SP 274 the ‘What’ and ‘Whys’ of Technical Names

Special Provision 274 assigned to Generic and Not Otherwise Specified (N.O.S.) entries in Model Regulations requires the shipper to supplement the Proper Shipping Name (PSN) with Technical Name on the Packages (marking) and in shipping papers (Dangerous Goods Declaration).

 ‘What’ must supplement the proper shipping name and ‘Why’ this is required.

What

The Generic and N.O.S. entries assigned with SP 274 shall be supplemented with

  • Technical or Chemical group names
  • Shall be a recognized chemical or other name currently used in scientific and technical handbooks, journals and texts.
  • Shall be entered in brackets immediately following the Proper Shipping Name
  • Modifier, such as “contains” or “containing” or other qualifying words such as “mixture”, “solution”, etc., and the percentage of the technical constituent may also be used
  • Trade names shall not be used for this purpose

 For Pesticides below may be used:

  • ISO common name(s),
  • other name(s) in the WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification
  • the name(s) of the active substance(s)

When not required?

When a national law or international convention prohibits disclosing the name of a controlled substance.

Why Technical name is required?

Below table shows some of the reasons for the requirement of technical names through special provision 274

 

LOGIC OF TECHNICAL NAME UNDER SP 274 - UN MODEL REGULATIONS
LOGIC OF TECHNICAL NAME UNDER SP 274 – UN MODEL REGULATIONS
  • Example: UN 1993 Flammable liquid, n.o.s. (contains xylene and benzene)

 

This article is in accordance with 37th amendment of IMDG Code.

Mercury (Hg)

We all know mercury is a silvery metal in liquid form. Probably most of us first saw it in childhood at the mirror like shining bulb end of thermometer when doctor pushed the thermometer in to our mouth .

In ancient days mercury was thought to have medicinal properties which will prolong life !! 🙂 Qín Shǐ Huáng Dì, Emperor of China, died due to  drinking a mercury and powdered jade mixture formulated by Qin alchemists thinking he will attain immortality. The Emperor’s tomb contained flowing mercury models of rivers in china. Ancient Egyptians and Greeks used mercury in cosmetics and other ointments.

Mercury is highly corrosive to aluminium and is classified as Corrosive Substances (Class 8) in model regulations. Recent study of corrosive effect of Mercury on Aluminium states that  heavy and sudden corrosion will take place leading to pitting and cracking which increases by presence of humidity. On mild steel the corrosion rate is.25mm/year.

Mercury is traditionally sold in flasks measuring about 2.5 litres (34.5 kg or 76 lb.). This weight is equal to one Spanish quintals; Spain was one of the biggest producers of mercury. Mercury is having high density of 13.54562 g/cm3

For sea transport IMDG Code list mercury under UN 2809 MERCURY Class 8 with special instruction prohibiting transport by hovercraft and other ships constructed of aluminium.  IMDG Code allows flasks up to 3L for transporting Mercury by sea, including the empty flask the total gross mass per flask may be around 45-50 kg.

There is a new convention by United Nations named Minamata Convention for protecting human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds.

Mercury Flask
Mercury Flask
Overpack containing Mercury
Overpack containing Mercury

If you are shipping Mercury or any article containing Mercury by Sea it is a mandatory requirement that you receive training to handle same as per IMDG Code.

For details of training click here  Click here for Elearning

DANGEROUS GOODS IN MACHINERY or APPARATUS

Certain machinery or apparatus containing small quantities of dangerous goods may be transported by sea under UN Number 3363 Class 9.  For assigning this UN Number various factors must be checked and ensure the conditions laid down in special provision 301 of UN Model Regulations / IMDG Code are met with.

Danger Class 9 sign, Dangerous Goods

Click here to see n example of Dangerous goods in apparatus.

Special provision 301 of UN Model Regulations

  • The entry UN 3363, DANGEROUS GOODS IN MACHINERY or DANGEROUS GOODS IN APPARATUS, Class 9 only applies to machinery or apparatus containing dangerous substances as a residue or an integral element of the machinery or apparatus.
  •  It shall not be used for machinery or apparatus for which a Proper Shipping Name already exists in the Dangerous Goods List.
  •  Machinery and apparatus transported under this entry shall only contain dangerous goods which are authorized to be transported in accordance with the provisions in chapter 3.4 (Limited quantities).
  • The quantity of dangerous goods in machinery or apparatus shall not exceed the quantity specified in column 7a of the Dangerous Goods List for each item of dangerous goods contained.
  •  If the machinery or apparatus contains more than one item of dangerous goods, the  individual substances shall not be capable of reacting dangerously with one another  (see 4.1.1.6).
  • When it is required to ensure liquid dangerous goods remain in their intended orientation, package orientation labels meeting the specifications of ISO 780:1985 shall be affixed on at least two opposite vertical sides with the arrows pointing in the correct direction.
  • The transport of dangerous goods in machinery or apparatus where the quantity of dangerous goods exceeds the quantity specified in column 7a of the Dangerous Goods List is authorized when approved by the competent authority.

European road regulations do not consider UN 3363 as dangerous goods.  Section 1.1.3.1.( Exemptions related to the nature of the transport) section (b)  of ADR states “ The carriage of machinery of equipment not specified in this Annex and which happen to contain dangerous goods in their i8nternal or operational equipment, provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage”.

Not Subject to IMDG Code

Certain substances, materials or articles which are listed in the UN Model regulations are not considered as hazardous for sea transport. However due to harmonization of rules these are listed in IMDG Code.

Below are the entries of such substances, materials or articles in IMDG Code 35-10.

UN No. Class Proper Shipping Name
1910 8 CALCIUM OXIDE
2807 9 MAGNETIZED MATERIAL
2812 8 SODIUM ALUMINATE, SOLID
3334 9 AVIATION REGULATED LIQUID, N.O.S.
3335 9 AVIATION REGULATED SOLID, N.O.S.