（Question on newly added Note #2 to DGR 8.2.3 in DGR 62nd Edition.）
Q.
A new Note #2 has been added to DGR 8.2.3“Shippers’ Declaration not required” in DGR 62nd Edition. It reads: “8.2.3 does not apply when UN1845, Carbon Dioxide, solid (dry ice) used as refrigerant for substances or articles not subject to these Regulations is described on a Shipper’s Declaration.” I read this Note as “8.2.3 does not apply when UN1845 Dry Ice used as a refrigerant is declared on a DGD for substances/articles not subject to the Regulations”, right? If my reading of this Note #2 is correct, is there such a case where we can issue a DGD for Dry Ice used as refrigerant for non-DG? If my interpretation is wrong, please enlighten me with an example. I am trying to figure out how this Note #2 is applied but unable to make sense of the application. (28 Feb 21)
A.
Note #2 in question has been added to complement the changes to Packing Instruction PI954 subparagraphs (c) and (d) of Additional Packing Requirements in packages. The revision on PI954 refers to dry ice used as refrigerant for non-DG items and declared on a DGD. PI954 (c) reads: “(c) the Shipper’s Declaration requirements of subsections 8,1 and 10.8.1 only apply when Carbon dioxide, solid (dry ice) is used as a refrigerant for dangerous goods that require a Shipper’s Declaration or when Carbon dioxide, solid (dry ice) used as a refrigerant for substances or articles not subject to these Regulations is described on a Shipper’s Declaration.” Note #2 is inserted to follow up on this revision.
Copyright (C) 2003 Kinoshita Aviation Consultants All rights reserved.