(Should we declare the quantity of UN 3164 with net quantity of gas or by gross weight of the device.)
Q.
When declaring UN 3164 Articles, pressurized, pneumatic as dangerous goods, please help us whether we should declare the net quantity of gas contained or by the gross weight of the article itself. Per Special Provision A114, majority of the hydraulic powered or gas powered cylinders can be handled as non-dangerous goods. If however, when shipping as dangerous goods, we could not find the answer in the IATA DGR whether we should declare with the “Net quantity of gas contained” or the “gross weight” of the device. Please give us guidance.  (28 Dec 18)
A.
When transporting UN3164 Articles, pressurized, pneumatic Div. 2.2, the declaration should be made by the “gross weight” of the device. According to SP A114, “Articles, containing gas intended to function as shock absorbers, including impact energy absorbing devices or pneumatic springs are not subject to these Regulations provided stipulations in (a) through (e) are cleared. Articles not fitting the stipulatios of SP A114 must be forwarded as dangerous goods and they need to be declared by the “gross weight” of the articles.

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