A.
For shipment of Dangerous Goods in Excepted Quantities, in addition to specific stipulations contained in the DGR, the 8 bullet points listed in DGR 2.6.1 “Applicability” must be adhered to. Furthermore, as stated in DGR Table 9.1.A, a formal acceptance, a shippers’declaration, identification of ULD and NOTOC are not required. When an Overpack is used, as stated in DGR 2.6.7.3, the Excepted Quantity marking (Figure 2.6.B) and if the individual packages inside the overpack are not visible from the outside, the word “OVERPACK” must be marked on the surface of the Overpack.

The permission to offer a shipper-built ULD as stated in DGR 9.1.4 (i) is simply to allow shippers to pre-load the individual packages into an ULD. ULDs are not an OVERPACK. Using an ULD does not mean you made an Overpack. Common markings such as an ULD Tag is needed, but there is no requirement to mark the ULD with the DG in Excepted Quantity marking. Each individual packages inside the ULD must bear the DG in Excepted Quantity mark. Such marking must show the primary hazard but subsidiary hazards are not needed to be marked.

Since the requirement of segregation (DGR 9.3.2) is not applicable, unless there is a specific state or carrier variation, segregation and verification of class and/or division is not required. The 5th bullet point under DGR 2.6.1 “Applicability” only stipulates 9.3.1 (Loading restrictions on flight deck and passenger aircraft) and 9.3.5 (Loading and securing requirements) are to be followed. DGR 9.3.2 is not mentioned and therefore need not be followed. About 5 years ago, there was a requirement for segregation, however, this requirement had been withdrawn together with the change of Q calculation to the application of the most stringent maximum quantity per applicable EQ code.

You appear to be misunderstanding an ULD for an Overpack. ULDs are not an Overpack.