(Question on location of Lithium Battery Handling Label and CAO Label.)

Q.
PI 968 Section II carries a statement “When the package dimensions are adequate, the CAO label must be located on the same surface of the package near the Lithium Battery Handling Label.” Can we interpret this statement as an exemption clause that there is no need to affix the CAO label and Lithium Battery Handling label on the same surface when the package size is small? (30 Apr 15)

A.
Please remember, as stipulated in DGR 5.0.2.13.4; 7.0.1; and 7.2.6.1(e), fundamentally all packages must be of such size that there is adequate space to affix all required markings and labels. This fundamental requirement is absolute and it stands.

The statement found in PI 968 Section II is not permitting a small inadequate package. It is giving some room for the shipper an excuse to apply the CAO Label and the Lithium Battery Handling Label not in proximity to each other if the situation so dictate. Please do not interpret the PI phrase as an acquittal or a pardon.


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