In this feature article Consultant Editor Desmond Waight, who was involved in the developments that led to the introduction of limited quantity packages (LQ), explains what is meant by this term and what the associated requirements are.
In the early 1980s the UN Committee of Experts on the Transport of Dangerous Goods had agreed changes to the requirements for packaging dangerous goods to require that from 1989, they were to be design type tested and approved to a performance-orientated packaging system.
In the UK, there was concern among trade associations representing the paints, adhesives, and printing ink manufacturers that the traditional tinplate packagings used for smaller sizes of these products would not pass the proposed UN tests. There was also great concern that they could not be readily redesigned at an economic cost to enable them to pass such tests.
Accordingly, in 1983, the involved trade associations, together with the Metal Packaging Manufacturers Association and the Association of Drum Manufacturers, supported by the Printing Industry Research Establishment (PIRA), set up a project with the aim of finding a way for fillers and users to comply with the incoming international requirements.
Following an international conference held in London in 1986, proposals for amendments of the UN provisions were put forward which eventually led to the adoption by the UN, and thus the modes, of the relaxations for combination packages containing dangerous goods in inner receptacles of restricted sizes, which we now know as “Limited Quantity packages” (LQ). This was on the basis that when divided up into numerous inner receptacles, the goods, while remaining just as intrinsically hazardous, presented a vastly reduced risk compared to the same goods carried in larger packages or in tanks.
Since then, changes to the scheme have occurred every two years, sometimes minor but at other times the changes have been major, and this trend looks set to continue. Indeed, some changes were agreed for the UN 18th revised edition which was published in summer 2013 and can be expected to be adopted by the modes from 2015. These changes however, are mainly editorial and also, to better define the size of the LQ mark.
Also, it is sometimes felt that complying with the full requirements for dangerous goods packaging is far easier than understanding the complexities of “limited quantities”, with many forgetting to include the word “packages”, which can lead to confusion with issues connected to small loads of dangerous goods. Unfortunately, the reference used is just “LQ” or “LQs”, rather than “LQP” or “LQPs”.
The current scheme
The current scheme is found principally in chapter 3.4 of the UN Orange Book, ADR, RID, ADN, IMDG Code and the International Civil Aviation Organization (ICAO) Technical Instructions (TIs). The International Air Transport Association (IATA) meanwhile, includes the requirements largely in Section 2 of its Dangerous Goods Regulations (DGRs).
Because air transport rules for limited quantity packages are so different to the surface mode provisions, in the rest of this article no further mention of the air mode rules will be made. Also, we will not refer to RID (rail) and ADN (inland waterway) as these modes are not frequently used surface transport modes.
The UN, ADR and IMDG Code schemes set out in their dangerous goods lists (Table A of chapter 3.2) for each type of dangerous good (UN number and packing group level, if applicable), the maximum quantity per inner receptacle that is permitted under the scheme. If this quantity is zero, then relaxations for limited quantity packages are not available. The maximum permitted under the scheme for any dangerous good is either 5l for liquids or 5kg for solids.
LQ packages have to consist of inner receptacles, not exceeding the maximum amount per receptacle permitted for the particular dangerous goods or articles (such as aerosols), in a suitable outer packaging with a gross weight not exceeding 30kg gross. The receptacles or articles may also be permitted packed on shrink- or stretch-wrapped trays subject to a maximum of 20kg gross weight.
There are also a number of specification requirements that have to be met; you should refer to the appropriate modal requirements for details.
LQ packages do not require labelling with the class danger label, but are required to be marked.
In the original proposal, worked up by a number of interested parties in the UK, the idea was for a framed rectangular mark in which the UN number, or UN numbers, of the goods in the package would be displayed. The size of the rectangle mark would have to exceed a certain minimum, but could be made larger in the case of a large number of UN numbers to be marked. This was based on the USA requirement for marking what was known there as Other Restricted Materials, type D (ORM-D) .
Unfortunately, when this proposal came to be discussed in the UN committee, one of the experts expressed the view that the mark should be diamond-shaped, as diamonds were, in his view, associated with danger.
As it was then late on a Friday afternoon in the July meeting of the UN, the committee, after a very short discussion, agreed that the mark should be diamond-shaped with the applicable UN Number or Numbers within.
This led to problems, with ADR/RID deciding that it would be possible under their modal requirements to replace a multitude of UN numbers with the letters “LQ”. However, the sea mode did not follow suit.
This led the UN in its 16th revised edition to introduce the current specification for the mark, as shown in Figure 1, with a variant as shown in Figure 2 for packages which also meet the additional requirements for packaging of LQs under the air freight mode (air freight also requiring that class labels be applied).
Figure 1: Current LQ mark
Figure 2: LQ mark for packages that are also compliant with air construction and testing requirement provisions
ADR, however, still provides that packages bearing marks in compliance with the previous requirements (see Figures 3, 4 and 5) can still be used for road transport until June 2015. They are not however, acceptable for sea journeys.
Figure 3: Where a single UN Number is in the package (with/without other dangerous goods)
Figure 4: Where multiple UN Numbers are in the same package
Figure 5: Option for multiple UN Numbers (that was only ever acceptable for European surface)
Neither ADR nor the IMDG Code requires the indication of supplementary classification as dangerous to the aquatic environment by affixation of the Marine Pollutant (MP)/Environmentally Hazardous Substances (EHS) mark. This “way up” marking is however required by both when applicable.
This is another area of some difference, even neglecting the special case of the air mode. For sea, full transport documentation is required, with the addition of the words “limited quantity” or the annotation “LTD QTY” after the core information.
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.
Placarding of CTUs
Here again, there are substantial differences between the various modes.
ADR only requires marking of the transport unit, with an enlarged version of the LQ mark, when the transport unit exceeds 12t and is carrying in excess of 8t of LQ packages. ADR permits an LQ mark to be shown, if applicable, when the transport unit displays a placard consequent on the presence of some fully regulated goods.
Conversely, the IMDG Code requires the marking of the Cargo Transport Unit (CTU) with an enlarged version of the LQ mark, when carrying any quantity of LQ packages, unless the CTU is also carrying fully regulated packages requiring that the CTU carry a class placard (when no LQ mark is permitted). When the LQ goods are a Marine Pollutant (MP), the Code requires the CTU to bear an enlarged MP mark, even though the LQ packages do not themselves need to bear this mark.
Here, at last, there is uniformity, with all modes requiring the training of all staff prior to any involvement with the transport of dangerous goods in LQ packages. This extends even to those who deliver supermarket shopping to customers (when LQ goods are often involved, although with the outer packaging having been discarded, as permitted by the Approved Derogations and Transitional Provisions (ADTP) Road derogation No. 4).
Last reviewed 24 October 2013