(State Variations and Operator Variations are referenced in the Packing Instruction pages. If USG-13 is not mentioned, May we assume the 25kg rule is not applicable to this particular substance?)

Q.
As an example, let?fs say there is a shipment of 16 packages of UN1993 Flammable liquid n.o.s.?? packed in LTD QTY PI Y344 each containing 10L or a total of 160L In PI Y344 there is only a reference to State Variation USG-04. There is no reference to USG-13. Since USG-13 is not shown in PI Y344, May we assume that USG-13 does not apply to this shipment, and the total lot of 160L can be shipped on a single passenger aircraft? For further reference, PI 355 shows both USG-04 and USG-13. Does this mean, for PI 355, the 24kg rule will apply?  (31 May 12)

A.
State Variation numbers referred to in the Packing Instruction pages May not be updated and should not be used as reference. Officers of such governments are really not checking each DGR edition and do not appear to be updating the information. These references are misleading. Instead of referring to the State Variation entries in the Packing Instruction pages, when preparing a shipment, the shipper must refer to DGR 2.8.2 and check all the applicable State Variations of the State concerned in the movement of the shipment.

USG-04 refers to RQ (Reportable Quantity) per 49CFR 172.101 Table 1 to Appendix A. Whether USG-04 is referenced on the Packing Instruction pages or not, USG-04 will apply to any and all substances listed in the RQ Table.

USG-13 as stated in its paragraph (d) applies to all substances except for ?gOther Regulated Materials?h as defined in 49CFR 173.144, substances of Class 9, radioactive material, aircraft batteries transported as items of replacement, and those articles and substances considered to be dangerous goods under these (IATA) Regulations but which are not subject to 49CFR Parts 171-180 (such as Limited Quantity and Excepted Quantity). Whether USG-13 is not mentioned in PI Y344 or mentioned in PI 355 does not make any difference. State Variation USG-04 and USG-13 apply to all dangerous goods to, from or through the U.S. and to shipments on US flag commercial aircraft.

At the bottom of 49CFR 175.75 (c) it spells out, ?gThe requirements of this paragraph (this refers to the 25kg rule) do not apply to Class 9, ORM-D-AIR and Limited or Excepted Quantity material.?h USG-13 does not apply to LTD QTY shipments. In the footnote of Table under 49CFR 175.75 (f), it says the 25kg rule does not apply to LTD QTY and RQ shipments.

However, both USG-13 in the IATA DGR and US-13 in the ICAO TI do not mention that LTD QTY is exempted from the 25kg rule and cause ambiguity. Nevertheless, since 49CFR is the governing rule, we can determine that the US rule, 49CFR, is correct and must be applied.

Consequently, the entire shipment of UN1993 PG III PI Y344 10L X 16 pcs can be loaded fully on one single passenger aircraft. Please disregard the State Variation numbers in the Packing Instruction pages since they are not updated and do not serve the purpose.


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