(I have a question on UN 3509 Packaging discarded, empty, uncleaned introduced in the 56th Edition for Year 2015.)

Q.
Is UN 3509 Packaging discarded, empty, uncleaned to be assigned to packagaing material of devices being disposed? May we understand that UN 3509 does not apply to reused UN packagings.  (31 Oct 14)

A.
UN 3509 Packaging discarded, empty, uncleaned is assigned to uncleared empty packagings that are to be disposed. SP A 200 applies which reads: “This entry applies to packagings that contain residues of dangerous goods and which no longer meet the provisions of Section 6. These packagings are forbidden for transport by air. Such packagings or parts thereof must be transported in accordance with 5.0.213.5.1 of these Regulations.” DGR 5.0.2.13.5.1reads: “An empty packaging that has contained dangerous goods must be treated in the same manner as is required by these Regulations for a package filled with that substance unless adequate measures have been taken to nullify any hazard. Note: Purging and thorough flushing of the packaging with a neutralizing agent is an acceptable method of nullifying the hazard.”

Packagings may be repeatedly used and re-used provided it meets the General Packing Requirements of 5.0.2. and the Package Test Requirements of Section 6. In particular, it must satisfy 5.0.2.4 and 5.0.2.5. If the packaging fail to satisfy the test requirements of Section 6, the packaging cannot be used any longer.


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