The purpose of this page is to bring together the essential packaging regulations for the example substances, making it easier for the reader to gain an understanding of the requirements and restrictions pertaining to the different packaging methods.
The choice of packaging and markings is dependent on the hazard class, quantity and mode of transport of the substance or item. You should first verify the transport information of the goods, for example, in the classification information under heading 14 of the safety data sheet (SDS). You can find the official legal requirements in the relevant decrees and regulations. Table A of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road provides a list of dangerous goods in UN number order as well as the applicable packaging regulations, warning labels, etc.
Note: Before sending dangerous goods, always check the regulations applicable to the mode of transport. In the examples below, the markings are only considered from the viewpoint of TDG legislation. No other mandatory markings, such as CLP warning labels, are discussed.
As a rule, the person packing a shipment of dangerous goods is not required to have a qualification for the task. More than other modes of transport, air transport has a higher degree of qualification requirements. For all modes of transport, legislation requires, e.g. packers and senders to have some informal task-specific training. On the other hand, companies that pack, send or transport dangerous goods on a regular basis should have a responsible person who is familiar with the special requirements related to the transport of dangerous goods or a so-called TDG safety adviser. For more information on safety adviser matters and acquiring a qualification, see the Traficom website.
Example 1: Ethanol-based hand sanitizer
When transported, hand sanitizers are dangerous goods as they normally have approximately 70% of alcohol by volume, which means that they are classified as flammable substances in transport risk class 3. The most common hand sanitizer transport titles include UN1987 ALCOHOLS, N.O.S (name of active ingredient) and UN1170 ETHANOL SOLUTION (ETHYL ALCOHOL SOLUTION). There are also other titles, which is why the transport information of the product should always be verified in the classification information under the SDS heading 14.
The example demonstrates the packaging in accordance with the packaging method proscribed for the substance (small packaging and IBC) as well as two methods for a limited substance quantity. The presented exceptions, the transport of a Limited Quantity (LQ) and Excepted Quantity (EQ), are not necessarily permitted for all goods under all modes of transport.
Substance information
UN number and substance name: UN1170 ETHANOL (ETHYL ALCOHOL) or ETHANOL SOLUTION (ETHYL ALCOHOL SOLUTION)
Hazard class: 3
Packaging group: II
Excepted quantities: E2
Special packaging regulations: 144, 601
Limited quantities: 1 L
Warning labels: 3 (flammable liquid)
Packaging methods: P001, IBC02, R001
Combination packaging regulations: MP19
Hazard ID number: 33 (flammable liquid, flash point below 23°C)
Packaging method P001
Table A, column “Packaging methods (8)” of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road specifies the permitted packaging methods for the substance. The used hazard label is the label type specified in accordance with Table A “Labels (5)”, and the UN number of the substance is marked on the packaging. The packaging used is UN-certified. The packaging method indicates the allowed type and material of packaging.
In addition to the packaging method, the second important criterion for selecting a packaging is the X, Y or Z in the packaging certification marking , which indicates the suitability for different hazard levels, i.e. packaging groups. Column “Packaging group (4)” of Table A includes the packaging group of the substance. The packaging groups from the highest to lowest hazard are I, II and III. Packaging group I substances are marked by X, packaging group II substances are marked by X or Y, and the least hazardous packaging group III substances are marked by X, Y or Z. In other words, a packaging approved for more hazardous substances is, as a rule, also suitable for less hazardous ones. What this means for packaging group II hand sanitizer is that the packaging must be certified for either packaging group I or II. In other words, the certificate must include either X or Y.
In a combination packaging, retail packagings or similar are placed inside a certified outer packaging.
A certified individual packaging may be a transferable package in and of itself. They include, for example, certified canisters and barrels.
In a Limited Quantity, LQ (1 L)
Column “Limited Quantities (7a)” in Table A of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road specifies the quantity limit of the transported good. The hazard label is the LQ package label in accordance with the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road, section 3.4.
