(A question on the interpretation of SP A72.)

Q.
SP A72 applies to UN1263, UN3066, UN3470, UN3469 Paint and Paint related material, UN1266 Perfumery products, UN1210 Printing ink and Printing ink related material. SP A72 reads: “A substance specifically listed by name in the List of DG must not be transported under this entry. Materials transported under this entry may contain 20% or less nitrocellulose provided the nitrocellulose contains 12.6% or less nitrogen.” I cannot understand the meaning of the first sentence of this special provision. What is the meaning of the first sentence and how does it apply? Can you give an example on this? (31 Dec 16)

A.
The first sentence of SP A72, “A substance specifically listed by name in the List of DG must not be transported under this entry.” is narrating the step of selecting proper shipping names according to DGR 4.0.1.2 の (a), (b), (c), (d).

The PSN of ”Paint” is a “group name” and in the hierarchy of proper shipping names “paint” is a group of substances that sits below the first level which is a specific named (pure) substance. So, if the “paint” is mainly “acetone” and is in PG II range, then it must be declared as “UN 1090 Acetone” and not “UN 1263 Paint”.


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