Requirements common to all transport codes
Consignment Procedures – Key Points
The following general procedures apply to all modes of transport:
- Classify the goods according to criteria specified in the relevant code or confirm the classification with the manufacturer or importer of the goods.
- Identify the Proper Shipping Name7 from the general index or alphabetical list of dangerous goods in the appropriate code.
- Check if the goods can be transported and if special conditions apply – some goods are prohibited under all circumstances. Others may require different packaging or the code may only allow smaller quantities. It may be necessary to comply with more than one modal code or domestic legislation.
- Check if different items can be placed in the same packaging, cargo transport unit (CTU), or large package (segregation). Segregations requirements can be significantly different between the different transport modes.
- Select the correct packaging based on the Packing Instruction or Class and Packing Group8 (when applicable) if the code does not provide Packing Instructions.
- Mark and label the goods in accordance with the appropriate code (usually UN number Proper Shipping Name9, Class label10 and Subsidiary Risk label 11 (if required), Packing Group (if applicable) plus any additional marks required by the code (such as marine pollutant, environmentally hazardous or elevated temperature marks).
- Provide a dangerous goods declaration stating the UN number, Proper Shipping Name, Class, the Packing Group where applicable and the number and kind of packages. Also provide flash point12 and Marine Pollutant13 if required. If not specifically required elsewhere on the document, this information may be placed in the ’additional information‘ section. Provide any additional information required by the specific code. Under the Land Transport Rules the consignor must advise of any special requirements for the safe carriage of the goods. The rules also require loaders and carriers to implement any special requirements indicated in ’additional information’.
- Pack cargo transport units14 according to segregation requirements. Document container/vehicle e.g. manifest (list goods) and provide a container/vehicle packing certificate15. Provide any additional information required by the specific code.
- Label cargo transport unit with Class placards16 and UN number if required17.
Identifying Dangerous Goods – Key Points
- Dangerous goods are classified based on their properties. Many pure dangerous goods can be easily identified and classified using the relevant Code’s ’general index‘or ‘alphabetical list’.
- If a substance or product is not listed by name, it must be assigned a Class, Division (if applicable), Subsidiary Risk (if any) and Packing Group (if applicable). This is done by comparing the chemical, physical, biological or infectious properties of the substance with the criteria for each Class or Division found in the classification section of the relevant code.
- When the substance has more than one risk, the primary and subsidiary risk(s) are determined using the code’s precedence of risk rules.
- Once this has been done, the Proper Shipping Name can be chosen from ‘generic’ type names. Use the following list of questions to guide you through the identification and classification procedure:
- Is the product a pure substance or is it a mixture containing only one dangerous substance?
- Is the substance listed by name or synonym in the list of dangerous goods?
- Is the product a mixture of dangerous goods, and is this mixture specifically listed?
- Is it listed under a ‘generic chemical family’ name (e.g. BUTANOLS or OXALATES)?
- Is it listed under a ‘generic non-chemical’ name (e.g. BATTERY FLUID, ACID, ADHESIVES, PAINT, SAFETY MATCHES etc)?
- Is it listed under a generic N.O.S (Not Otherwise Specified) name (e.g. ALCOHOLS, N.O.S. or FLAMMABLE LIQUIDS N.O.S., or PESTICIDES LIQUID, TOXIC, FLAMMABLE, N.O.S. etc)?
Proper Shipping Name
The Proper Shipping Name (PSN) is the name in the ‘List of Dangerous Goods’ that most accurately describes the product and has traditionally been written in upper case letters (or bold face lettering for ICAO and IATA). Any additional text in lower case is descriptive and used to select the appropriate Proper Shipping Name (it does not form part of the Proper Shipping Name).
- The Proper Shipping Name of a mixture of a dangerous substances with one or more non-dangerous substance(s) should have the word ‘SOLUTION’ or ‘MIXTURE’ added after the appropriate PSN of the substance (provided that the mixture or solution of dangerous properties are not altered to the extent that the classification changes, or the mixture or solution has a separate entry in the Dangerous Goods List). The percentage of the dangerous substance may also be added e.g. ACETONE 75% SOLUTION.
