Packing instruction P650: the three layers, the marks and what a courier checks at pickup

P650 is the packing instruction the ADR links to UN 3373, Biological Substance, Category B, in its list of dangerous goods (Table A). It therefore applies as soon as a specimen is classified as Category B. That classification is made by the sender, not the carrier; how that works and what Category A, Category B and the exempt specimen are is explained in what UN3373 means. Why the ADR also applies domestically and which exemptions exist is explained in ADR and medical specimens; the overview of the subject in transporting medical specimens.

P650 does not apply to the two other outcomes. An exempt human specimen, with a minimal likelihood of pathogens, is not a dangerous good; the ADR does require for it a leakproof packaging in three layers with absorbent material, one surface of at least 100 by 100 millimetres and the marking 'Exempt human specimen'. Category A (UN 2814 and UN 2900) falls under packing instruction P620 and under the full ADR provisions. P650 sits in between: stricter than an exempt specimen, much lighter than Category A.

A P650 packaging consists of at least three components: a primary receptacle, a secondary packaging and an outer packaging. Either the secondary or the outer packaging must be rigid. For liquids the primary receptacle and the secondary packaging must be leakproof, and there must be enough absorbent material between the two to absorb the entire contents, so that nothing reaches the outer packaging if there is a leak. In addition, either the primary or the secondary packaging must withstand an internal pressure of 95 kPa without leakage. Solids must be packed siftproof.

The complete packaging must pass a drop test of 1.2 metres, and at least one surface of the outer packaging measures 100 by 100 millimetres, so that the mark fits on it. Anyone placing several primary receptacles in one secondary packaging must match the absorbent material to the combined contents. The usual solution in practice is a tube or pot (primary), a sealable bag or canister with absorbent material (secondary) and a sturdy box or case (outer).

The outer packaging carries a diamond-shaped mark of at least 50 by 50 millimetres containing UN3373, and next to it the proper shipping name BIOLOGICAL SUBSTANCE, CATEGORY B in letters at least 6 millimetres high. That is what the ADR requires. The World Health Organization also mentions, in its guidance, the name and telephone number of a responsible person on the package; that requirement comes from the UN model regulations and the air transport rules, not from the ADR, but for the recipient a contact on the box is practical.

The mark should be legible and stay on the outer packaging: a mark that runs across a seam, half disappears under tape or is handwritten in a box that is too small does not do what it should. A courier checks exactly this at pickup: is the mark there, is it complete and is it legible?

P650 places a duty on the manufacturer or distributor of the packaging: they must give the sender clear instructions on filling and closing, so that the packaging does in practice what it did in the test. A P650 packaging is a system; a different bag, a different tube or a clamp that was not closed can undo the pressure resistance or the leakproofness. Anyone buying a packaging without instructions has no evidence that the whole complies with P650.

Responsibility for the packaging stays with the sender. The ADR requires the sender to use only approved and properly marked packagings, and the packer to observe the packing provisions and the marking. The ILT sums it up: the sender classifies, informs and ensures correct packaging with marking; the sender may outsource those tasks, but remains responsible. There is no P650-certified carrier that takes that over; how the whole chain from collection to analysis runs is described in laboratory transport.

For road transport P650 sets no quantity limit per package. The limits often quoted, 1 litre per primary receptacle and 4 litres per outer packaging, with an itemised list between the secondary and outer packaging, come from the air transport rules of ICAO and IATA and are not in the ADR. The WHO confirms that for transport by road, rail and water no limit per package applies under P650. A laboratory that based its packaging protocol on the air transport rules therefore does more than necessary for road transport; that is not prohibited, but it is not an ADR requirement. Nor is a dangerous goods transport document required for UN 3373 under P650.

The carrier has its own duties under the ADR: it checks that the goods are authorised for carriage and that the prescribed information has been provided, and ascertains by visual inspection that the load shows no obvious defects, leakage or cracks. In doing so it may rely on the sender's information. If it finds an infringement, it may not continue the transport until it has been remedied. For a P650 shipment this comes down to: mark present and legible, proper shipping name next to it, outer packaging intact and dry, announced as agreed.

What the courier cannot see is the inside: whether the secondary packaging is closed, whether there is enough absorbent material and whether the 95 kPa requirement was met. That remains the sender's responsibility. A courier who takes a shipment without a mark or with a wet, torn box anyway takes on a risk that should not be its own; a courier who leaves it behind and reports that immediately does what the ADR asks.

Most rejections at pickup are not about exceptional situations but about a handful of recurring mistakes.

• The diamond mark is there, but the proper shipping name BIOLOGICAL SUBSTANCE, CATEGORY B is missing.
• The mark is smaller than 50 by 50 millimetres, illegible or half covered by tape.
• There is no absorbent material, or too little for the entire contents.
• Neither the secondary nor the outer packaging is rigid, for instance a bag inside a bag.
• The air transport limits of 1 and 4 litres are applied as a road rule, or the other way round: an air freight shipment without an itemised list.
• An exempt specimen is given a UN3373 mark, or a Category B specimen the marking 'Exempt human specimen', without anyone having made the classification deliberately.
• The supplier's filling and closing instructions are not followed, so that the whole is no longer what was tested.

UrgentX does not classify and does not pack: that is, and remains, the work of the laboratory or practice offering the shipment. What we do at pickup is check that the mark (UN3373, or 'Exempt human specimen' for an exempt specimen) is present and legible and that the outer packaging is intact and dry. A shipment that is not recognisable or is incompletely packed does not come with us, and we report it immediately. We transport specimens separately from medicines and documents, and there is a spill procedure with an absorption and disinfection kit in the car. What you get from us is described under transport of laboratory samples.