Carriage of Dangerous Goods

[Robert Atkinson 2Participant @robertatkinson2]

Jelly,

On qty you are correct because of 500ml inner package it is compliant.

I'm not sure on packing. HCL in limited quantity under ADR requires packing to instruction P001 which requires a inner package of glass metal or plastic AND an outer package of a box or drum. While we don't have photo the original message implies it was a retail package with a plastic overwrap. This is probably not good enough.

Even if it did meet the packing requirement the lack of marking is critical. The ADR only applies to road transport. A package with limited quantity marking will not be shipped by air. Not having marking runs the risk of shipping by air.

Robert.

Edited By Robert Atkinson 2 on 08/12/2022 12:25:35

[JellyParticipant @jelly]

P001 wouldn't apply to goods traveling as LQ, only paragraphs 4.1.1.1, 4.1.1.2, and 4.1.1.4 to 4.1.1.8 apply within part 4 (packaging) for LQ.

The missing marking is the single element where there's definitively a non-compliance with the regulations, and I see how it's critical in the context of potential air-freight use (something I wouldn't have considered viable in the UK really).

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But I am aghast (but honestly not wholly surprised) if you're saying the screening of air-freight is that lax that it wouldn't identify that goods don't match their descriptions and are in breach of the conditions of carriage…

In the context that I know first hand that RM (like every other courier) is fully aware of the sheer volume of stuff contravening the conditions of carriage across every depot in the country, and pays substantial sums of money each month to various contractors to deal with the small proportion of said materials which they actually intercept.

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Putting my process safety hat on and thinking of the transport chain as if it was a process plant, if the only thing stopping DG's making it onto a plane relies on "the customer was honest enough to apply a LQ sticker and declare the goods" then that layer of protection might as well not exist.

Even Emmentaler doesn't have holes that big in it!

[John Doe 2Participant @johndoe2]

Freight aircraft fly all around and within the UK every night, e.g. Jersey, Edinburgh, Exeter, East Midlands, Belfast, as well as to Europe.

[Robert Atkinson 2Participant @robertatkinson2]

Jelly,

P001 clearly does apply to limited quantities of HCL. 4.1 requires all material to be properly packaged. P001 is the minimum standard for liquids.
4.1.1.5 (which you say applies) confirms outer packaging is required and in this case should be acid proof and have orientation marks.

" 4.1.1.5 Inner packagings shall be packed in an outer packaging in such a way that, under normal conditions of carriage, they cannot break, be punctured or leak their contents into the outer packaging.

Inner packagings containing liquids shall be packed with their closures upward and placed within outer packagings consistent with the orientation marks prescribed in 5.2.1.10.

Inner packagings that are liable to break or be punctured easily, such as those made of glass, porcelain or stoneware or of certain plastics materials, etc., shall be secured in outer packagings with suitable cushioning material.

Any leakage of the contents shall not substantially impair the protective properties of the cushioning material or of the

outer packaging."

Screening of goods for carriage of goods by air is basically predicated on correct declaration and marking of packages. Particuarly fo non-international freight as you do not know the routing so there is less of a a security risk and no smuggling.

Two inland routes that fly daily are Bournemouth-East Midlands and Exeter-London Stansted. Some is carried on passenger aircraft as well.
The lack of correct marking is resulting in more and more items being put on blanket bans by couriers regardless of their ADR, ICAO or IMDG status. An example is gas cylinders. Royal mail now have a ban on these even if they are empty.

And regardles of the ADR Royal mail have a TOTAL BAN on all Corrosives in the mail.

Corrosives (including aluminium chloride, caustic soda, corrosive cleaning fluid, dyes, acids, corrosive paint and rust removers, mercury and gallium metal)

• International – Not allowed in the mail
• UK – Not allowed in the mail

https://personal.help.royalmail.com/app/answers/detail/a_id/96/~/prohibited-and-restricted-items—advice-for-personal-customers

[Adam MaraParticipant @adammara]

Son in Law is a HGV driver, mainly containers. Earlier this week he had a load listed as non-hazardless. Contained lots of Haz-Chem labels when opened. It's not the first time.

[JellyParticipant @jelly]

 

Posted by Robert Atkinson 2 on 08/12/2022 19:24:42:

Jelly,

P001 clearly does apply to limited quantities of HCL. 4.1 requires all material to be properly packaged. P001 is the minimum standard for liquids.
4.1.1.5 (which you say applies) confirms outer packaging is required and in this case should be acid proof and have orientation marks.

I'm afraid that's not a correct interpretation of the regulations. You have inferred something (not unreasonably) from the wording of 4.1.1.5, but the regulations are prescriptive and must therefore be interpreted explicitly.

Packing Instructions (inclusive of P001) are contained in Paragraph 4.1.4.1.

Paragraph 3.4.1 states:

Ergo, compliance with paragraph 4.1.4.1 and thus the packing instructions is explicitly stated as not being required.

LQ wouldn't make any sense if it did require compliance with packing instructions, because then UN approved packagings would be required for retail products, which would massively drive up cost and complexity in the supply chain…

Which is the exact problem which the LQ rules were included to avoid.

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Posted by Robert Atkinson 2 on 08/12/2022 19:24:42:

Screening of goods for carriage of goods by air is basically predicated on correct declaration and marking of packages.

Given the amount of undeclared DG's that all the major parcel companies know they have moving through their systems, consistently and without fail; that seems to be a fundamentally flawed assumption on which to predicate an important safety measure.

I would assume that either:

• the relevant departments don't talk to each other, so the scope of the problem hasn't been highlighted, or
• it is a risk based judgement made by the company that it would be more expensive to implement effective screening, than to bear the cost of an accident.

Edited By Jelly on 09/12/2022 14:25:30

[Robert Atkinson 2Participant @robertatkinson2]

Jelly,
I think we are arquing the same thing. I've never suggested that approved or tested packaging was required. P001 requires inner and outer packaging which is basically what 4.1.1.5 says. If P001 requires approved packaging that is my mistake.

Robert.

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