(A question on Self-reactive substances.)
Q.
When shipping UN3229 Self-reactive substances, I was informed that approval of the Ministry of Transportation is required. The substance in question is UN3229 Self-reactive liquid type F (Bisphenol A type liquid epoxy resin, Dicyandiamide, Imidazole derivatives). I undertand if the substance is not listed in Appendix C. 1, a separate approval is required. Please give us guidance. (28 Dec 18)
A.
UN3229 is not listed in Appendix C. 1. Furthermore, all three substances shown in brackets are all not listed in Appendix C. 1. In Notes: 2. found at the head of Appendix C, it is stated that: “Self-reactive substances not listed in Appendix C. 1 are subject to classification approval by the national authority of the State in which the dangerous goods was manufactured. (See 3.4.1.2.4.1).”

Although not specifically naming the Minister of Transport, an approval by a competent authority of the State is needed. DGR 3.4.1.2.4.1 states that the classification of self-reactive sbstances must be made by the appropriate authority of the State in which the dangerous goods were manufactured on the basis of a test report.

It also explains the principles and procedures of the classification. It also stipulates that the statement of approval must contain the classification and the relevant transport conditions.

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