(Clarification on SP A197 regarding Environmentally Hazardous Substances.)

Q.
Some person interpret Special Provision SP A197 as if the inner packaging only contains quantity less than Net 5L or 5kg, SP A197 applies. What is the interpretation if you have 2 inner packages each containing 5L and these are packed in one outer packaging. The total quantity of the outer package is 10L. Will SP A197 apply? Kindly clarify.  (28 Feb 17)

A.
The answer is “YES”, SP A197 will apply. In the case of liquids under UN 3082, for single packagings if you have no more than 5L, and for combination packaging, if you have no more than 5L in any one of the inner packagings, provided the packagings meet 5.0.2.4.1; 5.0.2.6.1.1; 5.0.2.8, then SP A197 applies and the shipment will not be subject to any other provisions of the regulation.

Similar rule applies to solids under UN 3077. For single packagings if you have no more than 5kg, and for combination packaging, if you have no more than 5kg in any one of the inner packagings, provided the packagings meet 5.0.2.4.1; 5.0.2.6.1.1; 5.0.2.8, then SP A197 applies and the shipment will not be subject to any other provisions of the regulation.

The limit is 5L or 5kg regardless of outer or inner packagings, therefore, if you have 2 inner packagings each containing 5L or 5kg, and the total quantity of the outer packaging is 10L or 10g, SP A197 still applies.


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