All transport modes have adopted essentially the same standard for packaging, marking and labelling. Differences between the codes are discussed below.
These specify the packaging which may be used for each dangerous good. These packing instructions restrict the style (drum, box, jerrican etc), material (plastic, steel, fibreboard etc) and maximum permitted capacity for a particular style/material combination, or the maximum capacity per single packaging.
Air and sea
As well as complying with UN specification packaging, air and sea modes may further restrict the quantity of dangerous goods that can be shipped in a particular type of inner packaging and the total quantity per outer packaging (combination packaging) or a single packaging (i.e. a closed head drum). The quantity limits imposed in the air and sea modes can be lower than those specified in the UN Recommendation Packing Instructions. It is vital to check the requirements specified in the relevant modal code.
The Land Transport Rule incorporates by reference NZS 5433, which refers to the UN packaging instructions.
Comparison of package size limitations
Table 4 compares the allowable quantities that can be packed into a glass bottle inner packaging and a wooden box outer packaging for acetaldehyde.
Packaging requirements for UN1089 ACETALDEHYDE
|UN||NZS 5433||IMDG||ICAO & IATA|
|Passenger aircraft||Cargo aircraft|
|Maximum capacity glass bottle/jar ‘inner’||10 L||10 L||10 L
|Maximum capacity wooden box ‘outer’||150kg||150kg||75 kg||Forbidden||30 L
|Steel Drum (closed head)1A1 (as single packaging)||250 L||250 L||250 L||Forbidden||30 L|
|N = net, G = gross|
Small Packages – land transport only
Dangerous goods transported as small packages must comply with inner package quantity limits in Schedule 2 of the rule (Dangerous Goods in Limited Quantities and Consumer Commodities). The packaging must comply with clause 3.2(2) and 3.2(3) of the rule.
Dangerous Goods in Limited Quantities
Land and sea transport use the same quantity limits, type and style of packaging. The requirements for air transport are substantially different (refer to ICAO Technical Instructions or IATA Dangerous Goods Regulations for details).
The Land Transport Rule allows the abbreviation ‘DGLQ’ for dangerous goods in Limited Quantities. However, IMDG, ICAO and IATA do not recognise this abbreviation - their terminology is ‘Limited Quantities’ or ‘Ltd Qty’. ‘Ltd Qty’ is also acceptable for land transport.
Packaging for the land and sea transport of dangerous goods in Limited Quantities has to meet the general requirements specified in the relevant code, but does not have to pass the UN performance tests (i.e. drop test, stack test etc).
Air transport requires packaging for dangerous goods in Limited Quantities to be able to pass the stack test and withstand a drop of 1.2m onto the point that is most likely to sustain damage. This is a similar standard to Packing Group II requirements (minus the need for official testing in an approved laboratory).
Shrink or stretch-wrapped trays are not acceptable for air transport.
These are dangerous goods in Limited Quantities for personal use or household use that are packaged and distributed in a form suitable for retail sale. The term Consumer Commodities is used by IATA in their Dangerous Goods Regulations and in the Land Transport Rule: Dangerous Goods 2005, Rule 45001/1.
Land transport offers reduced requirements for goods defined as Consumer Commodities. Its definition of Consumer Commodities includes goods intended for recreational use. The rule limits the quantity to 1,000 kg per load. Any part of the load that exceeds 1,000 kg must fully comply with the rule.
The IATA regulations recognise Consumer Commodities as a proper shipping name and assigns it to ID number 8000 (as opposed to a UN number), Consumer Commodities, and is classified as Class 9 Dangerous Goods. Products that are packaged and identified as ID 8000, Consumer Commodities, Class 9 in accordance with aviation requirements may be transported on land in New Zealand under the Small Packages provisions of the dangerous goods rule. This enables IATA Consumer Commodities to be transported without any changes to the packaging or identification of the goods.
The term ‘Consumer Commodities’ is not used by the UN Recommendations or IMDG, however, reduced requirements for marking and labelling apply to dangerous goods in Limited Quantities for personal use or household use that are packaged and distributed in a form suitable for retail sale.
The UN Recommendations, IMDG Code, IATA Regulations, ICAO Technical Instructions and NZS 5433:2007 provide additional information as special provisions for some substances.
These special provisions contain very important information and must be read. They specify additional or reduced requirements for certain circumstances and provide definitions for terms used.
The special provisions are usually listed in a table within the code. In all codes a reference to the applicable special provisions is given in the list of dangerous goods. For example, UN2465 DICHLOROISOCYANURIC ACID, DRY or DICHLOROISOCYANURIC ACID SALTS has the special provision that the dihydrated sodium salt is considered non-dangerous. Thus the dihydrated sodium salt of dichloroisocyanuric acid is not a dangerous good for transport.
