With the release of the "Measures for the Safety Administration of Road Transport of Dangerous Goods" (hereinafter referred to as the "Measures"), the mode of transport in small packages has once again entered the public eye. Small pieces of dangerous goods such as aerosols, 84 disinfectants, daily chemical reagents, etc. The transportation of highly hazardous products has always been a hot topic in the industry.
These dangerous goods themselves are transported in small quantities, and if they are packaged in reliable, strong and durable packaging, or if certain conditions are met, their transport will be much less dangerous.
One of the major features of the "Measures" is the introduction of the exemption of small package transportation, which clarifies the legal and legal transportation behavior of small package transportation in my country from the level of administrative enforcement of laws and regulations.
01 Legal and regulatory basis
In Chapter 3.4 of the International Maritime Dangerous Goods Regulations, it is clarified that a limited quantity of dangerous goods shall be packaged according to the limited quantity and comply with the provisions of this chapter, except for the 7 cases listed (there is no test requirement for relevant packaging testing in 4.1.1.3) , without any other provisions of these Rules.
For this reason, if an enterprise uses a limited quantity of packaging when exporting hazardous chemicals by sea, it is not necessary to provide the "Outbound Cargo Transport Packaging Performance Inspection Result Sheet".
02 Packaging Restriction Requirements
Combination packaging should be used: Dangerous goods should be transported in limited quantities in inner packagings with suitable outer packagings, and intermediate packagings may be used. When transporting items such as aerosols or small gas containers, inner packaging is not required.
With the exception of 1.4 S explosives, shrink-wrapped or stretch-wrapped pallets that meet the specified conditions may be used as outer packaging. If fragile or breakable inner packagings made of glass, porcelain, coarse ceramics or certain plastics are used, they should be placed in qualified intermediate packagings.
Glass or ceramic inner packagings containing liquid corrosives of Class 8 (packing group II) shall be placed in compatible and rigid intermediate packagings as required.
In a word, combined packaging is required when transporting in limited quantities. Inner packaging and outer packaging are necessary, but for intermediate packaging, it can be judged whether it is necessary or not.
However, unlike exception packaging, a limited number of packaging testing requirements are not mandatory.
03 Package Weight
For example, the more common recent alcohol spray, UN No. 1170, is available in a limited quantity of 5L for Group III packaging. That is to say, the maximum volume of each small package cannot exceed 5L. If the small package is fragile or fragile, such as the inner package made of glass, porcelain, coarse ceramics or some plastics, it needs to be placed in an intermediate package that meets certain requirements, and then placed in the outer package. The total gross weight of the package should not exceed 20 kg. If the inner packaging is not fragile or breakable, no intermediate packaging is required, and the total gross weight of the package should not exceed 30 kg.
Notice! Limited quantities do not apply to all dangerous goods.
04 Packaging Marking Requirements
Of course, in addition to the selection requirements of the packaging itself, the packaging marking requirements are also another important feature that distinguishes the limited quantity from other modes of transportation.
After selecting the correct limited quantity packaging mark, you also need to choose the size of the limited quantity packaging mark reasonably according to the size of the actual product packaging.
05 Contents of limited quantity packaging inspection
For the packaging of dangerous chemicals exported in limited quantities, the customs shall comply with Chapter 3.4 of the International Maritime Dangerous Goods Transport Regulations, as well as the "Limited Quantity and Packaging Requirements for Dangerous Goods" (GB 28644.2-2012), and the "Export Dangerous Goods Packaging Inspection Regulations for Limited Quantities" (SN/T 4149-2015) and other requirements for inspection.
