Why are the majority of the worlds wipe manufacturers classifying their wipes as UN3175 and then advising they are not dangerous goods by quoting Special Provision 216?
On shipping wipes containing highly flammable liquids, the appropriate entry would be UN3175, to which is attached Special provision 216, which reads:
Mixtures of solids which are not subject to the requirements of ADR and flammable liquids may be carried under this entry without first applying the classification criteria of Class 4.1, provided there is no free liquid visible at the time the substance is loaded or at the time the packaging, vehicle or container is closed. Sealed packets and articles containing less than 10 ml of a packing group II or III flammable liquid absorbed into a solid material are not subject to ADR provided there is no free liquid in the packet or article
This paragraph I would read in 2 parts.
Part 1, up to the full stop.
This would mean that if I impregnated a wipe with a highly flammable liquid (its not an article as the cloth is only there to ‘carry’ the liquid), I do not have to test it in line with 4.1 criteria and I can use the entry UN3175 to ship it, as long as there was no free liquid when I load it.
Part 2, from the word Sealed.
Only when I use less that 10ml of liquid, and again there is no free liquid visible, would this be exempt the entry.
Where manufacturers are putting in 200ml – 2L of liquid this exemption can not be used.