The IMDG Code includes an additional set of special provisions numbered from 900. This numbering identifies them as being unique and is applicable to maritime transport only.
Proper Shipping Name
The UN Recommendations, IMDG and NZS 5433:2007 have traditionally written the Proper Shipping Name in upper case. Anything written in lower case is considered to be additional information. ICAO and IATA show the Proper Shipping Name by using bold typeface, rather than capital letters.
Goods too dangerous to transport
Some goods are considered too dangerous to transport. The IATA Regulations show these as being FORBIDDEN in the list of dangerous goods.
In special circumstances, the Regulatory Authority may approve the transport of certain forbidden dangerous goods.
Pollutants and environmentally hazardous substances
The UN Recommendations has adopted the GHS classification criteria for Acute Aquatic Toxicity category 1 & 2 and Chronic Aquatic Toxicity Category 1 for environmentally hazardous substances. Special Provision 179 permits the designation of ‘ENVIRONMENTALLY HAZARDOUS’ to be used with substances and mixtures which are dangerous to the aquatic environment, or which are marine pollutants, and that do not meet the classification criteria of any other class, or another substance within Class 9. This designation may also be used for wastes not otherwise subject to these regulations but which are covered under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, and for substances designated to be environmentally hazardous substances by the competent authority of the country of origin, transit or destination which do not meet the criteria for an environmentally hazardous substance according to the relevant transport code or for any other hazard
The IMDG lists many substances as pollutants in the general index or alphabetical list. These are identified by a P for Marine Pollutant and PP for Severe Marine Pollutant or • for substances that are marine pollutants if they contain 1% or more of a Severe Marine Pollutant, or 10% or more of a Marine Pollutant. The Maritime Rule 24A and the IMDG currently require a special mark (triangular label depicting a fish with a cross through it) on packaging with the words ‘Marine Pollutant’ after the UN number on documents. There are additional stowage requirements and reporting requirements in the event of a spillage or loss. The marine pollutant mark will change with the introduction of revision 34-08 of the IMDG to a black diamond with the dead tree & fish symbol.
- UN3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCES, LIQUID, N.O.S.
- UN 3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCES, SOLID, N.O.S.
Internal Pressure (Hydrostatic) Test
Packaging intended to contain liquids must be capable of passing an internal hydrostatic pressure test. The required test pressure is dependant on the liquid being packed and must be determined on a case-by-case basis. The various codes specify the acceptable means of calculating and measuring the hydrostatic test pressure. They also specify minimum test pressures. When selecting packaging, it must be able to withstand either the determined test pressure or the relevant minimum test pressure, whichever is higher.
There are some significant differences in the minimum test pressures permitted by the various transport codes. Air transport requires a higher standard.
International Air Transport Association
For single packagings, the requirements are:
- When using the actual liquid that the packaging is designed to contain, the minimum test pressure is 95kPa for all hazard classes, except for PG III of Class 3 and Division 6.1 where 75kPa is allowed. The reference for this is ICAO Part 6;4.5.3(a) and IATA 184.108.40.206.1.
- When using the vapour pressure as an indicator, then the minimum test pressure for all hazard classes is 100kPa. References ICAO Part 6;4.5.3(b) and (c) and IATA 220.127.116.11.2 and 18.104.22.168.3.
- For PG I liquids the minimum test pressure is 250kPa and ICAO Part 6;3.5.4.
For all inner packagings intending to contain liquids, the packaging must be capable of withstanding a pressure differential of not less than 95kPa for all hazard classes, except for PG III of Class 3 and Division 6.1 where they allow 75kPa, or, if using the vapour pressure as a standard, then the minimum pressure differential for all hazard classes and packing groups is 95kPa. The references are ICAO Part 4;1.1.6 and IATA 22.214.171.124.
Absorbent material: IATA requires absorbent material to be used with some goods (section 126.96.36.199.2). This should be compatible with the substance.
UN Recommendations, IMDG and NZS5433
The minimum test pressure to take account of vapour pressure is 100kPa for PG II & III liquids and a minimum of 250kPa for Packing Group I liquids.
Non UN Type-Tested Packaging
The 15th revised edition of the UN Recommendation (Chapter 3.5), ICAO Part 1, chapter 2, section 2.5 and IATA 2.7 allow very small quantities of some Classes of dangerous goods to be shipped as ‘Excepted Quantities’. The packaging does not have to be UN certified packaging but it must be of good quality combination packaging, capable of withstanding the normal conditions of transport, and must be compatible with the dangerous goods. Incompatible dangerous goods must not be included in the same package.
