(A question on the identification marking for multiple overpacks.)

Q.
The first bullet point in 8.1.6.9.2 Step 7 stipulates that “when a consignment consists of multiple overpacks, each overpack must have an identification mark (which may be in any alpha-numeric format) and …” . Further in 7.1.7.2, it says “When a consignment consists of more than one overpack, … each overpack to show an identification mark …”. It also says in the following Note that “Where an overpack contains more than one UN number, the total quantity of dangerous goods should be shown by UN number”. I do not quite understand the meaning of “a consignment”. For instance, if one AWB contains two dangerous goods, UN xxxx and UN yyyy, and they are each packed in 2 separate overpacks, since there are 2 overpacks, identification marks are needed. Since there are only 2 UN numbers, acceptance check can be done by checking the UN numbers against the Declaration. You need not check the identification marks. Am I correct?  (31 Jul 14)

A.
The contents of Notes 1 to DGR 8.1.6.9,2 Step 7 is identical to the Note following DGR 7.1.7.2 that for multiple overpacks, an identification number for the overpack and the quantity of dangerous goods must be shown by UN number. Let me answer your question. First of all, the meaning on “one consignment” is “one straight AWB” or in the case of a consolidation, “one House AWB”. It does not refer to a Master AWB.

If a consignment carries two dangerous goods (for example, UN xxxx and UN yyyy), and they are each packed in separate overpacks, an identification mark is needed for the 2 overpacks, i.e., Overpack No. 1 and Overpack No. 2. The UN number is to identify the dangerous substance or the dangerous article. The purpose of identification is different.

Overpack No. 1 would show UN xxxx, the Proper Shipping Name and the quantity, and Overpack No. 2 would show UN yyyy, the Proper Shipping Name and the quantity. A check is made against the Declaration.

You are mixing the identification mark on the overpack and the UN number, the latter is to identify the dangerous goods. The manner you are taking is a short cut of the acceptance procedure which is strictly prohibited in the handling of dangerous goods. You must clearly differentiate the purpose of the marks and/or numbers and the aim of the check. Shortcuts must never be employed in the process of dangerous goods. A step by step check is mandatory commensurate with its purpose.


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