(Question regarding the description entry in fine print.)

Q.
A shipper presented a DG declaration showing “with not more than 5% free sulphuric acid” against the proper shipping name of UN 2586 Alkylsulphonic acids, liquid. DGR 4.2 shows the words “with 5% or less free sulphuric acid” in fine print. The declaration is not made out strictly identical to what is shown in the DGR, however since the meaning is the same, and since the fine print is not part of the PSN, I concluded the shipment is acceptable. Please give us your guidance. (30 Jun 16)

A.
This is a simple English language question. DGR 4.2 shows in fine print “with 5% or less free sulphuric acid\". The submitted DGD shows “with not more than 5% free sulphuric acid\". The meaning is the same. There is no problem in accepting the shipment.

DGR 8.1.3.5 states, although it is preferable to duplicate what is shown in DGR 4.2, there is no problem even if singular or plural form is used in the PSN, or the order of the words are reversed, or whether British or American spelling is used. Furthermore those in fine print are descriptive information which is not part of the PSN. Even if the words “with 4% free sulphuric acid” is shown, it is acceptable as it is within the 5% criterion.

English expressions are different from Japanese. By saying “more than 5%” or “less than 5%” you are excluding 5% from the bench mark. If you want to include 5% in the bench mark, you need to say “5% or more” or “5% or less” or more precisely “equal to 5% or more” or “equal to 5% or less”.


[x close]


Copyright (C) 2003  Kinoshita Aviation Consultants All rights reserved.