(Question on how to declare empty uncleaned packagings on the DGD.)
Q.
DGR 8.1.6.9.2 (b) refers to how to declare empty uncleaned packagings, but the precise location of entering the information on the DGD is not crystal clear, There is a Note but the location again is not clear. Should it be before or after the “first sequence”? We figure entry to the “Quantity and Type of Packing” column would be appropriate but there are cases where the information is entered in the ”Proper Shipping Name” column. Please guide us with the correct location of entering the empty and uncleaned information.  (31 Oct 20)
A.
DGR 8.1.6.9.2 (b) states: “for empty uncleaned packagings containing a residue of dangerous goods, other thn Class 7, must be described as such by, for example, placing the words “EMPTY UNCLEANED” or “RESIDUE LAST CONTANED” before or after the first sequence as shown in 8.1.6.9.1. There is no requirement to show quantity, only the number and type of packagings.”

There is also a Note saying: “Irrespective of the allowance for the words “EMPTY UNCLEANED” or “RESIDUE LAST CONTAINED” to be placed before or after the first sequence, it is recommended that the wording be placed after the first sequence, for example, “1 Steel drum, empty uncleaned”.

As recommended by the Note, it is appropriate to enter the wording in the “Quantity and Type of Packing” column, for example, “1 Steel drum, empty uncleaned” since the focus is on the state of the packagings. . The information will also be clear by entering in the “Proper Shipping Name” column. As long as the information is properly transmitted and understood, the location of entry is of less importance. Entry in the “Proper Shipping Name” column may arouse more attention. The importance is to ensure transmission of information.

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