Packing, Marking and Labelling

Introduction

What are Packing, Marking and Labelling (“PML”) Requirements?

In order to harmonize general regulations with the International Maritime Dangerous Goods (“IMDG”) Code and promote safe storage and conveyance of DG in Hong Kong, the Fire Services Department (“FSD”), according to Section 142 of the Dangerous Goods (Control) Regulation (“Cap. 295G”), has put in place packing, marking and labelling (“PML”) requirements on Schedule 2 DG (“S2DG”) in the Dangerous Goods (Application and Exemption) Regulation 2012 (“Cap 295E”). For details of PML requirements, please refer to Parts III and IV of the Code of Practice for Control of Dangerous Goods on Land (“CoP”).

Packing

Pursuant to Section 92 of Cap. 295G, an S2DG packaging refers to receptacles (including those forming part of pre-packed S2DG packaging), tanks or materials receiving, holding or enclosing S2DG, but does not include vehicles, freight or aircraft containers.

The packing requirements regulate how DG shall be packed, including the sizes and materials of S2DG packaging.

Marking

Pursuant to Section 10 of Schedule 6 – Part 2 of Cap. 295G, the outer surface of an outermost S2DG packaging must be legibly marked with all of the following information:

(a) the UN number of each type of S2DG contained in the packaging; in the case of Class 3A DG, the HK number;
(b) the proper shipping name or true name of each type of S2DG contained in the packaging, in either English or Chinese, as specified in the CoP.

The information specified above must be marked in such a manner that it will still be clearly identifiable despite any exposure to open air and water.

Labelling

Pursuant to Section 13 of Schedule 6 – Part 3 of Cap. 295G, for an S2DG to be contained in an S2DG packaging, the outer surface of the outermost S2DG packaging must bear a label that is in the form of the Figures under Schedule 6 – Part 3 – Division 2 of Cap. 295G, and meet the specifications stated in Schedule 6 – Part 3 – Division 3 of Cap. 295G. You may also refer to the specimen labels provided in 3.4.3.4 of CoP.

The following table gives an example of proper packing, marking and labelling for UN 1402 CALCIUM CARBIDE / PG I, Class 4.3 contained in a single packaging with net mass = 200 kg:

Packing

Marking

Labelling

Self Photos / Files - Packing

UN 1402
CALCIUM CARBIDE

Self Photos / Files - Labelling

Basic Packing Instruction: BP403

Steel drum is a suitable single packaging for UN 1402 with net mass not exceeding 250 kg

Special Packing Instruction: SP31

For UN 1402, the packaging shall be hermetically sealed

UN No. : 1402

Proper Shipping Name:
CALCIUM CARBIDE

Figure No. 7a under Schedule 6 – Part 3 – Division 2 of the DG(C)R; or

3.4.3.4 of CoP

Exemption from PML Requirements

To facilitate trade operation and daily use of DG by the public, Cap. 295G contains specific provisions to exempt certain DG from PML requirements. There are two types of exemption – (a) and (b) below:

(a)

Exemption from packing, marking and labelling requirements:

Pursuant to Section 140 of Cap. 295G, the packing, marking and labelling requirements under section 142 do not apply to:

(i)

S2DG in consumer packs¹;

(ii)

S2DG with UN number "UN 3065" as specified in Part 2 of Schedule 2 to Cap. 295E;

(iii)

Class 3A DG in an approved tank²; or

(iv)

S2DG that are –

1.	contained in a receptacle that is permanently installed in and forming part of a machinery; and
2.	used or intended to be used for the proper functioning of the machinery.

(b)

Exemption from marking and labelling requirements:

Pursuant to Section 141 of Cap. 295G, the marking and labelling requirements under Section 142 do not apply to S2DG in limited packs³.

¹“Consumer packs”, in relation to S2DG, means –

(a)	for pre-packed S2DG – the capacity of the receptacle forming part of the pre-packed S2DG package does not exceed the maximum package size (if any) specified in column 9 of the table in Part 2, 3 or 4 of Schedule 2 of DG(A&E)R 2012 in relation to the DG; or
(b)	for the DG that are contained directly without any form of intermediate containment in a receptacle – the capacity of the receptacle does not exceed the maximum package size (if any) specified in column 9 of the table in relation to the DG.

²“Approved tank” means a tank approved under Section 114(1) of the DG(C)R.

³“Limited packs”, in relation to S2DG, means –

(a)	for pre-packed S2DG – the capacity of the receptacle forming part of the pre-packed S2DG package does not exceed the limited quantity (if any) specified in column 8 of the table in Part 2, 3 or 4 of Schedule 2 DG(A&E)R 2012, in relation to the DG; or
(b)	for the DG that are contained directly without any form of intermediate containment in a receptacle – the capacity of the receptacle does not exceed the limited quantity (if any) specified in column 8 of the table in relation to the DG.