Provisions for shipping dangerous goods in Limited Quantities
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Provisions for shipping dangerous goods in Limited Quantities
Many shippers choose to consign their goods under the Limited Quantities106 provisions when permitted by the IMDG Code because such goods are subject to less stringent packaging, marking and labelling requirements and fewer of the restrictions for transport by road and sea. This makes Limited Quantities attractive to manufacturers and shippers of dangerous goods products that are mass-produced for the consumer market and packaged for retail display and sale.
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106 IMDG Code, 2022 Edition Amendment 41-22, Chapter 3.4
For sea transport, the main advantage is that the segregation restrictions between classes are relaxed for dangerous goods in Limited Quantities. In practice, this means that packages of different classes of dangerous goods shipped in Limited Quantities, normally required be segregated and shipped in separate cargo transport units, may be shipped in the same shipping container, provided they are in separate packages. This greatly simplifies the distribution supply chain for organisations servicing retail outlets.
One segregation factor is not relaxed – different classes of dangerous goods that are regarded as incompatible must not be packed into the same outer package, even in Limited Quantities.
The safety rationale for allowing relaxations for the transport of dangerous goods in Limited Quantities is based on risk assessment. By replacing large packagings (e.g. a 200 litre drum) with a number of very small ones (e.g. 200 x 1 litre receptacles), and then placing the receptacles into outer packaging, the potential hazard and, therefore, the risk is measurably reduced. The potential spillage scale is reduced from 200 litres to 1 litre if one package becomes punctured.
The IMDG Code requirements for packaging, marking, labelling and documentation of dangerous goods in Limited Quantities are different from those of “normal” dangerous goods consignments. This section explains what those differences are.
Packaging requirements for goods shipped by sea as Limited Quantities107 are less stringent than for other dangerous goods:
- Packaging does not have to be UN-tested, but it must not leak, and must be built to fulfil the general packaging design criteria of IMDG Part 4
- Substances in receptacles must be in a two-part combination package comprising inner packagings placed inside outer packagings. Intermediate packaging is optional and the gross mass of the package must not exceed 30 kg (see below for exception to this)
- Robust articles in Limited Quantities such as aerosols are not required to be packed in inner receptacles and may be placed directly into outer packagings or in shrink-wrapped trays that meet the general packaging requirements of IMDG Part 4. Intermediate packaging is not required provided the article is not likely to break during transport. Shrink-wrapped trays must not exceed 20 kg
- The maximum mass for solids and capacity for liquids of the inner package is variable and determined by the UN Number and the packing group. The allowable maximum mass/capacity for inner packaging for each UN entry is displayed in column 7(a) of the Dangerous Goods List. If the mass/capacity of the inner packaging exceeds this figure, the goods cannot be classified as Limited Quantities
- There is no upper limit to the total number or weight of packages in Limited Quantities that may be packed to a cargo transport unit – a single shipping container may be packed to its maximum safe working load with packages of dangerous goods in Limited Quantities
- Limited Quantities packages may be made up into units, for instance, shrink-wrapped onto pallets
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107 IMDG Code, 2022 Edition Amendment 41-22, Section 3.4.2
The marking requirements for packages of Limited Quantities are less stringent than for “normal” dangerous goods108.
Each package must be marked with the Limited Quantities mark (see illustration) regardless of class.
- There is no requirement to mark packages with the Proper Shipping Name, UN Number, or apply the hazard class label or marine pollutant mark
- Inner packagings do not need to be marked or labelled because the outer packaging should not be opened in transit
- Packages containing liquids must display orientation arrows on opposing sides
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108 IMDG Code, 2022 Edition Amendment 41-22, Section 3.4.5
Dangerous goods consigned in Limited Quantities must be documented with a signed shipper’s declaration stating the number and type of packages, UN Number, Proper Shipping Name, Class, Packing Group etc in the normal way, but in addition, the declaration must be supplemented with words “LTD QTY” or “DANGEROUS GOODS IN LIMITED QUANTITY” after the dangerous goods description.
Dangerous goods in Limited Quantities packed in cargo transport units need a packing certificate in the normal way.
Shipping containers of dangerous goods in Limited Quantities only should not display any hazard class(es) placards or UN Numbers, but they should instead display the Limited Quantities mark 250 mm x 250 mm on both sides, front and back.
There are conditions for allowing dangerous goods to be classified as Limited Quantities. The general rules are as follows:
- There is a maximum permissible mass/capacity to be determined for the inner packaging, variable depending upon the UN Number, shown in column 7a of the Dangerous Goods List. If ‘0’ is shown in that column it is not permitted to be shipped in Limited Quantities
- Dangerous goods must be in PG II or PG III only
- Dangerous goods in PG I are prohibited as Limited Quantities (with minor exceptions)
- Must be in a combination package – inner packaging placed inside an outer packaging (with exception for articles in shrink-wrapped trays)
- There is a maximum allowable mass for the complete packaging (see below)
- There is no upper restriction on the overall number of packages of dangerous goods meeting the requirements of the Limited Quantities rules that may be shipped in a cargo transport unit
- Different classes of dangerous goods in Limited Quantities may be only shipped in the same package provided the segregation rules of IMDG 7.2 indicate they are compatible, and the goods will not react dangerously with each other
- Dangerous goods of classes that are not compatible according to IMDG 7.2 may be shipped in the same shipping container provided they are in Limited Quantities and in different outer packages
Note: To check if dangerous goods can be shipped as Limited Quantities you need to know details of the inner and outer packaging sizes.