely for a minimum set period of time � for example one year - and be able to produce them for inspection. The carrier now has a document which:-

• Contains a description of the goods carried and the dates and times of consignment together with the signature of the consignor

• Contains details of the consignor

• Contains a signature confirming that the goods as described were received by the Consignee.

• If he was not able to inspect the goods thoroughly at the time of receipt, this will be noted on the document. The carrier cannot then claim that the consignee acknowledged that the goods were in satisfactory condition.
• If the carriage charge was paid by the consignee, the document is a justification for the expenditure. If the driver was paid in cash upon receipt of the goods for the consignee, the driver must sign the driver�s copy (and therefore automatically the consignee�s copy) to acknowledge receipt of the money. The consignee will not acknowledge receipt of the goods until the driver has recorded the fact that he has been paid. The driver�s signature means that the transport company can demand the money from the driver.

• The consignee�s copy may have other uses. The tax authority may visit a factory. The inspector will ask �who supplies your raw materials and how do they arrive ?� If the answer is �by lorry�, the inspector can ask to see consignment notes for the period over which the consignee is asked to keep them. From this information a check can be made that:-
• the carrier has documented the work and recorded the charge in his accounts
• that the carrier�s records coincide with the supplier (for example the carrier is not acting fraudulently by making several trips with the same load and charging for each)
• that the consignor has recorded the sale of the goods in his accounts.

It will be more difficult to apply the �consignment note� scheme to multiple delivery journeys � for example a (large) truck making a number of small deliveries in a city.

It will be even more difficult to document the situation where there are a number of intermediaries � for example subcontractors, freight forwarders, and intermediate warehousing. The following detailed considerations are presented for completeness� sake, but they should not delay the introduction of (just) the consignment note.

• The problem is that there may be a number of different parties whose identities must be recorded � several different consignors for a consolidated load, several different carriers if carriage of all or part of the load is sub-contracted and several different consignees if parts of the load are to be delivered at different addresses. It may be practically impossible to record all this information in a single sheet, especially if the consignment consists of many different goods which must be described.

• Therefore, it is suggested that there be two types of document in such a case and both might be needed:-

1. A Consignment Note � as discussed before, which is a set of instructions from a consignor to a carrier to move goods from A to B
2. A Freight List � a set of instructions from a carrier to the driver to move a list of items from one specified place to another.

• It is suggested that the Consignment note should again be in three parts, numbered and available only from Licensed Issuers. The issuer will check that the applicant holds an operators licence and will keep a record of note issued. The Freight List may be printed by the carrier�s office, but it must list the applicable consignment note number next to each item of cargo.

• The reason for making this distinction is that a third party haulier may collect a number of consignments from a number of locations. He will then take them to a warehouse where they will be divided up, possibly re � packed into units of different size and distributed to a number of different locations. It is possible that different consignments will be mixed so that � for example � all the consignments destined for the Smo �. region are consolidated on to a single lorry (this will avoid causing three or four lorries to make long round trips to several places).

• It will therefore be necessary to prove:-

1. That the consignor(s) consigned to the carrier an item or group of items and that he was required to deliver them to the consignee or several consignees
2. That the goods were received in good condition

AND

3. That the lorry driver can account for every item on his vehicle
4. That the lorry driver knows who gave him the items and to where they will be or were delivered.

• Therefore, the consignor should fill in a consignment note, itemising the goods to be delivered to a particular consignee. It is submitted that there be one note per consignee, so if one load of goods is collected and parts are to be delivered to three consignees there should be three consignment notes. The driver or an authorised manager of the carrier should sign a copy of the note to acknowledge receipt.

• If the driver makes more collections before returning to the warehouse, then he will receive and sign for more goods with a note for each consignee. At this stage, each consignee has had a receipt and the driver can account for all the goods on his lorry.

Example

• Consignor 1 consigns the following goods

1 x 100 kg case of machine parts to Chugonovsky�s garage in Smo �.

2 x 20 litre drums of cleaning fluid to Chugonovsky�s garage in Smo �.

20 x car radio�s (case) to Kolimatsev�s shop in Smo �..

There will be two consignment notes from consignor 1 � the first covers both items carried from him to Mr Chugonovsky. The second covers the item carried to Mr. Kolimatsev.

• Consignor 2 also wishes to transport goods to Smo �. He wishes to send 4 cases Matador Tyres to Chugonovsky�s garage. There will be a separate (third) consignment note from him as he is another party � not consignor 1.

• At the warehouse, the goods are sorted. It is likely that they will be mixed with other inward consignments so that all the goods going to a particular region are placed on the same vehicle. The driver gives his consignment notes to the warehouse manager and the loads and notes are checked.

• The transport manager prepares a list of consignments (packages) for each vehicle, its route and delivery points. This is known as the Freight List. This is an acknowledgement by the transport company that it has received the listed items into its warehouse and a set of instructions to the driver. The driver is given a copy, together with the two remaining copies (1^st one was kept by consignor) of the consignment note for each delivery.

• At each delivery point, the consignee checks the goods he has received. He signs and dates the consignment note to acknowledge that he has received the goods. This signature will appear on two copies because of the self-copying form. The consignee is given one copy and the driver takes the other.

• The consignee now has a document confirming that he has received a list of goods from a consignor that was delivered by specified carrier on a specified date and time. If he pays by cash on delivery, the driver will acknowledge receipt of the money on his and the consignee�s copies of the note. If he will pay in arrears on account, he can check the invoice against the consignment note(s). For an invoice to be legally valid, every item must coincide with an item on a signed consignment note.

