(A question on how to enter the PG on a Declaration for UN3316 Chemical Kit.)
Q.
We are confused whether or not to enter the PG rating for UN3316 Chemical Kit on the DangerousGoods Declaration form. In checking SP A44, it says “The assigned packing group must be shown on the Shipper’s Declaration.” Please give us guidance.  (28 Feb 19)
A.
I refer to the “Significant changes and Amendments to the 60th Edition (2019)” found at the starting pages of the Dangerous Goods Regulation. On Page xxiv 4-Identification and 4.2-List of Dangerous Goods, there is a reference on UN3316 Chemical Kit under the second bullet hole. It says: “modification to the entries for UN3316 - Chemical kit and First aid kit to delete reference to packing groups II and III. The shipper must assign the appropriate packing group based on the most restrictive packing group in the kit as specified in special provision A44.”

PG indication in Column “E” for UN3316 on the blue pages is deleted. SP A44 obliges the shipper to ascertain the most restrictive PG in the kit. That PG must be shown on the DGD, and the packaging must conform to that PG performance standards.

Where the kit contains only dangerous goods to which no packing group is assigned, a packing group must not be indicated on the DGD. Per PI 960 under “Additional Packing Requirements” it says, “packagings must meet Packing Group II performance standards”.

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