(How should we enter the substance shown in Figure 8.1.O Example 11 (DGR Page 659) on the NOTOC?)

Q.
This declaration shows Radioactive Material in Excepted Package having a Class 3 risk. The precedence of risk is reversed with Class 3 being the primary and Class 7 being the subsidiary. The declaration shows the PSN representing both risks. We made the NOTOC accordingly however our ground handling agent stated that there is no need to show Radioactive Material in Excepted Package on the NOTOC. Please advise which is correct? Please also advise DGR reference? (28 Feb 13)

A.
The NOTOC form must be a mirror reflection of the Declaration. It is necessary to show both the PSN representing Class 3 and the PSN for Class 7 on the NOTOC. Granted, if it is merely Radioactive Material in Excepted Package, there is no need to show on the NOTOC. This substance, however, is a Class 3 substance with a Class 7 subrisk and it must be shown on the NOTOC as such. This is common sense. The regulation does not print such common sense understandings.


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