- If a product contains an unlisted flammable and toxic alcohol, it should be named ‘UN1986 ALCOHOLS, TOXIC, N.O.S.’, not the more general ‘UN1992 FLAMMABLE LIQUIDS, TOXIC, N.O.S.’.
- If the Proper Shipping Name includes the term N.O.S. the technical or scientific name should be written in brackets after N.O.S e.g. ‘ALCOHOLS, TOXIC, N.O.S. (allyl alcohol)’.
- Some generic Proper Shipping Names that do not include N.O.S as part of the name also require the addition of the technical name. These are indicated by special provisions. Examples of generic proper shipping names that require the addition of the technical name of the dangerous goods are those used for self-reactive substances, organic peroxides, pesticides and some explosives e.g. SELF-REACTIVE SOLID TYPE D (benzenesulphonyl hydrazide)
- If the substance is a mixture with more than one significant risk, provide the technical names of the substances contributing most significantly to the primary and secondary risk.
Appropriate packaging is vital in safely transporting dangerous goods. The entire UN Recommendations are based on the philosophy that securely contained dangerous goods pose little, or acceptable risk, during transport. Based on experience, the UN developed the minimum performance requirements for packaging. During the last decade, the UN has been developing packing instructions which provide detailed specifications for packing specific dangerous goods.
New Zealand approvals
Land Transport Rule: Dangerous Goods 2005 (Rule 45001/1) allows several options for packaging infectious substances.
1) Packaging must be UN specification packaging (e.g. IMDG, NZS 5433, ICAO, etc); or
2) for infectious substances affecting humans, packaging must comply with the requirements of the Director General of Health; or
3) for infectious substances affecting animals only, packaging must comply with the requirements of the Director General of Agriculture and Forestry; or
4) for routine diagnostic specimens or low risk biological products, packing that does not comply with 1), 2) or 3) above must comply with 3.2(5)(c) of the Rule.
HSNO Hazardous Substances
Substances approved as new Hazardous Substances under HSNO, or substances considered to be ‘approved’ when transferred from the transitional provisions, must comply with the requirements specified for the substance in the register of HSNO approvals at www.ermanz.govt.nz/search/registers.html(external link). Approvals from ERMA are not required for packaging of imported goods. However, packaging manufactured in NZ and empty packaging imported for use must have been test-certified as complying with UN packaging standards.
Section 3.2(1) of the Land Transport Rule requires packaging to be ‘type-tested’ against the performance requirements outlined in any one of:
- UN Recommendations
- ICAO Technical Instructions
- IATA Dangerous Goods Regulations
- NZS 5433; or
- packaging that complies with the requirements of the relevant regulatory authority.
Packaging for Limited Quantities and Consumer Commodities does not have to be type-tested but must meet the general safety requirements of section 3.1 of the Land Transport Rule.
Except for Class 7 Dangerous Goods, which are approved by the National Radiation Laboratory of the Ministry of Health, the Civil Aviation Rule Part 92 states packaging must be approved by the Director of the CAA. This approval is in addition to any other regulatory approval.
Maritime Rule Part 24A states packaging must comply with the IMDG requirements. The Director of Maritime NZ approves New Zealand-manufactured packaging, and also recognises approvals granted by the CAA, Department of Labour and the Ministry of Health.
The following organisations have delegated authority for the approval, inspection and testing of all portable tanks, tank containers and freight containers:
- American Bureau of Shipping
- Bureau Veritas
- Det Norske Veritas
- Germanischer Lloyd
- Lloyd’s Register of Shipping
Under HSNO, approvals for packages are not required from ERMA. However, packaging manufactured in NZ and empty packaging imported for use must have been test-certified by the manufacturer or importer of the packaging as complying with UN packaging specifications.
Packaging Selection – Key Points
The following key points should be considered when selecting packaging:
- Does it comply with the relevant code’s specific requirements?
- Is the substance compatible with the packaging? It is the packer’s and shipper’s responsibility to ensure the substance is compatible with the proposed packaging. It is important the substance does not react dangerously, weaken or cause the packaging to become brittle.
