In this article, Andrew Shylan of AJS HAZ Training explores the carriage of dangerous goods using the excepted quantity (EQ) exemptions, concentrating on the surface movement of EQs and the subtle differences between road/rail and sea transport.
The carriage of dangerous goods using the EQ exemptions were a method of packing and shipment for air transport until the inclusion of the EQ provisions in the 2009 surface regulations and have since remained one of the few methods of packing that spans all modes of transport. There is little difference between the modal regulations (prior to 2015, there were some differences in E codes between surface and air) apart from the modal documentation requirements.
This article will concentrate on the surface movement of EQs and the subtle differences between road/rail and sea transport as regulated by the European Agreement concerning the International Carriage of Dangerous Goods by Road/Rail (ADR/RID) and the International Maritime Dangerous Goods (IMDG) Code.
What are excepted quantities?
EQs are substances belonging to certain classes, other than articles and are allocated to packing groups (PGs) II or III, however similar to the limited quantity (LQ) exemptions, a small number of Class 3 (without subsidiary risk) PG I can be EQs in some circumstances.
EQs are still subject to the training provisions of ADR and IMDG Chapter 1.3 for all surface transport, therefore all staff involved in the carriage and handling of the dangerous goods will require awareness and function-specific training which must be periodically refreshed.
The classification procedures of ADR (Part 2) and assignment of PG must still be complied with as well as certain requirements for the packaging (Part 4).
EQs are not to be confused with radioactive material packed in excepted packages as per ADR 18.104.22.168 or IMDG 22.214.171.124 codes.
Substances that can be carried using the EQ exemptions are identified within the surface regulations in column 7b of Table A in ADR/RID, and the dangerous goods list for the IMDG Codes as shown in Table 1.
Column 7b cross references to ADR 126.96.36.199 and indicates the quantities that may be carried and their maximum quantities per inner and outer packaging.
Code E0 will indicate that transport of the substance is not permitted using the EQ exemptions.
Codes E1–5 indicate the maximum quantity in grammes for solids or millilitres for liquids and gases or millilitres/grammes for mixed packing.
Maximum net quantity per inner packaging
Maximum net quantity per outer packaging
In grammes for solids and millilitres for liquids and gases (water capacity)
If mixed packing, sum of grammes and millilitres
Substances assigned E1, E2, E3, E4 and E5 can be packed in inner packages limited to 1ml/g and a total of 100ml/g per outer package, and are not subject to the provisions of ADR Chapter 3.5 apart from the requirement for a robust packaging that secures the inner packaging with sufficient cushioning material such that under normal conditions of transport the inner packaging will not break. The package must also be stack and drop tested. Being the odd one out, the air regulations refer to this packing method as “De minimus quantities”.
Class 3 PG I substances allocated an E3 code cannot be packed as above and must meet the full provisions of ADR Chapter 3.5.
All substances shall be packed into inner packaging constructed of plastic (with a minimum thickness of 0.2mm for liquids) and/or glass, porcelain, stoneware, earthenware or metal. These inner packagings must not be affected or significantly weakened by the substances or cause a dangerous effect or permeation of the substance that could constitute a danger under normal conditions of transport.
The closure of each inner package must be securely held in place with wire, tape or other positive means and moulded screw thread necks must be fitted with leakproof threaded type caps. Each inner package shall be placed into intermediate packaging with cushioning material in such a way that under normal conditions of transport, it cannot break, be punctured or leak its contents. For liquids, the intermediate packaging shall contain enough absorbent material to absorb the entire contents of the inner packaging; the absorbent material may also be the cushioning material. The dangerous substances must not react dangerously with the cushioning or absorbent material and, regardless of orientation, the package shall completely contain the contents in case of breakage or leakage.
The intermediate packaging shall be securely packed into a strong, rigid outer packaging made of wood, fibreboard or other equally strong material.
Testing for packages
The complete package as prepared for transport, with inner packaging filled to no more than 95% for solids and 98% for liquids, shall be capable of withstanding a drop test onto a rigid non-resilient surface from a height of 1.8m without any breakage or leakage of any inner packaging and without significant reduction in effectiveness. There are different standards for the drop test orientation depending on whether the outer package is a box shape or in the shape of a drum.
A stacking test shall be carried out for 24 hours with a force applied to the top of the test sample to replicate the weight of a three-metre high stack of identical packages including the test sample. These tests, although not requiring an authorised test facility or acknowledgment by the competent authorities, must be documented and records made available for future package production samples.
The substance used during the testing must have the same physical characteristics as the substance to be carried including mass, grain size, relative density and viscosity.
Marking of packages
All packages containing EQs shall be durably and legibly marked with the marks shown below in Figure 1.
The marks in the shape of a square must have a minimum dimension of 100mm × 100mm and the package must be large enough to accommodate this mark. The mark must be red or black on a white or suitably contrasting background or may be printed directly onto the package. Only the number of the first or only label number shown in column 5 of Chapter 3.2 of ADR or column 3 (ie the class) of the dangerous goods list (IMDG Codes) needs to be shown. The name of the consignor or the consignee shall be shown if it is not already shown elsewhere on the package. Although there is no mention made in any of the regulations of a requirement to show the consignor or consignee’s addresses, this is often seen on the mark.
Use of overpacks 2017 change
When an overpack now contains dangerous goods packed and marked as EQs and the marks representing all the dangerous goods are not visible, the overpack shall be marked with the mark shown in Figure 2 below and shall also be marked with the word “OVERPACK” at least 12mm high and for ADR/RID in the official language of the country of origin and also, if that language is not English, French or German, in English French or German unless any agreements provide otherwise.
Maximum number of packages per CTU
The number of packages that can be placed into a vehicle or container has been restricted a maximum of 1000 per cargo transport unit (CTU).
This is the main area of difference between the different transport modes. Road and rail (ADR/RID) requires any document that accompanies the consignment to include the statement “Dangerous Goods in Excepted Quantities” and to indicate the number of packages. Sea (IMDG Codes) requires the information specified in Chapter 5.4 (as shown below) with the additional statement “Dangerous Goods in Excepted Quantities”.
For example, a chemical kit packed as EQ would be shown as: UN 3316, Chemical kit, 9, PG III (56°C cc), “Dangerous Goods in Excepted Quantities” Air (ICAO/IATA) rather surprisingly does not require a shipper’s declaration but if a document such as a bill of lading or an air waybill accompanies the shipment the statement “Dangerous Goods in Excepted Quantities” is required along with the number of packages.
Placarding and marking of CTUs
There is no requirement for road, rail or sea to indicate on the CTU the presence of EQ packages within the vehicle or container.
Mixed loading, stowage and segregation
The provisions of Chapter 7.5.2 ADR on mixed loading and 7.2 IMDG on segregation do not apply to substances packed as EQs in relation to other dangerous goods.
This article has highlighted the benefits to those who consign very small amounts of dangerous substances or trial samples of a dangerous substance that would be accepted on all modes of transport with little or no changes between those regulations. Once a substance is packaged, marked and documented as an EQ, it is, for all intents and purposes, not subject to as many of the regulatory requirements based on a risk approach of the very restrictive quantity requirements per inner and outer packaging.