IATA imposes additional labelling requirements.
Limited Quantities of some less-hazardous dangerous goods (e.g. those that are allowed to be carried on passenger aircraft) may be transported in non-UN specification packaging provided special provisions are met. These provisions are detailed in IATA’s section 2.8. The packaging does not have to be officially tested in an approved laboratory to UN specifications, but it must meet the requirements of the relevant Packing Instruction specified in the relevant code.
The package must be capable of passing the stacking test and be able to withstand a drop of 1.2 m onto solid concrete in the position most likely to cause damage. IATA denotes limited quantity Packing Instructions by a capital letter ‘Y’ in front of the Packing Instruction number.
ICAO and IATA Packing Instruction 910 allows cosmetics, drugs and medicines (packaged for retail sale or distribution for personal or household consumption) to be packed in non-UN specification packaging to a total gross mass of 30 kg. Stretch or shrink-wrapped trays are not acceptable.
The IMDG Code allows limited quantity shipments of up to 30 kg per package. Quantity per inner package is restricted. No requirements are specified for strength, other than the package must be of good quality and capable of withstanding normal transport conditions.
The Land Transport Rule also provides dispensation for packaging dangerous goods in Limited Quantities and Consumer Commodities (Rule section 3.1 and 3.2(2)).
NZS 5433 and the Land Transport Rule allow Dangerous Goods in Limited Quantities and Consumer Commodities up to 30kg per package to be in packages that meet the general safety requirements of section 3.1 of the Land Transport Rule (see sections 2.3 and 3.2(2)).
It is not possible to deal with this subject in any depth in this document, other than to point out that some combinations allowable on land are not allowable at sea and vice versa. Consignors and freight forwarders involved in the land and sea consignment of dangerous goods must comply with the requirements of both modes. This includes vessels and roll-on/roll-off ferries operating on the New Zealand coast.
The IMDG Code introduced segregation groups which list substances with similar properties. In addition to the general segregation requirements by Class or Division, the IMDG may specify addition segregation requirements for specific dangerous goods. The additional segregation requirements are specified in the list of dangerous goods (part 3 of the IMDG). Cyanides of division 6.1 must be segregated ‘away from acids’. Acids refer to any substance in the ‘Acid Segregation Group’. Note: The ‘away from acids’ does not apply to all acids; it applies only to those listed in the Acid Segregation Group. Many weaker organic acids are not included in the Acid Segregation Group. The Segregation Groups have been reproduced in NZS 5433:2007
Table 5 shows the differences between segregation requirements for land and sea transport.
The Land Transport Rule and NZS 5433 make allowance for segregation devices on board vehicles. These are not accepted under the IMDG Code unless specifically permitted by Maritime NZ.
The IMDG Code requires that dangerous goods that require ‘Away from’ segregation (3m separation), or ‘Separated from’ segregation (6m separation) should not be packed in the same Cargo Transport Unit (CTU)SUP19 .
The IATA Dangerous Goods Regulations include segregation requirements for dangerous goods within packages and stowage segregation on board aircraft. Airlines will not accept cargo transport units packed by consignors or freight consolidators.
|Combined land and sea segregation requirements
This table specifies the general segregation requirements – the IMDG Code may specify additional segregation requirements under stowage and segregation for individual goods.
* indicates land transport segregation is more restrictive.
** indicates marine transport is more restrictive.
| Column A
Class or Division and name of dangerous goods
Must not be loaded in the same freight container or on the same vehicle
Must not be loaded in the same freight container; and
must be separated horizontally by at least three metres unless all but one are packed in separate freight containers
|1 Explosives (except 1.4)||2.1, 2.2, 2.3, 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 6.2, 7, 8, *9||-|
|1.4 Explosives||2.1, 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.2, 7, 8,||2.2, 2.3|
|2.1 Flammable gases||1, 3, 4.2, 5.1, 5.2, 7, **6.2||4.1, **8|
|2.2 Non-flammable, non-toxic gases||1, **6.2||4.2, 5.2, **3, **7|
|2.3 Toxic gases||1, 3, 4.2, 5.2, food items, **6.2||**7|
|3 Flammable liquids||1, 2.1, 2.3, 4.2, 5.1, 5.2, 7, **6.2||4.3, **2.2|
|4.1 Flammable solids||1, 5.2, 7, **6.2||2.1, 4.2, 5.1, **8|
|4.2 Spontaneously combustible||1, 2.1, 2.3, 3, 5.1, 5.2, 7, **6.2||2.2, 4.1, **4.3, **6.1, **8|
|4.3 Dangerous when wet||1, 5.1, 5.2, 7, **6.2||3, 8, **4.2, **8|
|5.1 Oxidising substances||1, 2.1, 3, 4.2, 4.3, 5.2, 6.2, 8||4.1, 6.1, 7|
|5.2 Organic peroxides||1, 2.1, 2.3, 3, 4.1, 4.2, 4.3, 5.1, 6.2, 7, 8||2.2, 6.1|
|6.1 Toxic substances||1, food items, note 1||5.1, 5.2, **4.2, **6.2|
|6.2 Infectious substances||1, 5.1, 5.2, food items, **2.1, **2.2, **2.3, **3, **4.1, **4.2, **4.3, **5.1, **5.2, **7, 8||**6.1|
|7 Radioactive materials||1, 2.1, 3, 4.1, 4.2, 4.3, 5.2, **6.2, 8||5.1, **2.2, **2.3|
|8 Corrosives||1, 5.1, 5.2, 6.2, 7, food items, note 1, note 2||4.3, **2.1, **4.1, **4.2, **4.3|
|9 Miscellaneous dangerous||substances and articles *1 (except 1.4)||-|
|Note 1: Cyanides (Class 6.1) must not be loaded in the same freight container or on the same vehicle with acids (Class 8).
