Q.
Reference is made to the definition of SP A46. SP A46 reads: “Mixtures of solids which are not subject to these Regulations and flammable liquids may be transported under this entry without first applying the classification criteria of Division 4.1, providing there is no free liquid visible at the time the substance is packaged and for single packagings the packaging must pass a leak proofness test at the Packing Group II level. Small inner packagings consisting of sealed packets or articles containing less than 10 mL of a Packing Group II or III flammable liquid absorbed into a solid material are not subject to these Regulations provided there is no free liquid in the packet or article.”

My shipper says their shipment is Alcohol Wipe and SP A46 can be appied to their shipment. My observation is negative as each alcohol absorbed tissue is not individually packed in a sealed packet. There are 50 Alcohol Wipes in one plastic bag. I therefore think this item should be assigned as UN 3175 Solids containing flammable liquids, n.o.s. or ID 8000 if the item satisfies the provision f PI Y963. (31 May 20)