（Please guide us on the interpretation of Special Provision A197.）
Q.
We are shipping Environmentally Hazardous Substance in solid form. Please guide us how to interprete SP A197. I take it that a Single Packaging may hold 5kg, and an inner package may hold 5kg. We place in one carton, 5kg plastic bags X 2 = 10 kg. May we apply SP A197 to our shipment? (28 Dec 19)
A.
SP A197 means one single packaging may hold a maximum of 5 kg, and one inner packaging may hold a maximum of 5kg. In your case, your inner packaging is holding 10 kg therefore you cannot apply SP A197. It all ends up to whether you regard one single plastic bag as one inner package, or you regard a bundle of 2 plastic bags as one inner packaging.
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