(There was no absorbent material in a liquid dangerous goods package which we received. Should we report this discrepancy?)

Q.
We imported a supply of flammable liquid, but the packages did not have absorbent materials in them. Where should we report this discrepancy? (31 Aug 12)

A.
Absorbent material must be used with packages of flammable liquid when the PG is I. Taking Packing Instructions PI 350, PI 351, PI 360 and PI 361 as examples, you will read in the Additional Packing Requirements that “inner packagings must be packed with absorbent material and placed in a rigid leakproof receptacle before packing in outer packagings.”

This implies absorbent material necessary to absorb the entire liquid contents need to be used. On the other hand, if you refer to PI 352, PI 353, PI354 and PI 355 where the PG is II, there is no direct reference to a requirement of absorbent material, but in the Closure Requirement, it spells that “closures must meet the requirements of 5.0.2.7.” Referring now to 5.0.2.7, in addition to the requirements written in 5.0.2.7.1, particularly in DGR 5.0.2.7.2, it states: “In addition, for liquid substances, closures must be held securely, tightly and effectively in place by secondary means.

Examples of such methods include adhesive tape, friction sleeves, welding or soldering, positive locking wires, locking rings, induction heat seals and child-resistant closures. The closure device must be so designed that it is unlikely that it can be incorrectly or incompletely closed.

When secondary means of closure cannot be applied to an inner packaging containing liquids, the inner packaging must be securely closed and placed in a leakproof liner and then packed in an outer packaging.” Since you did not specify the Packing Group of the substance in question, please recheck the packing group. If any person in the dangerous goods supply chain discovers an irregularity, whoever he/she May be, the person has an obligation to notify the competent authorities of the country where the incident happened or was uncovered and also to the competent authority of his/her own country.


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