- Has the packaging been tested to the correct test specification? This is most important where UN specification packaging is purchased to package dangerous goods e.g. 20-litre pails are purchased to package flammable liquids.
To select packaging, check the following factors:
- Solids or inner packages: Does the substance adequately fill the packaging and is the total weight less than or equal to the test specification for the proposed packaging?
- Liquids: The specific gravity (SG) of the substance must be equal to or less than the test specification of the packaging. If the test specification SG is not marked, the packaging has been approved for liquids with SGs up to 1.2.
- Is sufficient head space (ullage) available?
- Can the packaging withstand internal pressure generated by the substance when the temperature increases under normal transport conditions?
- A package intended to retain liquids must be able to withstand pressure from either:
- the expansion of the contents (filled to 95% capacity at 15oC and heated to 55oC); or
- the vapour pressure generated when the contents are heated to 55oC
- (whichever is higher).
- Each code provides formulas to calculate the minimum hydrostatic test pressure required for a particular liquid. Flammable liquids in particular have a wide range of vapour pressure (100-250kPa).
- It is the shipper’s (or consignor’s) and packer’s responsibility to ensure the packaging has been tested to the required test pressure for the substance being packed.
- Is the cushioning or absorbent material compatible with the substance? Polystyrene beads are not suitable cushioning material for many hydrocarbon solvents - a small leak will dissolve the beads and reduce cushioning.
- Refer to the relevant code for the full requirements.
Marking and labelling
All codes have similar marking and labelling requirements.
Labelling specifically refers to Class label(s) and Subsidiary Risk labels.
Marking refers to the Proper Shipping Name and corresponding UN number (preceded by the letters ‘UN’) e.g. ‘UN 2902 PESTICIDE, LIQUID, TOXIC, N.O.S. (contains 80% drazoxolon)’.
These include special marks such as the orientation, marine pollutant, environmentally hazardous and elevated temperature marks.
The physical separation of incompatible goods helps safeguard against accidents by reducing the probability of an adverse reaction between incompatible dangerous goods if containment is lost. The UN Recommendations recognise the need to segregate incompatible materials; however no specific guidelines are given as these are specified in the modal codes.
There are some significant differences between the codes. These differences reflect the different stresses and strains encountered in the various modes, as well as the quantities of dangerous goods involved. (See Segregation under ‘Differences between Modes’ on page 30.)
Documentation – Key Points
Information required on transport documentation is essentially the same for all transport modes, although some codes require a specific form.
The following information requirement is common for all modes and should be included for each dangerous substance, material or article:
(a) UN number (preceded by the letters ‘UN’).
(b) The Proper Shipping Name.
(c) The goods’ Class or Division (when assigned). Substances and articles of Class 1 (explosives) should be followed immediately by the compatibility group letter.
(d) The Packing Group (if assigned).
(e) Number and type of packages.
(f) Total quantity of dangerous goods covered by the description (by volume, mass, or net explosive content, as appropriate).
All codes require additional information when using generic Proper Shipping Names containing N.O.S. as part of the name, e.g. drazoxolon is a toxic liquid which is used as a pesticide but is not listed by name in the index or alphabetical list. The correct Proper Shipping Name to use is ‘UN 2902 PESTICIDE, LIQUID, TOXIC, N.O.S. (drazoxolon)’.
The additional information required is usually limited to stating the two most dangerous components. If the mixture has a primary and subsidiary risk, the components mainly responsible for these risks should be listed e.g. an emulsifiable concentrate of azinphos-ethyl, which is toxic and has a flammable solvent would be named as ‘UN3017 ORGANOPHOSPHOROUS PESTICIDE, LIQUID, TOXIC, FLAMMABLE, N.O.S. (80% azinphos - ethyl, 15% xylene)’. The qualifying words ‘contains’ or ‘containing’ may be added to the technical name e.g. ‘UN3017 ORGANOPHOSPHOROUS PESTICIDE, LIQUID, TOXIC, FLAMMABLE, N.O.S. (containing 80% azinphos-ethyl, 15% xylene)’.
All codes allow multiple entries and a mixture of dangerous/non-dangerous goods on the same declaration; however, the dangerous goods must be listed first.
