(Question on labelling and documentation of UN 3373 with dry ice?)

Q.
As far as labelling is concerned, UN 3373 shipments require a diamond mark with the letters “UN 3373”. Column “D” of the blue pages (DGR 4.2) is left blank not requiring the Div. 6.2 hazard label. However, it says in DGR 7.2.3.7 Class 6 that “in addition to the primary hazard label (7.3.15) Division 6.2 infectious substances packages must bear any other label required by the nature of the contents” implying that the Div. 6.2 hazard label cannot be ignored. When dry ice is used, the package must bear the Class 9 hazard label and dry ice data must be indicated. Now for documentation, PI 650 do not require DGD but PI 954 says DGD is required when dry ice is used for cooling dangerous goods. Div. 6.2 is certainly dangerous goods but required no DGD. How do we manage this dilemma? (31 Aug 14)

A.
As stated in PI 650 nothing else in the Regulations applies. So therefore DGR 7.2.3.7 does not apply to UN 3373. Div. 6.2 hazard label is not necessary. On the package, please affix the diamond mark with the letters UN 3373, the Class 9 label and indicate dry ice data. DGD is not required even if you are using dry ice for UN 3373 since UN 3373 does not require a DGD in the first place. Indicate on the AWB, all requirements for UN 3373 as spelled out in PI 650 plus the dry ice data.


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