(I have a question on DGR State Variation JPG-09.)

Q.
State Variation JPG-09 refers to a requirement to display the applicable hazard labels on two opposite sides of an ULD when radioactive material is stored within. Whereas DGR 10.7.4.3.2 states that for freight containers labels must be affixed to all 4 sides of the container. Please guide us which regulation is to be followed.  (31 Aug 16)

A.
Your question stems from the misinterpretation of the terms, “ULD” and “FREIGHT CONTAINER”.

First of all, State Variation JPG-09 is referring to “Unit Load Device – ULD” (a loading device used for unitizing bulk shipments). ULDs are pallets or duralumin or plastic containers owned by the airlines used to unitize bulk shipments for ease in loading. When radioactive material shipment is loaded in or on a ULD, the ULD must display the hazard labels (DGR 10.7.2) on two opposite sides of the ULD. Refer to Appendix A for the definition of “Unit Load Device” where it is explained that ULDs are pallets and containers used by the airlines to unitize bulk shipments for ease in handling and loading.

On the other hand, DGR 10.7.4.3.2 is referring to a “Freight Container” which is a strong rigid specially made “packaging” for the safe transport of radioactive material. Refer to Appendix A and look for “FREIGHT CONTAINER” with the trefoil symbol on the left margin. You will understand that it is a “type of package” used for transport radioactive material. Containers having less than 3 cubic meters inner volume is termed as “small freight containers” and those exceeding 3 cubic meters are called “large freight containers”. The freight container is a special container comprising of a lead shielding container to reduce radiation which is covered by a steel protective container with a total net weight of 5,000 kg or more. For such freight containers, labels must be displayed on all four sides.

To summarize, JPG-09 is referring to ULDs used for loading, and DGR 10.7.4.3.2 is referring to a special package for transport of radioactive material.


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