Four lines on one pallet: which are dangerous goods?
A fruit-packing co-op in Griffith wants a mixed pallet collected by a general freight carrier on Friday. The consignment note lists four lines. Line 1: four 205 L drums of 'Parts Washer Solvent'; the SDS gives a closed-cup flash point of 63 °C, an initial boiling point of 196 °C and the statement 'causes severe skin burns and eye damage', and Section 14 says 'not classified as dangerous goods for transport'. Line 2: twelve cartons of aerosol air freshener, each carton holding 24 × 400 g cans marked flammable. Line 3: three 200 L drums labelled 'hydrochloric acid 33%' that were emptied and drained at the depot two days ago and are being returned for refilling; nobody rinsed them. Line 4: eight wet lead-acid forklift batteries, filled with acid, on a timber pallet. The co-op's manager says the whole pallet is 'just chemicals, none of it needs placards', and the depot has one driver available who holds a current dangerous goods driver licence.
1. For each of the four lines, state whether it is dangerous goods for road transport and, if it is, the class and (where you can) the UN number. Show the test you applied to each line.
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The test: classification is a legal determination against the ADG Code criteria, not against the supplier's label or the customer's opinion. Work line by line.
Line 1 - the solvent. Flash point is the obvious trap. Class 3 catches liquids with a closed-cup flash point of 60 °C or less (plus liquids carried at or above their flash point). At 63 °C this product fails the flash-point test, so it is not Class 3 on that basis. That does not make it harmless: it must still be tested against the other classes. 'Causes severe skin burns and eye damage' is the GHS signal for skin corrosion, which is the same property that drives Class 8 - a substance that destroys skin, or corrodes steel at more than 6.25 mm per year, is Class 8. On the SDS evidence this is a corrosive liquid (Class 8), with the packing group set by the corrosion data. If a proper assessment showed no class criteria were met, it would be a combustible liquid (C1) - a storage and WHS issue, not a transport DG.
Line 2 - aerosols: UN 1950, Class 2.1 (flammable) because the cans are marked flammable. Aerosols are dangerous goods; any limited-quantity relief changes the packaging and paperwork, not the classification.
Line 3 - the 'empty' drums: a packaging that has not been cleaned of residue is still dangerous goods. They travel as EMPTY UNCLEANED, UN 1789, Class 8, PG II.
Line 4 - wet lead-acid batteries: UN 2794, Class 8 (no packing group). The non-spillable type (UN 2800) can be exempt if it meets the vibration and pressure-differential tests - these are flooded, so it does not.
2. Section 14 of the solvent SDS says it is not dangerous goods for transport, but the same SDS says it causes severe skin burns. Which governs, and what should happen before the pallet is accepted?
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Transport classification is governed by the ADG Code, not by the supplier's Section 14 statement. Section 14 is written by the supplier and is frequently wrong, out of date, or simply copied from the WHS classification - it is evidence, not a determination. The ADG criteria decide: if the product destroys skin or corrodes steel at the stated rate, it is Class 8 whatever Section 14 says.
Two documents are being conflated here. The GHS/WHS classification drives the label and the SDS. The transport classification drives UN numbers, packing, placards and documentation. They often agree, but they are separate legal instruments and one does not validate the other.
Before the pallet is accepted, ask the consignor for the basis of the classification - the corrosivity data (in-vitro skin test result, or steel corrosion rate) and the UN entry they have used. If it cannot be produced, treat the product conservatively as Class 8 until a competent person classifies it.
The loader should not accept an inconsistent declaration and the driver should not sign for it; record the query on the consignment note. The consignor is legally responsible for correct classification. The driver's job is to check that the document is complete and consistent with the packages in front of him - and here it is not.
3. What description and markings do the three 'empty' acid drums travel under, and what would change if they had been rinsed?
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Empty is not the same as clean. Under the ADG, packaging that has held dangerous goods and has not been cleaned, purged or decontaminated remains dangerous goods until the residue is gone.
The three drums must travel as: EMPTY UNCLEANED / UN 1789 / HYDROCHLORIC ACID / 8 / PG II, with the Class 8 label visible, listed as a line on the DG transport document with the number and size of packages, and counted in the aggregate if the vehicle becomes a placard load. Closures must be secure (bungs in, no open tops) and the drums must not be stowed where they can leak onto other freight.
If the drums had been drained and then rinsed and cleaned to the point where no dangerous goods residue remains, they are no longer dangerous goods in transport: no label, no UN number, no DG document entry, provided the old labels are removed or obscured. Note the downstream obligation - the wash water is itself a Class 8 waste and must be managed as such. You have not made the acid disappear, you have moved it.
What does not change either way: they are heavy items that must be restrained, and the driver still has a duty to check them.