(May a 6HA1 with venting holes be used for dangerous goods?)

Q.
A 6HA1 Composite Packaging has small venting holes in the outer steel drum. It is accompanied by a Test Certificate for ocean transport as able to withstand 30kPa air tight pressure test. The shipper states that after filling the inner plastic receptacle with dangerous goods, there is a need to depressurize the packaging and the small holes in the outer steel drum are intended to take out extra pressure from the interior. Should the inner plastic receptacle burst or tear, some contents may inevitably flow out from the small holes. Is this 6HA1 permissible for air transport?  (31 Dec 15)

A.
No. The answer is “Absolutely No”. As stipulated in DGR 5.0.2.13.2 “Venting”: “Venting of packagings to reduce internal pressure, which may develop by the evolution of gas from the contents, is not permitted for air transport, except as otherwise specified in these Regulations”, all packagings for air transport must be air tight. In DGR 5.0.2.9, it specifies that packagings for liquids must be able to withstand without leaking an internal pressure which provides a pressure differential of not less than 95 kPa. Only the following items may have a venting feature. All packages that contain UN1845 Dry ice must be constructed so that internal pressure of carbon dioxide gas from sublimating dry ice will not rupture the packaging as stipulated in PI 954. UN1977 Nitrogen, refrigerated liquid and UN1963 Helium, refrigerated liquid when Open Cryogenic Receptacles (PI 202) is used, they must also be equipped with a venting feature.

Furthermore, DGR 6.2.17 “Composite Packaging” has no provision allowing venting holes. As stated in DGR 5.0.4.2 “Conditions Normal to Air Transport – Pressure”, at cruising altitude, the pressure differential can be 25 kPA to as high as 75 kPa which is normal for air transport.


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