Does IATA SP A802 Require UN Specification Packaging for Limited Quantity CO₂ Cartridges?

Calling all IATA DG experts… I have another brain twister for the “Wisdom of the [DG] Crowds.” An ICAO/IATA SP seems to require Spec Packaging for LQ shipment.

I [really — not theoretical] have small CO2 cartriges (under 50 ml but 800 psi) I’m shipping from the US to, say Europe.

This is a huge e-bike company and I can’t take any chance on being imprecise.

I have forty 25-gram cartridges (gas receptacles, not aerosols) in a LQ box under PI Y203. So then there’s SP A802 which corresponds to UN2037 which says this:

A802 Notwithstanding the absence of a packing group in column E, substances and articles assigned to these entries must be packed in UN Specification packagings that meet packing group II performance standards. This does not apply when —aerosols— are prepared for transport in accordance with the limited quantity provisions…

So I added the dashes there for the word “aerosols”. I don’t know if ICAO/IATA -intended- to limit the exception to the restriction to be for aerosols or EVERYTHING under UN2037 which are, for the most part, gas receptacles without a self-closing release device…. so “aerosol” doesn’t seem appropriate. In appendix A it defines an aerosol and adds the word “and” (fitted with a self-closing release device).

So, a CO2 cartridge is not an Aerosol, is it? And so… how can SP A802 require me to have spec packaging at a PG II level for a limited quantity shipment?

Doesn’t make sense.

Some might say “oh just ignore that — they MEANT to say aerosols or gas receptacles…. but wanted to save space.”

If I had to guess, I’d say that the ICAO A802 variation is not precise, I think it does include gas receptacles and for convenience or oversight they just used the word “aerosols” when they meant “articles like aerosols or gas receptacles…” because I think that’s where this all came from — remember packing groups were eliminated years ago for “articles” and I would image this SP was put in here to ensure some minimal packaging integrity for articles not shipped as an LQ.

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Extra credit question: tell me why SP A98 doesn’t work to or from the US or on a US carrier. These cartridges are under 50 mL but are about 800 psig.