(With Section IB applicable from Year 2013, May we apply the Class 9 hazard label and the Lithium Battery Handling Label on different sides?)

Q.
In reference to PI 965 and PI 968, effective from 2013, a new Section IB will be installed where both the Class 9 label and the Lithium Battery Handling label are to be applied. Must these be on one single side of the packaging? Since the packaging is used to contain just the lithium batteries, the size is rather small, and it is difficult to apply both labels on one single side. May we apply the labels on different sides? (31 Aug 12)

A.
The Class 9 label is used to alert the airline staff that an Acceptance Check List is needed for acceptance and the shipment must be listed on the NOTOC. Due to this purpose, alike the other labels Mar ings, these two labels must be readily visible and legible and not obscured by other labels or Mar ings.

The label location is as spelled out in DGR 7.2.6.1 and 7.2.6.2. The packagings must be of such size that there is adequate space to affix all required Mar ings and labels as stated in DGR 5.0.2.13.4.

The revision effective 2013, is to alert the airline staff that Section IB requires an Acceptance Check List and listing on the NOTOC.

To accomplish this purpose, there is a definite cause to have these two labels to be affixed adjacent to each other. There is a distinct purpose in having these two labels shown alongside each other.


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