The limited-quantity paint consignment that is not limited quantity
You are the DGSA for a rail freight operator at a combined terminal. A regular customer offers 48 cartons for one wagon to a domestic destination. Each carton contains 12 cans of UN 1263 PAINT, Class 3, PG II, flash point 23 °C. Each can holds 5 L, so the consignment is 2,880 L. The consignment note reads “UN 1263 PAINT, 3, II, 48 cartons, 2,880 L”. The cartons bear the limited-quantity mark, and the customer insists that no placards or full dangerous goods note are needed because the load is “limited quantity”. You check the RID limited-quantity limits for Class 3 PG II: the inner packaging limit is 1 L. The wagon is already in the outbound rake; the terminal manager asks you to sign it off because the train departs in 40 minutes.
1. Is the limited-quantity claim correct? Give the RID reasoning and state the immediate consequence for the consignment.
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No. The limited-quantity regime is not a general light-touch option; it depends on the packaging limits for the specific class and packing group. For Class 3, PG II, the RID limited-quantity inner packaging limit is 1 L and the package gross-mass limit is 30 kg. A 5 L can exceeds the inner limit, and a carton containing 12 × 5 L cans will also exceed 30 kg gross. The limited-quantity mark is therefore invalid.
The consequence is that the load must be treated as fully regulated Class 3, PG II dangerous goods: packages need the Class 3 label and UN number, the wagon needs the required placards, the consignment note must contain a full dangerous goods description, and emergency information must be available to the train crew. The customer cannot rely on the limited-quantity mark to avoid placards or documentation.
2. What must you do as DGSA before the train departs, and what must be reported to management?
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The DGSA’s role is to monitor compliance, advise on compliance and report to management; the DGSA does not certify the load and cannot “sign it off” as compliant when the packaging limits are breached. Before departure you should instruct the terminal to hold the wagon, record the finding with the consignment details and photographs if possible, and notify the consignor in writing that the limited-quantity claim is invalid.
The consignor must either repack into compliant limited-quantity packaging or present the load as fully regulated dangerous goods with correct labels, placards and documents. You should check whether the same customer has other consignments in the rake. The non-compliance and the action taken belong in the DGSA’s report to management under the annual reporting duty. If management overrides the hold and the risk remains serious, consider notifying the competent authority.
3. If the consignor repacks into compliant limited-quantity packaging, what operational and documentary checks should still be made?
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Repacking removes the immediate packaging-limit breach but not all checks. Confirm that each inner packaging is no more than 1 L, each package gross mass is no more than 30 kg, the packages are undamaged and closed, and the limited-quantity mark is correctly applied. Check that the consignment note still identifies the consignor, consignee, UN number, proper shipping name, class, packing group, number and type of packages, and total quantity, even though the load is limited quantity.
Operationally, check that the wagon is suitable and clean, the packages are secured against movement in rail conditions, and the load is not mixed with anything that would be prohibited or unsafe. Confirm with the train crew what emergency information is available and whether any wagon placarding is required in addition to the limited-quantity mark. Record the verification and close the finding in the DGSA report.