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Transportation of small quantity or small packaged dangerous goods is a major focus of hazardous good logistics enterprise and transport operators. In the past, small quantity or small packaged dangerous goods could be transported via special vehicles only, rather than express or transported as general goods, bringing relatively high cost for enterprise.
China’s new RTDG regulation JT/T617-2018 adds exemptions for dangerous goods transport in the general provision which will reduce the compliance obligations and financial burdens for relevant stakeholders. Although it doesn’t offer 10 categories’ of exemption in ADR it still offers the potential to reduce logistics costs for stakeholders. It is necessary for stakeholders to understand the exemption criteria for small quantity dangerous goods and exemptions for special provisions, limited quantity and excepted quantity.
1. Transport requirements exemption for small quantity dangerous goods
Partial transport requirements in JT/T617 could be exempted when dangerous goods carriage amount in each transport unit doesn’t exceed its maximum carrying capacity (refer to JT/T617.1, table 1). Exemptions in each part are:
JT/T 617.1 General Provisions | R Article 9 Security and defense requirements |
JT/T 617.2 Classification | - |
JT/T 617.3 Index of Dangerous goods name and transportation requirement | - |
JT/T 617.4 Provisions for the use of transport packagings | - |
JT/T 617.5 Consignment | R Article 7 Container, tank and vehicle plate and mark R Article 8.4 Safety card of road transport of dangerous goods |
JT/T 617.6 Provisions concerning the conditions of carriage, loading, unloading and handling | R Article 5 Loading, unloading conditions of package carriage(except V5 and V8 in appendix A) R Appendix C CV1 |
JT/T 617.7 Transport conditions and operational requirements | R Exemption except 4.3.1、4.3.3-4.3.6、5.3、6.1.1a)、6.2.3、6.2.4、6.2.5、6.3、6.5的S1(a)、S1(d)、S2(a)、S4、S5、S14-S21、S24) |
How to determine if dangerous goods meet the small quantity transportation exemption criteria?
Find transport category and maximum carriage amount according to UN number and packing group
Find transport category
a. Via JT/T617.1 Table 1: Dangerous goods are classified into 5 transport categories, which are 0, 1, 2, 3 and 4, to facilitate the classification management of carriage limit for each transport unit and the calculation for maximum carriage amount. The packing group, class code and UN number of 5 classes could refer to JT/T 617.1 Table 1.
b. Via JT/T 617.3 List of dangerous goods: The 15th column in Appendix A- List of dangerous goods in JT/T617.3 indicates transport categories of all dangerous goods, which is a more intuitive way to identify the category.
Example 1: JT/T 617.1 Table 1 Result for UN3473, Class 3
Example 2: JT/T 617.3 List of dangerous goods Result for UN3473 Class 3
Ascertain maximum carriage amount of each transport unit
In the case that carried dangerous goods belong to the same category, the maximum carriage amounts per transport unit corresponding to each transport category are as below:
Transport Category | Maximum Carriage Amount per Transport Unit (KG/L) | |
JT/T 617 | ADR 2015 | |
0 | 0 | 0 |
1 | 10 | 20 |
2 | 160 | 333 |
3 | 500 | 1000 |
4 | Unlimited | Unlimited |
*The maximum carriage amount in JT/T617 and ADR are different, and the same dangerous goods might be divided into different categories in two regulations. For an example:
UN No. | Chinese Name and Description | English Name an description | Hazard category | JT/T 617 | ADR 2015 | ||
Transport category | Maximum carriage amount per transport unit | Transport category | Maximum carriage amount per transport unit | ||||
3232 | B型自反应固体，控温的 | Self-reactive liquid type B, Temperature controlled | 4.1 | 0 | 0 | 1 | 20 |
2215 | 马来酐 | Maleic Anhydride | 8 | 0 | 0 | 3 | 1000 |
3473 | 燃料电池筒，或设备中含有的燃料电池筒或与设备装在一起的染料电池筒，含有易燃液体 | Fuel Cell Cartridges or fuel cell cartridges contained in equipment or fuel cell cartridges packed with equipment containing flammable liquids | 3 | 3 | 500 | 3 | 1000 |
(1). If dangerous goods belong to the same transport category, maximum carriage amount should accord to above method. In the case carriage amount doesn’t exceed the maximum limit, partial transport requirements are exempted.
(2). If dangerous goods belong to different transport categories, the maximum carriage amount per transport unit should not exceed 500 (KG/L) calculated by timing coefficients:
Amount multiple 50 in the case of dangerous goods in transport category 1
Amount multiple 3 in the case of dangerous goods in transport category 2
Amount multiple 1 in the case of dangerous goods in transport category 3
*The differences between JT/T617 and ADR also exist in coefficients and maximum carriage amount.
Example for calculating the carriage amount:
Scenario: A carrier plans to consign below dangerous goods in one transport unit: 20kg of UN 3108, 180kg of UN1299 and 60kg of UN1888.
