(When shipping Lithium batteries contained in equipment (PI 967 and PI 970), should we indicate net weight or gross weight?)

Q.
DGR 8.1.6.9.2 Step 6 (d) states: Where the maximum quantity per package is shown as ?gNo Limit?h or has a packing instruction number in Columns H, J and L of the List of Dangerous Goods, the quantity must be:

1. for substances, the net weight or volume (e.g. UN2969, UN3291)
2. for lithium batteries packed with equipment (UN3091 and UN3481) in accordance with PI969 and PI966 respectively, the net quantity of battery(ies) per package, or
3. for articles, the gross weight followed by the letter ?gG?h (e.g. UN2794, UN2800, UN2990, UN3166).

UN3480 (PI965) and UN3090 (PI968) both indicate Gross Weight ?gG?h quantity and agree to 8.1.6.9.2 Step 6. (d) 3.

UN3481 (PI966) and UN3091 (PI969) for lithium battery packed with equipment both indicate PI numbers in columns J and L and both PI are in conformity with 8.1.6.9.2 Step 6. (d) 2 to indicate the net quantity.

The problem is with UN3481 (PI967) and UN3091 (PI970) for lithium batteries contained in equipment _ whereas the blue pages refer to a PI number reference, and the yellow pages refer to entering a net weight, according to 8.1.6.9.2 Step 6. (d) 3., with examples named such like UN2794, UN2800, UN2990 and UN3166 shown, subparagraph (d) 3 would be more appropriate to apply to UN3481 and UN3091 lithium batteries contained in equipment. Thence the Gross Weight need to be shown, however the PI states for net weight.

Kindly clarify. (31 Jan 12)

A.
You are not reading PI 967 and PI 970 correctly. Section I of PI 967 and PI 970 both state the limit in net weight but this is the net weight of lithium batteries per equipment and it is not a package limit. It is not the quantity that would be shown on the DGD. The quantity to be shown on the DGD is the Gross Weight as stipulated per DGR 8.1.6.9.2 Step 6. (d) 3.

Furthermore, there is no limit indicated for the number of individual pieces of equipment that May be in a single package, or any requirement for the shipper to Dec are the number of pieces of equipment.

All of this will change from 2013 when all of the lithium battery packing instructions will specify the maximum net quantity limit of lithium batteries per package.


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