(Please advise whether the net quantity of UN 3528 Engine, internal combustion, flammable liquid powered should be declared in kilograms or in litres.)

Q.
We have a question regarding Engines and Machinery which will shortly be declared as UN 3528 instead of UN 3166. At present, we are shipping them as UN 3166 but effective 1 April 2017, we will be using UN 3528. We declared UN 3166 on the DGD in kilograms using the net weight of the engine itself. Since UN 3528 is classified as Class 3, we are puzzled whether we should use litres or can keep on declaring them in kilograms. Kindly advise.  (31 Mar 17)

A.
As stated in DGR 8.1.6.9.2 Step 6 (a), Dangerous Goods Declarations must show the “Net Quantity”. The definition of ”Net Quantity” is stated in Appendix A. The “Net Quantity” is either the volume or weight of the dangerous goods described in the Proper Shipping Name. The Proper Shipping Name of UN 3528 is Engine or Machinery. Therefore, the net weight of the Engine or the Machinery must be used to indicate the “Net Quantity”. You can continue to use the net weight in making the declaration. Furthermore, the 25 kg rule of US State Variation USG-13 will apply to Engines and Machinery in Class 3, however US FAA has mentioned that until the rules in 49CFR gets amended, FAA will not take action against shipments prepared under ICAO TI 2017-2018.


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