(Is retention of shipping documents stipulated in DGR 1.3.4 mandatory for non-regulated dangerous goods?)

Q.
Our company handles lithium batteries (PI 965〜PI 970) but most of them fall under Section II as non-regulated shipments. Do we have to abide to the rule of retaining shipping documents for minimum 3 months as stipulated in DGR 1.3.4? (30 Jun 12)

A.
There is no obligation to retain shipping documents for shipments that are exempted from dangerous goods procedures as being non-regulated, such as lithium batteries shipped under Section II.

However, some State May have a variation. It is therefore necessary to double check DGR 2.8.1 for any State Variation which might say otherwise. Furthermore, there May be an instance where a shipment which should have been handled as dangerous was by error handling as exempted. If such an incident surfaces, a retroactive investigation would take place. It is therefore advisable to have a record taken of all such non-regulated shipments.


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