• The driver leaves the consignee with one or more signed notes confirming receipt of the goods. He can prove that they were delivered. If he was given money, he must account for it because he has confirmed the fact on his and the consignee�s copy of the note.

• The driver then repeats the process at each delivery point, ticking off the consignments on his Freight List as he does so. If he is stopped by GIBDD or RTI, he will be able to account for every item that is and has been on his lorry. For items that he has already delivered he will have a crossed off entry on his Freight List and a signed consignment note. For items not yet delivered he will have two copies of the consignment note and an entry on his Freight List.

• When the driver returns to the depot, he gives the transport manager his Freight List, with all the items ticked off. The driver gives the single remaining copies of each consignment note to the transport manager. If he was unable to deliver any items, he returns them. The driver writes �not delivered� or similar words on the Freight List and the manager countersigns this (and takes back the 2 copies of the concerned consignment notes).

The driver�s work is now complete. The Transport manager can now arrange for invoices to be sent or accounts to be prepared for the work.

• If an item is lost or stolen in transit, it will be possible to show where it went missing, either:

• consignor will have signed consignment note from driver acknowledging receipt
• transport company will not have a signature from the consignee
• consignee will confirm goods did not arrive

• consignor will have signed consignment note from driver acknowledging receipt
• driver will have copy of Freight List, signed by warehouse manager
• transport company will have no proof from consignee that goods have arrived

• consignor will have signed consignment note from driver acknowledging receipt
• transport company will have copy of Freight List proving that goods were given to the driver
• transport company will have no signature from consignee and consignee will confirm goods were not received.

3) Sub � Contracting

• If all or part of the work is sub � contracted, the carrier will pass his two copies of the consignment note(s) to the subcontractor, together with a modified Freight List listing the items and the places to which they must be delivered. The subcontractor will sign this and give a copy to the contractor to acknowledge receipt.

• When the goods are delivered, the customer signs the two copies of the consignment note(s), keeps one and gives the other to the driver. The driver returns it to the subcontractors office.

• The consignor can prove he consigned the goods by producing the acknowledgement of receipt from the main carrier.

• The main carrier can prove he sub contracted the goods by producing the signed copy Freight List from the subcontractor.

• The subcontractor can prove that the goods were delivered by producing his copy of the Freight List and a signed consignment note from the consignee.

• The consignee can prove what he received by producing his copy of the signed consignment note.

• If the load is sub-contracted for a second or third time, there is no problem. The carrier�s and the consignee�s copies of the note(s) follow the part(s) of the load to which they refer. On each occasion that the carrier passes all or part of the load to a sub-contractor, he hands over the notes and a copy of the Freight List, keeping a signed copy Freight List for himself. The carrier can prove that he has handed the goods to the subcontractor. It is the responsibility of the parties to agree in a written agreement who is responsible for in the event of loss or damage, and to what extent. In the future, it is likely that such negotiations will involve insurance companies. It is possible that insurance companies will refuse to cover the sub-contracting of valuable or dangerous consignments.

• Consignment notes stay with the goods, moving from consignor to consignee
• Freight List stays with the carrier for that part of the journey (which is part of a multi-journey transport chain between consignor�s and consignee�s addresses)
• There must be one consignment note for each set of goods sent from one consignor to one consignee.

The main opportunity for fraud would appear to be the re-use of a consignment note, whereby the consignor or consignee pays the carriage charge for subsequent loads in black market cash.

In the case of a single journey consignment note, this risk can be reduced by requiring that the date and time of consignment and delivery be noted on the document, supplemented by the vehicle odometer readings at the time of consignment and receipt.

If more than one vehicle is used, the registration numbers and opening and closing readings for both vehicles can be noted � the same procedure that is used with a tachograph chart. If the place where the journey started and ended is also noted, obvious discrepancies in distance will be apparent to an inspector.

Secondly, the consignee will have to account for the goods he has received and has spent company money in buying. If his accounts show that a certain sum (e.g. $1000) has been spent on (input) materials� purchase, but his rate of (output) production would suggest a higher rate of (input) supply, there is a problem to be investigated (by the interested tax authorities).

In the case of the multiple party consignments (section VII -2) there is an added difficulty for fraudulent behaviour, in that the Freight List must reflect the goods on the vehicle at a certain time. In the case of a mixed consignment, it will be difficult to replicate precisely the contents of a mixed consignment and to persuade a number of consignees fraudulently to re-use consignment notes.

*NB FOR DANGEROUS GOODS SPECIFY: 1. Substance identification number (if applicable)

2. Substance description 3. Class 4. Item number and letter (if any)

The consultants have also considered the document �Notes for the DRT Council meeting on the issue of �Improving forms for the initial accounting of the road transport operations� �. This document proposes the use of both a �way bill� and a �consignment note�. The consultants consider that it should be possible to meet the control requirements through the use of a single form and recommend this approach on the grounds of simplicity, cost and accuracy of information.

The way bill as it is proposed in the document for the DRT Council, seems designed to control certain activities of the operator and the driver but the consultants consider�and recommend that these matters can be adequately controlled through other means. The matters covered and the alternative methods of control are as follows:

There are a number of items suggested for inclusion in the consignment note in the document prepared for the DRT Council meeting which have not been incorporated by the consultants in their proposed model. Details of these data elements and the reasons for their exclusion are given in the table below:

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