Find the corresponding transport category and choose the related coefficients. The final amount for mixed carriage amount is 420 kg which is less than 500kg, and is eligible for small quantity transportation exemption.
Goods | Category | Carriage （kg） | Coefficient | Equivalent in mixed loading （kg） | Total carriage in mixed loading （kg） |
UN3108 | 2 | 20 | 3 | 20 *3=60 | 420（＜500） |
UN1299 | 3 | 180 | 1 | 180*1=180 | |
UN1888 | 2 | 60 | 3 | 60 *3=180 |
2. Transport requirements exemption in special provisions
Dangerous goods which meet the special exemption provisions in Appendix A, column 6 in JT/T617.3-2018 shall be exempted according to relevant items and requirements in Appendix B of JT/T617.3-2018.
Special provisions are presented in numbers. Details have been listed in Appendix B in sequence. Based on the practical situation in domestic transportation, not all special provisions in ADR are adopted, however in consideration of consistency, the non-adopted numbers are not cancelled and listed in Appendix B as “retained”, for instance, 123(retained).
Details of special provisions are mainly connected with the categories of dangerous goods. Dangerous goods meet special provisions will not be transported as dangerous goods. Exemptions in the special provisions are mainly divided into below several situations:
(1). The ingredient or the concentration of dangerous goods meets special provisions, such as 38, 39, 45, 47, 59, 62, 66, 138, 142, 144, 169, 177, 208, 215, 226, 249, 252, 271, 305, 332, 533, 543, 587, 590, 591, 597, etc.
Example 1: Although formaldehyde solution is listed in the list of dangerous goods, a further determination is needed based on its concentration. According to the special provision, if the formaldehyde solution is flammable, then it is category 3 dangerous goods; if the formaldehyde solution is non-flammable with formaldehyde no less than 25%, then it is category 8 dangerous goods, otherwise it is general goods.
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provision |
2209 | 甲醛溶液，含甲醛不少于25% | Formaldehyde solution with not less than 25% formaldehyde | 8 | Ⅲ | 533 |
Special provision SP 533: UN1198 Formaldehyde solution, flammable, Category 3; Formaldehyde solution, non-flammable, formaldehyde less than 25%, is not subject to JT/T 617.1-2018~JT/T617.7-2018
Example 2:
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provisions |
3065 | 酒精饮料，按体积含酒精超过24%但不超过70% | Alcoholic beverages, with more than 24% but not more than 70% alcohol by volume | 3 | Ⅲ | 144 145 247 |
Special provision SP 144: Aqueous solution with alcohol no more than 24% by volume is not subject to JT/T 617.1-2018~JT/T617.7-2018
(2).The form/shape of dangerous goods meets special provisions, such as 32, 242, 546, 586, 588, 600, etc.
Example:
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provisions |
1350 | 硫 | Sulphur | 4.1 | Ⅲ | 242 |
Special provision SP 242: Sulphur into certain shapes (such as globule, particle, pill form or slice) is not subject to JT/T 617.1-2018~JT/T617.7-2018
(3).Package requirements for carriage amount meets special provisions, such as 119, 145, 190, 191, 286, 291, 319, 366, etc.
Example:
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provisions |
3065 | 酒精饮料，按体积含酒精超过24%但不超过70% | Alcoholic beverages, with more than 24% but not more than 70% alcohol by volume | 3 | Ⅲ | 144 145 247 |
Special provision SP 145: Alcoholic beverage with packing category Ⅲ loaded in containers no more than 250L is not subject to JT/T 617.1-2018~JT/T617.7-2018
(4).Articles meet special provisions, such as 188, 238, 251, 289, 594, etc.
Example:
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provisions |
0503 | 气囊充气器或气囊装置或座椅安全带预张紧装置 | Safety devices, pyrotechnic | 1 |
| 235 289 |
Special provision SP 289: Air bags or seat belts installed in vehicles or in vehicle components such as steering rods, door paneling, seats, etc., are not subject to JT/T 617.1-2018 ~JT/T617.7-2018
(5). Other special provisions, such as 141, 168, 199, 241, 283, 335, 346, 646, etc.
Example:
UN Number | Chinese Name and Description | English Name and Description | Hazard Category | Packing Category | Special Provisions |
1362 | 碳，活性的 | Carbon, activated | 4.3 | Ⅲ | 646 |
Special provision SP 646: Carbon obtained by steam activation is not subject to JT/T 617.1-2018 ~JT/T617.7-2018
3. Transport Requirements Exemption in Limited Quantity and Excepted Quantity
Dangerous goods transported in limited quantity and excepted quantity are also exempted from major transport requirements, ChemLinked will provide an analysis and interpretation of these conditions in a following article.
With the release of JT/T 617-2018, enterprise could benefit from transport requirement exemption and save costs by making a transport plan compliant to the regulation according to the category, carriage amount, packing group, etc., of dangerous goods.