In an Excepted Quantity, EQ (E2)
Table A, column “Excepted Quantities (7b)” of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road specifies the excepted quantity code of the substance. EQ code E0-E5 specifies the net limit for the internal packaging and package. The hazard label is the EQ package label in accordance with the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road, section 3.5.
IBC packaging method IBC02
Table A, column “Packaging methods (8)” of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road specifies the permitted IBC packaging methods for the substance. The used hazard label is the label type specified in accordance with Table A “Labels (5)”, and the UN number of the substance is marked on the IBC packaging.
In addition to the packaging method, the second important criterion for selecting a packaging is the X, Y or Z in the IBC packaging certification marking, which indicates the suitability for different hazard levels, i.e. packaging groups. Column “Packaging group (4)” of Table A includes the packaging group of the substance. The packaging groups from the highest to lowest hazard are I, II and III. Packaging group I substances are marked by X, packaging group II substances are marked by X or Y, and the least hazardous packaging group III substances are marked by X, Y or Z. In other words, a packaging approved for more hazardous substances is, as a rule, also suitable for less hazardous ones. What this means for packaging group II hand sanitizer is that the IBC packaging must be certified for either packaging group I or II. In other words, the certificate must include either X or Y.
Example 2: Refrigerant gas R 134a
Substance information
UN number and substance name: UN3159 1.1, 1.2-TETRAFLUOROETHANE (REFRIGERANT GAS R 134a)
Hazard class: 2
Packaging group: -
Excepted quantities: E1
Special packaging regulations: 662
Limited quantities: 120 ML
Warning labels: 2.2 (non-flammable, non-toxic gas)
Packaging methods: P200
Combination packaging regulations: MP9
Hazard ID number: 20 (suffocating gas or gas without additional hazard)
Packaging method P200
Table A, column “Packaging methods (8)” of the Finnish Transport and Communications Agency Regulation on the Transport of Dangerous Goods by Road specifies the permitted packaging methods for the substance. The packaging method indicates the allowed type and material of packaging. For gases, the most common packaging method is P200. Gas vessels, such as different gas cylinders must conform to it. You can find information on the conformity of gas cylinders here.
Dangerous good UN number: UN 3159
The marking on the gas cylinder includes the UN number of the dangerous good. The marking should be at least 12 mm high.
Warning labels in accordance with the TDG hazard class: Warning label 2.2 (non-flammable, non-toxic gases)
The hazard label is the label type specified in accordance with Table A, “Labels (5)”. The warning label must be a square resting on its tip. The warning label must be at least 100 mm x 100 mm in size. If a full-size label does not fit on the gas cylinder, the label may be reduced subject to the conditions provided in the terms of transport.
Other warning signs:
The warning labels used in TDG shipments are not the same as the warning signs in the CLP regulation. A CLP warning sign that is not required by the transport regulations should only be displayed on the shipment as part of a whole CLP warning label, not as a standalone sign.
Gas cylinder certification mark: ... π0031 ABC1 -40°C 2009/01 ...
The π sign and inspection body ID number in accordance with the Directive on Transportable Pressure Equipment (2010/35/EU). In Finland, the material must be able to withstand temperatures down to -40°C. The sign also indicates the time of manufacture, for example.
Gas cylinder inspection marking:
In the periodic inspection of a gas cylinder, the inspection body stamps the cylinder with an inspection stamp. The periodic gas cylinder inspection stamp is comprised of the inspection body’s ID and the time of the periodic inspection: year-month. The cylinder should be equipped with a label indicating the year of the next periodic inspection.
Transport title of the substance:
1.1, 1.2-TETRAFLUOROETHANE (REFRIGERANT GAS R 134a) The official transport title of the dangerous substance contained by the gas cylinder, if required by the transport mode regulations. The minimum size of the marking is the same as that of a UN number.
Gas cylinder colour:
The colour markings of gas cylinders (SFS-EN 1089-3) are based on the properties of the gas. The standard does not apply to LPG, refrigerants, portable extinguishers or the gas cylinders of fixed extinguishing systems.
