The Overpack That Hid the Labels
A consolidator builds an overpack containing four fibreboard boxes of UN1993 Flammable liquid, n.o.s. (Class 3, packing group III), each box holding 5 litres in plastic bottles, plus two boxes of UN3082 Environmentally hazardous substance, liquid, n.o.s. (Class 9, packing group III). The overpack is shrink-wrapped and banded. The consolidator marks the overpack with the word 'OVERPACK', the UN numbers, and the net quantities, but does not reproduce the hazard labels, arguing that the inner boxes carry them and are visible through the shrink wrap. The overpack is tendered as a single unit for a passenger aircraft. The acceptance officer must determine whether the overpack is compliant and whether the passenger aircraft is the correct mode.
1. Evaluate the overpack marking and labelling, and the mode of transport question.
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Two separate issues must be assessed: overpack presentation and aircraft eligibility.
Overpack marking and labelling:
- The word 'OVERPACK', the UN numbers, and the net quantities are required and were applied.
- Hazard labels for each dangerous good in the overpack must be reproduced on the overpack unless the labels on the inner packages are visible. Shrink wrap that is opaque, reflective, or obscured by banding does not satisfy visibility; the officer must judge whether every label is clearly visible from outside.
- If visibility is doubtful, labels must be applied to the overpack. The consolidator's argument is a claim, not a demonstration.
Mode of transport:
- Class 3 packing group III liquids are generally permitted on passenger aircraft within quantity limits, but the officer must check the applicable packing instruction and the passenger aircraft quantity limit for UN1993.
- UN3082 Class 9 is normally permitted, but the officer must confirm the packing instruction and any per-package limits.
- The overpack must also be checked against any limit that applies to the combined package.
Decision: Accept only if labels are visible or reproduced and all quantity limits for passenger aircraft are met. Otherwise require relabelling or re-routing to cargo aircraft.
2. The consolidator asks whether the overpack can instead be split into its component boxes to avoid the labelling question. Advise on the implications.
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Splitting is technically possible but changes the consignment in ways that must be re-verified, so it is not a shortcut around compliance.
What changes:
- Each box becomes a separate package, so per-package quantity limits are assessed individually rather than against the overpack.
- Each package must carry its own hazard labels and any required marks; the 'OVERPACK' mark is removed.
- The shipper's declaration and air waybill must be amended to reflect the new package count and quantities.
- The overpack's structural benefit is lost, so the boxes must be shown to be suitable for individual handling and stowage.
What does not change:
- The classification, packing group, and packing instruction compliance of each box.
- The passenger aircraft eligibility of each item.
Advice: Splitting is acceptable only if the documentation is corrected and each package is independently compliant. It should not be presented as a way to avoid applying labels, because the labelling requirement simply moves to the individual packages. The officer should require a corrected declaration before acceptance.