Carriage of Dangerous Goods

• The Inner Packagings are 500ml, which is less that the maximum 1L specified in column 3.4 so it does come under LQ.
• It's hard to say without detailed photos, but it does sound like the packagings met the LQ rules (which are much less restrictive than the packing instructions for using inner and outer packages for non-exempt DG's which you described).
• It is missing it's marking but that mark should be the LQ Mark, not a Hazard Diamond

The LQ rules were implemented to allow the easy shipment of dangerous goods packed for retail sale, largely to facilitate Distribution Center to Store carriage by high street retailers and supermarkets, the result is rules where as long as the core inner package size rules are met everything else is very permissive (allowing up to 8 tonnes per transport unit to be exempt under them for example).

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I have to say as a DGSA this really doesn't feel like a big deal in terms of Road, Rail or Sea modes, as it's effectively a missing sticker which doesn't mean a lot to many people anyway.

Yes, it is technically non-compliant, and yes it does create some level of additional risk, but it isn't liable to cause a major incident of the kind that ADR was intended to control and mitigate...

It's much more of a occupational safety issue for RM (although again, practical experience teaches me that it's unlikely to be as dramatically dangerous as expected).

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I can see your argument that the IATA DG rules exist for a very good reason and that shipment of DG by air has to be very closely controlled...

But if RM's screening before internal air carriage is so lax that they would allow packages containing unexpected, undisclosed liquids through to load on to a plane, then frankly there are bigger security issues at hand really.

Edited By Jelly on 08/12/2022 10:10:20

Not only volatiles and corrosives, Good old RM failed to deliver a couple of bottles of highly dangerous Steam Oil. Strangely enough, they didn't seem top have a problem with Ketone?????

Regards Ian.

While a student I had a summer job at a campsite/caravan park and to clean the urinals and toilets we used strong Hydrochloric Acid which came in a bottle with its own mop that sat in a cup on the side of the bottle. You poured a bit of the acid into the cup and than dipped the mop into it. A single wipe along the top of the urinal or round the rim of the toilet bowl leaving just an indiscernable amount of acid was sufficient to remove any limescale or staining as it ran down.

Just before I retired I had to co into the cleaner's cupboard at work for some rubbish bags (the amount of rubbish collected in over 40 years teaching and over 11 at that school!!!) and there appeared to be something very similar on the shelf clearly still in use.

Edited By Nick Clarke 3 on 08/12/2022 11:23:38

As an (out of work) airline pilot, who amongst other duties spent a season flying cargo for the Royal Mail, and DHL etc, I would urge folk to be safe.

As part of our extensive pilot training, we do recurrent classroom lectures about Dangerous Goods and have to pass Dangerous Goods exams every couple of years. Dangerous goods must be known about and there are strict regulations about which dangerous goods can be packed next to other dangerous goods - to avoid chemical and physical reactions. So it is vital that the contents are correctly declared, packed and labelled.

We also do classroom lectures about aircraft fires, and practical fire fighting instruction and tests in aircraft mock-ups.

Aircraft have crashed and caused loss of life owing to undeclared or badly packaged dangerous goods. Undeclared or incorrectly packaged dangerous goods in aircraft is a definite no-no.

Sorry for the telling off !

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

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!

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

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)

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

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.

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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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

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.