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Environmentally Hazardous Substances – Exemption

March 9, 2016

Provisions for transporting environmentally hazardous goods by road, sea and air

Companies that currently ship environmentally hazardous materials under UN3077/3082 by limited quantity (LQ) may be unaware of the existence of a provision within transport regulations, which enables these goods to be transported in low quantities with reduced regulatory responsibilities.

 

The provision was introduced into the 18th revised edition of the UN Model Regulations and subsequently implemented into dangerous goods legislation for all three major modes of transport – air (IATA), road (ADR) and sea (IMDG).

What am I exempt from?

Products that qualify for the provision, which were previously shipped under limited quantity, would no longer require the LQ diamond mark or any other transport related label or marking on the outer packaging. Additionally, a dangerous goods note would not be required to be prepared for air or sea shipments.

Do you qualify?

Assigned special provision SP375 in ADR 2015, materials carried under UN3077 or UN3082 in either single or inner packaging of 5L or less for liquids or 5kg or less for solids, are not subject to any other provisions of ADR, provided they are packed in good quality packagings and adhere to the general packaging provisions, in sections 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 of ADR.

The same provision can be found in section 2.10.2.7 of IMDG 2014 and as Special Provision A197 in the current 57th edition of IATA. Full details of the corresponding general packaging provisions for IMDG and IATA, can be found in in sections 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 of IMDG, and sections 5.0.2.4.1, 5.0.2.6.1.1 and 5.0.2.8 of IATA.

 

Other Regulatory Responsibilities

It is important to note, however, that whilst these packages may no longer be subject to marking and labelling requirements under transport legislation, they may require labelling in accordance with Article 33 of CLP. Article 33 provides specific rules for the labelling of outer packaging, inner packaging and single packaging under CLP regulations.

A follow up newswire covering the details of Article 33 of CLP, will be released in the near future.

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What does the future hold?

Future amendments to the transport regulations may include changes to this provision being extended to include viscous liquids which are environmentally hazardous and flammable provided they meet the criteria of the viscous flammable liquids derogation.

For further information please attend Safeware Quasar’s Dangerous Goods Awareness Training Course (details can be found at the following link): Dangerous Goods Awareness Training Course

 

Other useful information sources:

UNECE Website

IMO website

IATA website

 

For other Safeware Quasar and industry relevant information visit our news page.

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