(I have a question on DGR State Variation JPG-023.)

Q.
I fail to understand State Variation JPG-23. I would appreciate a detailed explanation. (30 Sep 16)

A.
JPG-23explains that when Class 7 Radioactive Material is classified as “Excepted Package” (meaning “excepted quantity”) and has a subsidiary risk of another class, the subsidiary risk becomes the “Primary Risk” and radioactivity changes to a “Subsidiary risk”.

Even though radioactivity becomes a Subsidiary Risk, it is required to abide with the rules contained in DGR 10.5.8 “Excepted Package” as well as follow JPG-03 (must not contain pyrophoric or explosive radioactive material) and JPG-09 (ULDs must bear the radioactive label on two opposite sides of the ULD). The reversal of the Primary and Subsidiary Risk is written in 3.10.3 Radioactive Material of 3.10 Classification of Articles/Substances with Multiple Hazards.

The rules on Excepted Package spelled out in 10.5.8 must be adhered to. In Figure 8.1.O (Example 11) there is a sample of a declaration where Class 3 Flammable Liquid became the Primary Risk. Note that specification packages for radioactive material cannot be used any longer, and a Flammable Liquid Class 3 package PI 353 is now to be used.


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