(Queston on Special Provisions relative to UN3077 Marine pollutant.)
Q.
There are Special Provisions SP A97, A158, A179 and A197 listed for UN3077 Marine pollutant. We understand that if the substance do not satisfy the provisions of these Special Provisions, the substance in question cannot be regarded as being “not restricted”. Please guide us whether our understanding is correct. (30 Jun 20)
A.
First of all, the Proper Shipping Name for UN 3077 is Environmentally hazardous substance, solid, n.o.s.★. The Special Provision numbers listed in Column “M” of the Dangerous Goods List do not necessarily indicate whether the substance or artice must be declared as dangerous goods or as “not restricted”. They define the conditions that must be followed or indicate other requirements.
SP A97 spells “These entries must be used for environmentally hazardous substances but do not meet the classification of other class or other Class 9 substance. They may also be used for wastes covered under Basle Conventon.”
SP A158 (335) reads: “Mixtures of solids not subject to these Regulations or solids classified by shipper as Environmentally hazardous substance, liquid or solid (UN3082 or UN3077) may be transported provided no free liquid is visible at time of packaging or loading. Sealed packets and articles containing less than 10mL of environmentaly hazardous liquid, absorbed into a solid material but with no free liquid in the packet or article, or containing less than 10 g of environmentaly hazardous solid are not subject to these Regulations.”

SP A179 states: “For UN3077, irrespective of the maximum net quantities specified in Columns J and L of the Dangerous Goods List, intermediate bulk containers (IBC) with a maximum net quantity not exceeding 1,000 kg are permitted in accordance with Packing Instruction 956.”

SP A197 (375) reads: “These substances when transported in single or combination packaging containing a net quantity per single or inner packaging of 5L or less for liquids or having a net weight of 5 kg or less for solids are not subject to any other provisions of these Regulations provided the packaging meet the general provisions of 5.0.2.4.1 (Packaging Quality), 5.0.2.6.1.1 (Direcct Contact of Packaging) and 5.0.2.8 (Ullage).”
As explained, Special Provisions SP A158 and SP A179 are the only two having to do with conditions for defining “Not Restricted”.

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