Sampling Dangerous Goods

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1. Sampling of dangerous goods

Dangerous Goods are goods which could pose a direct safety and health risk when sampled, particularly chemicals, chemical preparations and chemical waste material, labelled according to IATA, IMDG or ADR regulations. In trade those goods are accompanied with all relevant paperwork.

Sampling of dangerous goods should only be done by officers trained and equipped to sample these kinds of goods. Alternatively, a contractor may be called in, but the procedure may vary in different Member States.
Where sampling is carried out by a contractor, the customs officers must supervise the sampling since customs remain responsible for the sampling. Ensure that the sample is sealed and labelled correctly. Appropriate labels with the hazard class and symbol must be fixed to the sample and a copy of the SDS must be attached to the sample form.

It is essential that everyone involved in the sampling including officers supervising contractors are wearing the appropriate Personal Protective Equipment.

Products which are not classified as dangerous goods may still pose a threat to those who come into contact with them. The SDS of a chemical or product will give more comprehensive information on its dangerous properties.
For more information on the Health and safety risks see the chapter on Hazardous Substances.

When goods are classified as dangerous goods, it should be mentioned on the bill of lading and/or in the declaration of the goods. It is mandatory to supply product specifications and safety regulations (e.g. the SDS).
When goods are not declared as being dangerous goods but you are in doubt about the safety risk of sampling, the importer should be asked for the SDS or the technical specifications of the product if no SDS is available. This information should be present before the inspection of the consignment. If you are still in doubt, you should consider the product as goods with unknown composition. You may ask the customs laboratory or your national inspectorate for dangerous goods for further information and instructions.

You must never sample the following (extremely dangerous) products (even when in retail sale packages!):

• Explosives and fireworks;
• chemical and bacteriological warfare materials and contagious products;
• Radioactive compounds and nuclear material.

If necessary, these extremely dangerous products should be sampled by other competent official bodies. Customs laboratories are in general not equipped to safely store and analyse these samples. Send these samples to a competent laboratory.

Small and medium packages containing dangerous goods may be sent unopened to the laboratory after consultation, provided the packaging is original, secure and undamaged.

Larger packages should be sampled by a trained officer or contractor, if sufficient safety precautions are available (e.g. personal protective equipment, ventilated workspace e.g. fume hood - if necessary). The formation of aggregated samples should be avoided as far as possible to reduce exposure.

Certain dangerous products are not sampled by Customs because of special agreements with other official bodies, dependent on the national regulations.

Suitable transport to the customs laboratory must be arranged taking into account the rules on the transport of dangerous goods. Usually samples of dangerous goods can be transported in limited quantities, where ADR regulations are significantly less elaborate. For more information about ADR see chapter Transport of dangerous goods by road ADR. See also regulations IATA and IMDG.

If the goods are found not to be in accordance with the information supplied (labelling, hazard class, documents), the goods should be treated as goods with unknown composition. If in doubt consult the laboratory and your superiors regarding the accuracy of the information and any discrepancies found.

The amount of sample of dangerous goods for both qualitative and quantitative analyses should be kept as small as possible in order to reduce the risk and avoid unnecessary waste. Consult your customs laboratory or another competent laboratory about the amount of sample required.

Never take dangerous products or products with unknown composition to an office area! 

2. Sampling of goods of unknown composition

Substances of unknown nature have to be handled with care and should be treated as dangerous substances until they have been identified.

Substances of an unknown chemical composition may arise from the trafficking of controlled chemicals like:

• drugs;
• precursors of drugs;
• explosives precursors;
• pharmaceuticals;
• NPS;
• Military or dual-use goods.

In these cases, there is either no information available or the information provided is expected to be false. Doubts about the chemical nature of goods may also arise from contradictive declarations or because substances are part of a monitoring program.

Unknown substances must be handled with care and should be treated as dangerous substances until they have been identified.
For more information on the Health and safety risks see the chapters Hazardous Substances and Drugs and illicit substances.

There are several techniques available to attempt the identification of unknown substances on site. In some cases, handheld devices may be able to identify substances without opening transparent packaging (e.g. Raman spectrometer). Otherwise, small samples have to be obtained for the identification using other handheld devices, e.g. IR spectrometers, rapid tests or mobile instruments. In all cases, packaging has to be removed carefully layer by layer in order to avoid accidental spillage. If small samples have to be obtained for testing, small tubular probes and special seals to immediately reseal the package are needed. Officers should receive special training for the use of testing instruments, including opening packages of these type of goods, and be aware of the limitations of this type of testing.

If an unknown substance cannot be identified on site, you will need to seek expert advice (customs laboratory, internal or external specialist). If further testing is necessary small packages up to 5 kg/ 5 l can be sent to the laboratory without sampling the content. Larger packages should be sampled using similar precautions and safety measures as describes for Dangerous Goods. Preferably however these goods should not be opened in the field. Therefore, it is recommended that these packages are sent to the laboratory unopened. But different procedures may apply in your country. Consult your local officers or customs laboratory for more information.

If substances have been identified or are suspected to be illicit substances the entire load will need to be seized. The tasks performed by customs laboratories in the identification and analysis of illicit substances vary in member states from the identification of substances to the full analysis of the seizure. Consequently, sampling procedures largely depend on the type of analysis to be performed by the customs laboratory and on national regulations on forensic procedures for the sampling of drug seizures. Therefore, you must consult your national regulations on sampling illicit drug seizures.

Remark: the practice regarding these type of samples might change faster than for other types of samples. Always consult actual information!

For more information on sampling of illicit drugs see:

• the United Nations Office on Drug and Crime (UNODC)
• the European Network of Forensic Science Institutes (ENFSI)