All of the codes also require a signed declaration that the goods have been prepared for transport in accordance with relevant requirements. Most codes permit the use of electronic data interchange and an electronic signature.
Comparison of the documentation requirements
A comparison of the documentation requirements is shown in Table 2.
|Proper Shipping Name||Yes||Yes||Yes|
|Additional information required for N.O.S.
and generic Proper Shipping Names
|Packing Group required||Yes||Yes||Yes|
|Indicate number and kind of packages||Yes||Yes||Yes|
|Indicate mass per outer package||No||Yes
|Indicate the total quantity||Yes||Yes||No|
|Required for any quantity||Yes3||Yes||Yes|
|Require emergency procedure guide||No||No||No|
|Multiple entries allowed on declaration||Yes||Yes||Yes|
|Non-dangerous goods allowed on declaration - listed after Dangerous Goods||Yes||Yes||Yes|
|Indicate Marine Pollutant||No||Yes||No|
- Required only for marking bulk containers.
- (N) – Net weight, (G) – Gross weight (net mass for explosives).
- Not required for small packages (i.e. up to 50 kg/l of dangerous goods in Limited Quantities.
Dangerous Goods in Limited Quantities
All codes provide for transporting Limited Quantities of medium and low-danger dangerous goods, recognising they often present a reduced level of risk during transport.
The requirements are:
- Packing Group I substances are not generally permitted, but there is a small number of exceptions e.g. 500 ml of UN 1263, PAINT, packing group I.
- Flammable, toxic, corrosive or oxidising gases are not permitted (aerosols UN1950 are permitted).
- Some Classes or Divisions of dangerous goods are not permitted e.g. Class 1, Division 6.2 and Class 7.
- The goods must be packaged in combination packaging i.e. an inner and outer package.
- The maximum quantity permitted per inner package is prescribed and depends on the Class, Packing Group and whether it is solid or liquid.
- The maximum gross mass of the combination package cannot exceed 30 kg.
- Shrink or stretch-wrapped trays meeting certain conditions may be regarded as outer packaging and the package shall not exceed 20 kg gross. Inner packages that are liable to break or be easily punctured (e.g. glass, porcelain, stoneware or certain plastics) cannot be transported by this packaging method nor is it accepted for air transport.
- Packaging needs to be good quality, but does not have to be type-tested or marked in accordance with the UN performance standards. Air transport packaging still needs to meet certain standards (see ‘Differences between modes’ on page 25).
- Some requirements for marking, labelling, segregation and documentation are also reduced.
- The Classes and quantities of goods that can be transported under these provisions for land and sea are almost identical. The Land Transport Rule allows lighters or lighter refills UN1057 and compressed non-flammable gases (excluding oxidising or corrosive gases) to be transported under the requirements of Dangerous Goods in Limited Quantities (DGLQ). See Land Transport Rule Schedule 2 and Schedule 2A for size restriction details.
- Table 3 summarises the modal differences for marking and labelling dangerous goods in Limited Quantities.
||The UN number(s) of the dangerous goods in the package, placed within a diamond||
|Package Class label||Not required||Not required||Class label(s) required|
|Cargo Transport Unit 18 markings||Not required||‘LIMITED QUANTITIES’ or LTD QTY (for full load in the cargo transport unit)||Not applicable|
|Cargo Transport Unit placards||
||Not required||Not applicable|
For detailed information:
Sea transport IMDG Code, Chapter 3.4, Dangerous Goods in Limited Quantities and Part 24A of the Maritime Rules.
Land transport Land Transport Rule, section 2.3.
Air transport IATA dangerous goods Regulations, section 2.8.
Note: The Land Transport Rule limits the gross amount that may be loaded into a transport unit (vehicle or vehicle combination) to 1,000 kg or 1,000 litres, whereas sea and air transport rules do not (See ‘Differences between modes’ on page 25).
Consumer Commodities are dangerous goods in Limited Quantities that are intended for personal or household use and are packaged and distributed to retailers.
