How do I comply with Special Provision 327 for waste aerosols?

Waste aerosols

Aerosols are UN no 1950 and there are 12 entries in Table A of Chapter 3.2. Most aerosols are flammable only. The arrangements for "new" aerosols are well set out in ADR especially at chapter 6.2.

Waste aerosols are covered by a special provision SP 327 in part 3.3 which states

"Waste aerosols consigned in accordance with 5.4.1.1.3 may be carried under this entry for the purposes of reprocessing or disposal. They need not be protected against inadvertent discharge provided that measures to prevent dangerous build up of pressure and dangerous atmospheres are addressed.  Waste aerosols, other than those leaking or severely deformed, shall be packed in accordance with packing instruction P003 and special provision PP87, or packing instruction LP02 and special packing provision L2. Leaking or severely deformed aerosols shall be carried in salvage packagings provided appropriate measures are taken to ensure there is no dangerous build up of pressure."

Packaging made of any material including plastics and aluminium can be used as long as it is either "suitable" (P003 and its associated provisions) or certified for the purpose as LP 02.

The special provisions PP87 or LP02 must be met which means that whatever is used has to prevent a build up of pressure and be able to retain free liquid.

In any event a dutyholder has to do a risk assessment and that should consider amongst other things the risk of static charges, thermite reactions and how effective ventilation is likely to be given that it may only be applied at the tops of the packaging.

In principle packaging suitable for use in transport ought also to be suitable for on site storage but there may be good reasons why an alternative approach would be recommended.