Dangerous Stuff - Hazardous Substances

Most of the information in this section has been taken from "The International Freight Guide" with the kind permission of the British International Freight Association.

Responsibility
The Regulations
1. Classification: the Substance
2. Packing
3. Marks and Labelling
4. Documentation
Conclusion

2. Packing

The Regulations all require that the description of the type of package, the weight, quantity or capacity is declared. At present, only the Regulations relating to transport by air have the option of stating the "UN" package type designation in the documentation, for example, either "4D" or "plywood box". Although the same type of packaging may be acceptable by all modes of transport, they are likely to be different in the capacities or weight that may be permitted. It is again an area of potential delay and conflict that can only be resolved by understanding and compliance with the Regulations.

The typical declaration and basis for package marking and labelling could therefore comprise the following;

(For ADR, the description would include the "Substance" designation "3.5 (c), ADR".)

2.1 "UN" certified packages

These are not to be confused with uncertified.

The Regulations all refer to the use of certified packages. These types of packages meet provisions with regard to their manufacture and materials, and have undergone stacking, pressure, drop and other tests. The Regulations permit various types of packages to be used. They do not in themselves state that they are suitable. If, for instance, you normally used a plywood box, it would seem logical to use a certified plywood box rather than the fibreboard or multiwall sack that could be permitted.

It is for the user to select the appropriate packaging type that is suitable for the commodity, transport mode and possible handling that the journey will involve. It is not enough just to use a type of package because the Regulations permit it !

A typical "UN" certification that could appear on a fibreboard box would appear as follows:

These respectively mean the following:

• un UN symbol (usually in a circle)
• 4G Package type code used in the Regulations
• X The packing group that the package can be used with
• 50 Maximum gross weight
• S Suitable for use with solids or inner packaging
• 94 Year of manufacture
• GB Country of manufacture
• 1/123 Testing certification number

It is in these areas that frequent problems occur, as each set of modal regulations varies its requirements. A simple example is thinners or paint-related material.

A 205-litre capacity steel drum, with removable head, could be acceptable for transportation throughout Europe by road and comply with national CDG and ADR international regulations. It would, however, not be allowed for the sea crossing to Europe or Ireland, as in general removable head packages are not acceptable for free-flowing liquids under the IMDG Regulations By air, the capacity of the drum may be too large to be acceptable as a single package.

There are also differences in the packages themselves, which in most cases require manufacture and testing to standards defined within the Regulations. For tins, a lower standard light tinplate gauge is acceptable under domestic CDG and ADR which does not comply with other modal Regulations. Since most products using these packages are manufactured to UK domestic transport standards, CDG and in a Single Market concept ADR, it can be seen that there is considerable scope for problems to arise when these substances are subject to sea or air Regulations.

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