Consumer Commodity packages do not need to be marked with the Proper Shipping Name or UN number or labelled with a Class label, although a Class label and Proper Shipping Name are one of the alternatives permitted by the Land Transport Rule (see section 2.3(1)(g)).
The term Consumer Commodities is not used for sea transport - these are regarded as a special type of dangerous goods in limited quantities and you do not need to display the Class label, Proper Shipping Name or UN number.
Requirements for Small Quantities
- The 15th revised edition of the UN Recommendations has introduced dangerous goods in Excepted Quantities for all modes of transport. (See ‘Significant changes to Dangerous Goods Codes’ on page 13)
- Sea transport – currently there are no exemptions, however the IMDG 34-08 is expected to include provisions for dangerous goods in Excepted Quantities.
- Air transport - extremely small quantities are exempt (up to 30 g or ml depending on the risk - IATA section 2.7 Excepted Quantities).
- Land transport - provisions for small packages (see Land Transport Rule sections 2.4 and 2.5). The Land Transport Rule also allows for dangerous goods in Excepted Quantities that are transported in accordance with the requirements of ICAO or IATA (See 1.4(1) of the Dangerous Goods Rule).
All modes require empty containers that have not been purged and freed of all traces of dangerous goods to be consigned as dangerous goods. The Proper Shipping Name should be amended by ‘EMPTY UNCLEANED’ or ‘RESIDUE LAST CONTAINED’ before the Proper Shipping Name of the last contents of the empty container of package.
Until recently there have been subtle but significant differences in aerosol classification. The 13th revised edition of the UN Recommendations adopted a new definition for Flammable Aerosols. This was subsequently adopted by ICAO, IATA and the IMDG resulting in uniform classification criteria for aerosols.
Regrettably there is now a significant difference between the definition of a flammable aerosol in the Transport Codes versus HSNO. The HSNO classification of 2.1.2A should not be relied upon to classify aerosols as flammable for transport. Some aerosols that do not meet the classification criteria of 2.1.2A may be flammable for transport. This potentially creates an unsafe situation. It is intended that the HSNO classification will be amended to align it with the GHS and UN Recommendations.
- Proper Shipping Name - describes a dangerous item in the numbered list of dangerous goods in chapter 2 of the UN Recommendations. It is considered to be the most appropriate name where synonyms or alternative names exist for the same item. Where a choice of names is permitted by the code, the Proper Shipping Name is the name that most accurately describes the goods. It is also recognised internationally. Also see Proper Shipping Name in the section titled ’Differences between modes’.
- Packing Group - Classes 3, 4, 5.1, 6.1, 8 and 9 have been divided into three Packing Groups (PG): I, II or III. The Packing Group indicates the degree of danger within the Classes and specifies the standard of packaging. Packing Group I denotes high danger and therefore requires the highest standard of packaging; II denotes medium danger; and III denotes low danger.
- UN Number - this is the number assigned to an item in the list of dangerous goods in chapter 2 of the UN Recommendations, and identifies the item by Proper Shipping Name and Class. It is always prefixed by the letters UN.
- Class Label - distinctive diamond-shaped labels (a square set at an angle of 45 degrees) to identify the Class by a combination of colour, Class number (in the bottom angle) and distinctive pictograms.
- Subsidiary Risk label - label or labels denoting additional significant risks. These are identical to class labels.
- The lowest temperature at which there is sufficient vapour to form an explosive mixture, when tested by the prescribed method.
- Identified in the IMDG list of dangerous goods by P, PP or (indicates the substance may contain a Marine Pollutant).
- Cargo Transport Unit - either a road freight vehicle, a railway freight wagon, a freight container, a road tank vehicle, a railway tank wagon or a portable tank. Airlines will not accept cargo transport units packed by shippers or freight forwarders.
- A container/vehicle packing certificate is not required for bulk liquids or solids in tanks.
- Placards are large labels, minimum size of 250 x 250mm or 400 x 400mm (for bulk containers).
- Required for full container loads under IMDG section 5.3.2 Marking of Cargo Transport Units.
- A Cargo Transport Unit includes a road freight vehicle, a road tank vehicle, a rail freight vehicle rail tank wagon or a freight container, or a portable tank.
Download the full document: