A.
DGR 7.2.8 does not apply to this case. DGR 7.2.8 is saying labels of other regulations may be used provided the color, design and shape will not be in conflict or get confused with the DGR labels. This case in question shows a clear disparity between the DGR label and the GHS pictograms. UN3148 Water reactive liquid, n.o.s.★ Div. 4.3 does not have a corrosive hazard, yet a GHS pictogram indicating the existence of a corrosive hazard is applied on the package. Something is wrong.

As you know, GHS Regulation is intended for the safety of individuals who are using the dangerous substanes, while the DGR is intended to protect the people engaged in the transport of dangerous substances.

UN3148 do not have a corrosive hazard. It only has a Div. 4.3 hazard. It is hard to believe that after opening the package, the substance gains a corrosive hazard. DGR Div 4.3 hazard can be covered by the GHS ”Flammable” and ”Harmful” pictograms. The reason why it has a “Corrosive” pictogram must be pursued. For such shipments, the correct step is to secure a Safety Data Sheet (SDS) and screen through the document to ascertain the reason why a GHS Corrosive pictogram is applied. Thence per DGR 3.8.3 there is a need to determine whether the corrosivity is below or above PG III level. If the corrosivity is below PG III, the corrosivity can be ignored. If, however, the corrosivity is above PG III level, the substance will have to be categorized as having DGR Class 8 hazard and UN3129 Water reactive liquid, corrosive, n.o.s.★ Div. 4.3 (Class 8) will have to be applied causing need of segregation requirements against certain other dangerous shipments. Such disparity between GHS and DGR must not be overlooked but clarified. Thence, the corretct UN number and PSN should be determined and the correct DGR label must be applied.

Information on GHS pictogram is shown in Appendix B 4 of the DGR.