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A Kurdziel  
#1 Posted : 17 December 2014 13:05:19(UTC)
Rank: Super forum user
A Kurdziel

Hello I would like to know if the Carriage of Dangerous Goods regs apply in this case, in particular, is there a requirement for us to have a Dangerous Goods Safety Adviser? We are an R&D lab and we will be sending out testing kits to customers. Each kit will contain 6 x 35 ml sealed tubes of 100% ethanol and then we will arrange the pickup of when the customer requires it - collecting 6 x 50 ml sealed tubes of what will be 70% ethanol. It is this ethanol that is causing the trouble. I would think the UN number in both cases is therefore: UN 1170. A shipment might consist of upto 300 of these kits. The courier company we are thinking of using is saying that we need a DGSA to comply with the regs I think we are exempted because a) it is not our main work activity and b) the volumes are too small given the fact that it is broken up into small packages rather than being transported in bulk. Any help for those who have experience of these regs would be very much appreciated.
Andrew W Walker  
#2 Posted : 17 December 2014 14:16:52(UTC)
Rank: Super forum user
Andrew W Walker

Hi. There is no need to appoint a DGSA. 1.8.3.2 of ADR explains it. http://www.unece.org/fil...2013/English/VolumeI.pdf The labelling and packaging will need to comply with 3.4. http://www.unece.org/fil...013/English/VolumeII.pdf Hope this helps Andy
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