(Is it permissible to include Excepted Quantity dangerous goods PG I in a Chemical Kit?)

Q.
Per SP A44, the most stringent PG within the UN 3316 Chemical kit is to be used on the declaration. When looking at UN 3316 Chemical kit in the DGR 4.2 List, UN 3316 only shows PG II and PG III. For example, if we are shipping UN 1133 Adhesives PG I (EQ Code E3) and LTD QTY UN 1993 PG II substance in a Chemical Kit, what is the PG that we must show on the DGD? (31 May 15)

A.
Yes, SP A44 states the most stringent PG must be declared on the DGD. Excepted Quantities are forbidden to be packed with other dangerous goods requiring a DGD. Refer to DGR 2.6.5.2. Consequently, EQ substances cannot be packed inside UN 3316 Chemical kit which requires a DGD. Since UN 1133 Adhesives PG I is “forbidden” for LTD QTY therefore there is no way to include this item in a Chemical Kit. 55th Edition DGR did not have a PG designation. With the 56th Edition, PG was indicated in Column E. As it was determined doubtful to allow PG I substances in a Chemical Kit, the 56th Edition DGR shows only PG II and PG III are allowed for UN 3316.


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