Note 2: Strong acids must not be loaded in the same freight container or on the same vehicle with strong alkalis. (All Class 8 Corrosives in packing group I or II should be considered to be strong acids and alkalis. Some exemptions have been granted by Maritime NZ).
Note 3: Segregation devices may be used as specified in 6.4 of Land Transport Rule 45001/1. Segregation devices have not been approved for sea transport.
Labelling and placarding
Labelling and placarding principles are common to all codes. The use, number, location and size of the placards varies, however all modes require all outer packagings to be labelled with Class labels.
Class and Subsidiary Risk labels: Subsidiary Risk labels are identical to Class labels.
Quantity: All dangerous goods transported by air or sea must be labelled. The same requirements apply to land transport, except a vehicle carrying small packages in an aggregated quantity less than 50 kg or 50 litres does not need to be placarded.
Location and number: A vehicle for sea transport must be placarded on two sides and the front and rear. For road transport, the same vehicle is required to be placarded front and rear. The minimum size for the placards is 250 x 250 mm. Bulk tankwagons are required to be placarded on both sides and the rear. The minimum placard size is 400 x 400 mm for land transport in New Zealand.
Dangerous placard: The black and orange striped ‘DANGEROUS’ placard used for land transport is not acceptable for air or sea transport. These modes require all Class and Subsidiary Risk labels/placards to be displayed. A vehicle placarded according to marine requirements is also acceptable under the Land Transport Rule. The converse, however, is not acceptable.
Container Packing Certificates
The Land Transport Rule section 5.2(7) requires a Container Packing Certificate or Vehicle Packing Certificate to be carried if the goods are in a closed, pre-packed freight container or vehicle. The certificate states the container and the goods have been inspected and that the packages are labelled and marked, segregated and secured in accordance with the Land Transport Rule.
The persons responsible for packing a freight container or vehicle must ensure that no dangerous goods which are required to be segregated under section 7.2 of the IMDG Code are packed within the same freight container or vehicle, intended for sea transportation, without the prior approval of Maritime NZ.
As Table 5 shows, a land transport Container or Vehicle Packing Certificate does not necessarily ensure compliance with maritime requirements, and vice versa. This is due to the differences in segregation requirements. Check columns A to C in Table 5 to ensure both land and sea segregation requirements are met
Cargo Transport Units and Freight Containers
In addition to the placards, the IMDG Code requires full container loads of one dangerous good to be marked with the UN number. The number should be placed either in the lower-half of the Class placard or on a separate orange placard placed close to the Class placard (see IMDG section 8.7).
This code also specifies that dangerous goods that do not completely fill a freight container or cargo transport unit are to be placed immediately inside the doors of the container or be readily accessible in a transport unit (e.g. a vehicle).
It also requires those responsible for packing a container to provide a Container Packing Certificate declaring compliance with IMDG section 5.4.2 (also see ‘Container Packing Certificate’ above).
Standards New Zealand has published a guide for stowing dangerous goods in freight containers NZS HB 77:2008
The IMDG Code has special provisions for intermediate bulk containers (IBCs) and bulk containers. Under the Land Transport Rule, bulk containers other than IBCs must display an emergency information panel (section 7.2(5)).
Portable tanks for compressed or liquefied gases must comply with the Health and Safety in Employment (Pressure Equipment, Cranes and Passenger Ropeways) Regulations 1999 (HSE 1999), administered by the Engineering Safety Department of Labour. Tanks meeting the requirements of IMDG or the UN Recommendations are also considered to be in compliance with the HSE.
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