Last reviewed 7 November 2013
In this feature article Consultant Editor Desmond Waight explains the concept of and requirements for excepted quantity packages (EQ), as well as their recent sub-set of “de minimis quantities”.
The introduction of excepted quantity (EQ) package provisions by the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCETDG) is a reasonably recent development. It should be noted here that it is “excepted” and not “exempted” package provisions that are being discussed. Dangerous goods in EQ packages are still dangerous goods and are subject to the controls of the modal regulatory requirements.
The idea of EQ packages had been around for a number of years in the air mode, where it offered substantial benefits to those consigning very small receptacle sizes of dangerous goods. However, the concept was not recognised at that time by the other modes that are likely to be of interest to readers, ie sea and international and domestic surface carriage in the wider “European” area (ie ADR, RID and ADN).
The concept behind EQ packages is really an extension of the risk-based approach that permits relaxations for dangerous goods packed in limited quantity (LQ) packages. However, it is extended so that, provided the amounts per receptacle are very restricted, and the amounts per package are quite restricted, then in many ways, once packaged, marked and documented, the dangerous goods may be treated almost as if they were exempted from the other regulatory requirements.
From 1 January 2013, the principal was extended to what is known as de minimis quantities, where provided the amount per receptacle is extremely restricted and the amounts per package very restricted, then, subject to some packaging provisions, the goods may be treated as if they were not in fact dangerous goods. This new variant will be very important for those who develop new molecules and need to ship the tiny trial quantities.
A principal difference between the LQ package provisions and the EQ package provisions is that a loss of care was taken to ensure that the EQ package provisions should be accepted without change by all modes.
The current scheme
The current EQ package scheme is found in Chapter 3.5 of the UN Orange Book and is reproduced faithfully in Chapter 3.5 of ADR, RID, ADN, IMDG Code, and ICAO Technical Instructions (TIs), although ADR is reorganised slightly compared to the UN and IMDG Code (in that the maximums per package are included at the start of ADR 184.108.40.206, whereas in the UN and IMDG, these are separately listed in 220.127.116.11 (d)).
The International Air Transport Association (IATA) is again the odd one out by including the requirements largely in Section 2.6 of their Dangerous Goods Regulations (DGRs).
However, all the modes set down in their dangerous goods lists (eg ADR Table of Chapter 3.2) for each type of dangerous goods (UN number and packing group level, if applicable), an EQ package code, starting with the letter “E”. Unfortunately however, at this time, there may be a difference in the code allocations between the air mode and the surface modes. However, at the December 2012 UNSCETDG meeting, it was agreed to amend the assignment of E codes to ensure multimodal harmonisation with the ICAO Technical Instructions, with some changes as proposed by the representative of ICAO. This will hopefully mean that from 1 January 2015, E code allocations will be uniform across all modes. Meanwhile however, one has to check each particular mode or modes requirements to ascertain their applicable E codes.
If code E0 is allocated, then that particular dangerous good may not be offered on that mode as an EQ package.
However, if one of E1 to E5 is allocated, then the dangerous goods may be shipped as EQ packages, provided that the amounts per inner receptacle and amounts per package do not exceed the amounts set out in the table below.
Maximum per receptacle*
Maximum per package**
* in grammes for solids and millilitres for liquids and gases (water capacity)
** if mixed sum of grammes and millilitres
EQ packages have to consist of inner receptacles, an intermediate packaging and an outer packaging. The components must meet the specifications laid down, eg an inner receptacle of plastic for liquid dangerous goods must be at least 0.2mm in thickness. Also, the package must be at least large enough to take a 100mm2 package mark (see below).
In addition, design type samples of the packaging must be constructed and tested as laid down, although this does not have to be at an approved test house, nor does the satisfactory passing of the test have to be acknowledged by a Competent Authority (CA). However, the testing must be appropriately documented and the documentation available for any subsequent series production sample to be compared against.
LQ packages do not require labelling with the class danger label, but are required to be marked.
The mark, developed by the expert from the UK, is shown below. This is reproduced either in black or red on a contrasting (ie not necessarily white) background. The mark is a square with a 100mm side length.
If a number of EQ packages are collated into an overpack, then the overpack shall be marked with the EQ mark, unless the EQ marks on the inner packages are clearly visible. However, the overpack does not have to indicate “OVERPACK”, unlike for LQ packages.
This is an area of difference. Road and rail only requires that any other document accompanying the goods shall include the statement “Dangerous Goods in Excepted Quantities” and indicate the number of packages. Sea freight requires a full transport document (ie a Dangerous Good Note (DGN)) with the above words. Surprisingly perhaps, air does not require a normal dangerous goods shipper’s declaration, but does require the bill of lading or airway bill to include the above statement and the number of packages.
Under ADR however, the only requirement is that the consignor shall advise the carrier, in advance of carriage (something that is not required in the case of a transport document), of the total gross mass of LQ packages that are being consigned.
Marking of CTUs
Sea does not require cargo transport units (CTUs) to display any mark in consequence of the presence of EQ packages within.
All modes set a maximum of 1000 packages per CTU.
Here, at last, there is uniformity, with all modes requiring the training of all involved staff prior to any involvement with the transport of dangerous goods in EQ packages, although the scope of training required is larger for sea and air freight than for European surface transport.
De minimis EQ “exempted dangerous goods"
The UNSCETDG, recognises that extremely small amounts of dangerous goods, while possessing the hazards, do not pose any risks if the good is appropriately packaged.
Accordingly, from 1 January 2013, if a dangerous good is assigned code E1, E2, E4, or E5, and the maximum net quantity per inner receptacle does not exceed 1ml for liquids and gases (or 1g for solids), and is packaged as laid down for other EQ packages (with a slight variation), and that package does not exceed 100g or ml; then the goods do not have to meet any other provisions of the modal requirements.
In this brief article, we have attempted to describe the EQ package provisions. This article should not be used in substitute for checking the exact requirements in the applicable modal requirement(s).