(Please advise on how to assign a Proper Shipping Name to a substance used for repairing aircraft parts.)

Q.
We have a “SEALANT” used for repairing aircraft parts. Three different liquids are contained each in independent closed chambers of a unit. Liquids “A”, “B” and “C” are mixed when used as a sealant. Liquid “A” is UN 3082 Environmentally hazardous substance, liquid, n.o.s. but in very small quantity. Liquid “B” is not dangerous goods. Liquid “C” is UN 1993 Flammable liquid, n.o.s. PG III and is the predominant substance. Please guide us how to select the proper shipping name in completing the Shipper’s Declaration. (30 Sep 17)

A.
Liquid “A” is UN 3082 Environmentally Hazardous substance, liquid, n.o.s. but the quantity is very small. Liquid “B” is not dangerous. Liquid “C” is the predominant substance and is UN 1993 Flammable liquid, n.o.s. PG III. The liquids are contained in sealed independent chambers. For use as sealant, the liquids are mixed. If details of both liquids “A” and “C” are to be shown on the Declaration, the PSN would be: “UN 1993 Flammable liquid, n.o.s. (……….) and UN 3082 Environmentally hazardous substance, liquid, n.o.s. (……….) contained in separate closed chambers forming a unit and used as a “sealant” when mixed”. In the Quantity column, you will show the individual net quantities as: “One unit contains …… mL; Total …… units in one fireboard box; Total quantity …… Fibreboard boxes or …… L”.

Such a declaration would become complicated, and since UN 3082 is of a very small quantity, it can be disregard and simply declared as UN 1993 Flammable liquid, n.o.s. (………). Per SP A197, if the quantity of UN 3082 is less than 5L, it is not subject to the conditions of the Regulations.


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