(The 59 Edition DGR introduces segregation of Lithium Batteries with certain dangerous goods. Please guide us whether the one year grace period will apply to Overpacks and APIO ?)

Q.
The 59th Edition DGR effective 1 January 2018 introduces segregation of UN3480 and UN3090 (Section IA, IB) against dangerous goods of Class 1 other than Div. 1,4S, Div. 2.1, Class 3, Div. 4.1 and Div. 5.1. This new segregation requirement is to apply for Overpacks in 5.0.1.5.1, APIO in 5.0.2.11, Section IA, IB and Overpacks of Section II of PI965 and PI968 as well as for 9.3.A and DGR 9.3.2.1.3. There is a Note to DGR 9.3.2.1.3 where it reads: “Operators should take steps to implement these segregation requirement as soon as possible, however the provisions of this paragraph with respect to the segregation of lithium batteries from other dangerous goods as shown in Table 9.3.A do not become mandatory until 1 January 2019.” Would this grace period until 1 January 2019 apply to 5.0.1.5.1 Overpacks, 5.0.2.11 APIO, Section IA, IB and Overpacks of Section II of PI965 and PI968 ?  (30 Nov 17)

A.
The grace period until 1 January 2019 only applies to Table 9.3.A and DGR 9.3.2.1.3 Loading. There is no grace period for all the other issues and the lithium battery segregation starts from 1 January 2018. The reason why a grace period was introduced for Table 9.3.A loading segregation is because many airlines have acceptance, preparation and loading as a computerized procedure and may require time to upgrade it. On the other hand, overpacks, APIO, and packing requirements of PI965 and PI968 to be performed by the shipper requires immediate application and therefore no grace period was considered.


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