Packages of Environmentally Hazardous Substances (EHS) assigned to UN 3082 for liquids and UN 3077 for solids, may now be exempted from dangerous goods requirements in quantities less than 5 L or 5 kg per package or inner packaging.

This new provision is taken from the 18th edition of the orange book and is implemented in ADR 2015 by a new special provision, SP 375 which reads as follows:

“These substances when carried in single or combination packagings containing a net quantity per single or inner packaging of 5 L or less for liquids or having a net mass per single or inner packaging of 5 kg or less for solids, are not subject to any other provisions of ADR provided the packagings meet the general provisions of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8”.

If you are using the (currently voluntary) 37th amendment to the IMDG Code, this provision can be found at 2.10.2.7 and in the current IATA DGR 56th edition via Special Provision A197.

This provision has important implications for distributors of chemicals and mixtures assigned to UN 3077 and UN 3082, which often includes many agrochemical products.

It is worth noting that whilst these packages will not be subject to the dangerous goods marking and labelling requirements,  they will still require labelling in accordance with CLP.

If you require help or advice with any aspect of the transport of dangerous goods please contact the team at EcoStar Environmental Ltd.