(A question on lamps containing mercury.)

Q.
I need guidance on moving lamps containing mercury. According to the regulations, unless the conditions of DGR 1.2.11 are met, it cannot be exempted. Thence we need to ship it as dangerous goods. Is it correct to move it as UN3506 Mercury contained in manufactured articles, Packing Instruction 869? DGR 1.2.11 does not mention about rules if it does not meet the exemption requirements. I believe DGR 1.2.11 originates from the Note to SP A69. I felt so as SP A69 is referred to in UN3506 as well. (31 Oct 15)

A.
DGR 1.2.11 is saying that if the lamps do not contain radioactive material, and there is not more than 1g of dangerous goods in a single lamp and there is not more than 30g of dangerous goods per package, it is not subject to the regulations. This rule applies to lamps containing mercury as well. Since no indication of mercury contents was given in your question, I cannot answer to the point, however if your lamp contains more than the limit, it must be declared as UN 3506 Mercury contained in manufactured articles and PI 869 applies. If limits are cleared, it can be shipped as non-dangerous goods. DGR 1.2.11 did not originate from SP A69.

【Subsequently, it was made known that the mercury contents in one lamp was 7g. With 4 lamps in one package, the contents of mercury in one package was within limits of 30g, however individual lamp limits exceeded 1g, therefore DGR 1.2.11 did not apply to this shipment.】


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