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Use and abuse of ‘limited quantities’ declarations


The limited quantities provisions are frequently misunderstood – they are not a mechanism by which dangerous goods can simply be declared and placed into the supply chain as though they fall entirely outside of the scope of the applicable regulations


Non-declared or mis-declared cargo entered into the international supply chain vastly increases the risk to cargo, property, the environment and, most importantly, the lives of all individuals moving the goods. While problematic for all categories of cargo,


classified dangerous goods (DG) in particular pose the greatest challenges. The correct declaration of cargo is dependent on several factors, including expertise, knowledge and training. Ignorance of the underpinning regulations, and for international shipments, how those regulations interact with one another, has the potential to result in unintentional mis- declaration. Compliance, however, also requires that


stakeholders are motivated to do the right thing. 10


A recent survey suggested that 33% of mis- declaration was willful. Factors giving rise to these decisions include circumventing restrictions on the carriage of a particular commodity and financial gain, in the avoidance of the applicable DG surcharge.


Degrees of culpability? Methods of mis-declaration vary, which makes policing activity even more challenging. Shippers are known to alter the safety data sheet (SDS), use a less well known (or entirely incorrect) synonym as disguise or take advantage of special provisions, exempting the goods from the full application of the relevant regulations. Goods may also be shipped under the


provisions of limited quantities (LQ), partly taking


the goods outside the application of the relevant DG regulatory requirements, thus avoiding or attracting a lower surcharge. The LQ provisions are frequently misunderstood. ADR and the IMDG Code set out specific provisions, applicable to the carriage of certain classes of DG in limited quantities. The applicable quantity limit for the inner packaging or article is specified for each substance in Column 7a of Table A of Chapter 3.2 (the Dangerous Goods List). Important to highlight is that the value ‘0’ in Column 7a indicates that a particular substance is not permitted to be carried under the LQ provisions. DG packed in limited quantities, which meet


the criteria of the LQ provisions, largely but not entirely, fall outside the other provisions of ADR and the IMDG Code. In practice, the LQ provisions allow certain DG to be packed in inner packagings and placed in suitable outer packagings. This might, for instance, be 500 ml bottles of household bleach, packed in boxes of 10. The principle being that, in the event that the cargo transport unit, the pallet or even the outer packaging becomes damaged, there is a low probability that all of the inner packages would leak. Under the regulations, the total gross mass


October 2020


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