Solvent-based adhesive: wrong packing group and package limit
A freight forwarder presents 40 steel cans, each containing 5 L of solvent-based adhesive, for a passenger flight from Amsterdam to Nairobi. The safety data sheet gives a closed-cup flash point of 21 °C and an initial boiling point of 38 °C; the adhesive contains 45% toluene and 10% acetone. The shipper has completed the Shipper's Declaration as 'UN 1133, Adhesives, 3, PG III, 40 × 5 L, 200 L, packing instruction 353' and has packed all 40 cans into one 4G fibreboard box. The box bears a UN specification marking '4G/Y30/S/…' and its actual gross mass is 214 kg. The shipper argues that the flash point is above 0 °C, so PG III is appropriate, and that the 5 L cans are inner packagings so the passenger aircraft limit does not apply to the outer package.
1. Determine the correct class, packing group and packing instruction for this adhesive. Show how the flash point and boiling point lead to your answer.
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Class 3, PG II. The packing group is set by the flash point and initial boiling point, not by the presence of toluene or by the fact that the flash point is above 0 °C. For a Class 3 liquid: PG I applies when the initial boiling point is 35 °C or less; PG II applies when the flash point is below 23 °C and the initial boiling point is above 35 °C; PG III applies when the flash point is 23 °C or higher and not more than 60 °C. Here the flash point is 21 °C (below 23 °C) and the initial boiling point is 38 °C (above 35 °C), so the correct packing group is II. UN 1133 Adhesives, Class 3, PG II, is assigned packing instruction 353 for passenger aircraft (or 355 for cargo aircraft). The shipper's PG III entry is wrong, and the error changes both the quantity limit and the packing instruction.
2. Evaluate the package and quantity against the applicable passenger aircraft limits. Include the UN specification marking and the shipper's inner-packaging argument.
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Under PI 353 for a PG II Class 3 liquid, the maximum net quantity per package on a passenger aircraft is 5 L. That limit applies to the completed package, not to each inner can. A single outer box containing 4 × 5 L = 20 L therefore exceeds the limit by a factor of four. The UN specification marking is also inconsistent: '4G/Y30' is a fibreboard box with a maximum gross mass of 30 kg for the Y (Packaging Group II/III) rating, but the box is declared at 214 kg actual gross; the Y marking does not authorize 214 kg. The '5 L inner' argument does not save the package. Limited-quantity relief is also unavailable: for Class 3 PG II the limited-quantity inner limit is 1 L, so a 5 L can is not eligible. The package is not acceptable as offered.
3. What should the acceptance agent do, and what corrections would make the shipment acceptable for passenger aircraft?
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Reject the consignment as offered; do not sign the acceptance checklist. The shipper must correct the packing group to II, repack so that each outer package contains no more than 5 L net (for example, one 5 L can per 4G box) and so that the actual gross mass does not exceed the UN marking, and submit a new DGD showing the correct PG, PI 353 and net quantity. If the shipper wants to keep the 40 cans in fewer packages, the alternative is a cargo aircraft shipment under PI 355, where the PG II limit is 60 L per package, but then the package must bear the 'Cargo Aircraft Only' label and the DGD must reflect PI 355. In either case, the operator must verify the UN specification, labels, marks and 24-hour emergency contact before acceptance.