（A question on APIO of Dangerous Goods with Exempted Dangerous Goods.）
Q.
Hitherto, we did not have an opportunity to transport multiple dangerous goods in an “All packed in One” type packaging, We are now going to practice “APIO” type shipments of SEALANTS which may consist of two or more dangerous properties as PARTS. We would have common cases where we would be placing a small quantity of UN3082 Environmentally hazardous substance, liquid, n.o.s.★ for which SP A197 is applicable with packages of Flammable Liquid. With such a scenario, while UN 3082 can be shipped as “an exempted dangerous goods”, if we are to ship this UN 3082 as APIO with Flammable Liquid, wouldn’t we have to consider UN 3082 as dangerous goods and include it in the “Q” value calculation? Or, may we leave UN 3082 out of the “Q” value calculation and just simply show the Flammable liquid on the DGD? We need your guidance. Even if the UN 3082 maybe less than 5 L applicable for SP A197, if the quantity of the Flammable Liquid is close to the Q = 1.0 benchmark, the resultant “Q” value would exceed 1.0. Thence, we feel we may have to include UN 3082 in the “Q” value calculation. We are mixed. Please clarify? (31 Jul 21)
A.
As for UN 3082 Environmentally hazardous substance, liquid, n.o.s.★, when SP A197 can be applied, as it says in SP A197, i.e., “packagings of 5L or less and 5kg or less are not subject to any other provisions of these Regulations, provided the packagings meet the general provisions of 5.0.2.4.1 (Packaging Quality), 5.0.2.6.1.1 (Direct contact of packagings) and 5.0.2.8 (Ullage), there is no need to apply the “Q” value calculation spelled out in 5.0.2.11 (g).
Since “any other provisions of these Regulations” are not applicable, the Dangerous Goods Declaration need only declare the Flammable Liquid. UN 3082 will be shown on the AWB only. You will enter in the “Nature and Quantity of Goods” box on the AWB, (UN 3082) Environmentally hazardous substance, liquid, n.o.s.★ (name of substance) (Quantity in Litres not exceeding 5L) and SP A197. Since the substance has been exempted from being dangerous goods, you will place the UN number in brackets.
Futhermore, as it says in Notes 2 of 7.1.5.3.1, for SP A197 applicable substance, the environmentally hazardous substance mark (Figure 7.1.B) is not required. And as it says in the last part of Notes 2, since you are not intending to transport the substance as dangerous goods, you need not follow the other provisions. If you prefer to send the item as environmentally hazardous substance, then, all applicable parts of the Regulations must be followed.
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