Are my eyes getting better with age or did something change? Something changed.

New to the regulations this year is a statement regarding the size of text on labels for dangerous goods. Both IATA (Air) and IMDG (Marine) have made changes to reflect the UN Model Regulation that become mandatory as of January 1^st, 2014. Please reference “UN Model Regulations: 17^th Edition; Section 5.2.1.1 (Vol 2. pg. 139)”, “IATA: 54^th Edition; Section: 7.1.5.5 – Size (pg. 619)” and “IMDG Code: 2012 Edition; Section: 5.2.1.1 (Vol 1. pg. 244)” to find the following information.

As of January 1, 2014, mandatory size for “UN number” and letters “UN”:

Some things to note:

1. The way this is written is such that the UN number and letters “UN” MUST be at least the size specified above whereas other package markings SHOULD be that minimum size.
2. Other package markings include the proper shipping name, technical name, the word “Overpack”, and any other markings.
3. For IMDG, cylinders marked in accordance with the 2010 version of IMDG are acceptable until no later than July 1^st, 2018 (and only if marked by December 31^st, 2013), otherwise the sizing requirements must be followed.

UN Packaging codes reveal necessary information about a package’s specifications.  They provide concise answers to questions of:
what it can hold, how much, where it was authorized, when it was made, etc.
The UN packaging code, however, doesn’t always tell the whole story…

Although there may be other test levels achieved, these may not be reflected on the packaging itself.  For example, take a steel drum that has successfully passed the most stringent tests (PG I), and is marked accordingly with the ‘X’ performance level.  This package, in all probability, can/has also passed the less rigorous tests required to meet both the ‘Y’ and ‘Z’ performance level. (Referencing a testing certificate, a test report, or the registration of a successfully tested package, will confirm this.)

So what does this all mean?
Filling limits for single or composite packaging, containing less hazardous material for which they were tested & marked (e.g. PG III material in a PG I packaging), can be re-calculated as per below.

Provided all the performance criteria can still be achieved by the higher relative density product, the following will apply:

For liquids:

a.  A packing group I packaging may be used for a packing group II material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.

b. A packing group I packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 2.7, or 2.25 times the specific gravity marked on the packaging.

c. A packing group II packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.

For Solids:

A single or composite packaging which has been tested and marked for liquids may be filled with solids to a gross mass not exceeding the capacity of the packaging in liters, multiplied by the specific gravity indicated in the package marking, or 1.2 if there is no indication in the marking.  In addition,

a.  A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group II solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

b.  A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 2.25, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

c.  A single or composite packaging which has been tested and marked for packing group II liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

For more information, please to refer to the applicable regulations:

TDG: CAN/CGSB – 43.150 – 97 – Part II, 13 & 14
49 CFR: Part 173.24 a (b) (1)-(3)
UN Model Regulations (17^th Ed.): Part 6.1.3 – Note 3
ICAO: Part 6, Chapter 2, Note 3
IATA: Section 6.0.4.0.3
IMDG Code: Part 6.1.3, Note 3

UN Performance Packaging	Packaging Chart	Regulations

http://www.thecompliancecenter.com/posters/packaging.htm

http://www.thecompliancecenter.com/regulations/