Golden year

Unlike other modal and national regulations covering the transport of dangerous goods, those published by the International Air Transport Association (IATA) change every year, rather than every two years. And while IATA’s Dangerous Goods Regulations (DGR) have no legal force, they are widely used by both air shippers and carriers as the field manual for the shipment of dangerous goods by air.

Next year’s 50th edition of the DGR takes into account the biennial changes being introduced by the International Civil Aviation Organisation (ICAO) in the 2009-2010 edition of the Technical Instructions. Other updates to the DGR derive from national and carrier variations.

The following is a summary of some of the major changes that users will expect to find. It is not exhaustive and users should check carefully against the official document to see how they will be affected.

Section 1 – Applicability

1.2.3 The exception provided for dangerous goods carried on an aircraft for use in providing medical treatment has been clarified. The revised text makes it clear that the exception applies to an aircraft adapted for specialised use – such as an air ambulance – or to a regular public transport aircraft where such carriage is approved by the operator.

Training There are changes to the provisions for recurrent training in 1.5.0.3. At present, refresher training is required every 24 months but, if this is undertaken early, the missing period is ‘lost’. Henceforth, any recurrent training undertaken within the three months leading up to the cut-off date will be regarded as having been completed on the expiry of the 24-month period.

‘No carry’ or ‘Will not carry’ operators have been added to the text and contents of Table 1.5.B, reinforcing the message that those carriers that have a policy of not accepting dangerous goods as cargo still need to train all applicable employees in the DGR. A new 1.5.3 specifies the training curriculum required for such personnel.

In 1.5.5.3 it is now specified that dangerous goods training records must be retained for at least 36 months.

The list of high consequence dangerous goods in 1.5.5.3 has been extended to include explosives of Divisions 1.4 and 1.5, substances of Class 3 and desensitised explosives of Division 4.1.

Section 2 – Limitations

Revisions have been made in Section 2.3 to the provisions for the carriage of solid carbon dioxide, small oxygen cylinders, underwater high intensity lamps, lithium batteries and fuel cell cartridges.

The requirements for dangerous goods in excepted quantities have been revised to come into alignment with the provisions newly introduced in the UN model regulations, which were derived directly from the air transport provisions. Amendments include the assignment of ‘EQ’ codes and the use of the new marking.

Amendments to the state variations in 2.9.2 have been received from Australia, France, Malaysia, UAE, UK and US. There are also a significant number of amendments to the operator variations in 2.9.4.

Section 3 – Classification

In 3.2.2.4 the exemption value for Division 2.2 gases has been revised from 280 kPa (absolute) to 200 kPa (gauge).

In 3.9.2.4 the criteria for the classification of environmentally hazardous substances have been aligned with those in paragraph 2.9.3 of the UN model regulations. However, these criteria apply only to the classification of goods shipped under UN 3077 or 3082 and not to substances that have another hazard characteristic. In order to avoid intermodal problems, use of the new environmentally hazardous substance label is allowed for goods shipped under UN numbers when they require it for land or sea transport.

Section 4 – Identification

The text in 4.1.3.2, which explains how to classify and assign mixtures and solutions, has been amended to clarify how to identify the best options where a mixture or solution contains only a very small quantity of one or more dangerous good in an otherwise pure substance. This is an air-only change and may result in modal disharmony for certain shipments. It derives from the dangerous incident involving a canister of ethyl chloride that exploded in Dubai in December 2007, fortunately after the flight had ended. The issue has been taken to the UN Sub-committee of experts and changes are possible in the model regulations in due course.

List of Dangerous Goods The format of Table 4.2 has been extended to accommodate the new ‘EQ’ codes and, to make room, columns C (Class or Division) and D (subsidiary risk) have been combined into a single column C. Any subsidiary risk is now shown in parentheses after the primary risk, as required by the shipper’s declaration.

There are various amendments to the List of Dangerous Goods, including but not limited to:

(a) the addition of UN 3475 for E85 and other ethanol/gasoline mixtures;

(b) new entries for fuel cell cartridges (UN 3476 to 3479);

(c) new entries for lithium ion batteries (UN 3480 and 3481) to differentiate them from lithium metal batteries, which retain the old UN numbers, UN 3090 and 3091;

(d) the extension of Special Provision A69 to cover other compressed gases, specifically argon, helium, neon, nitrogen and xenon;

(e) the revision of the packing group allocation for UN 1250 methyltrichlorosilane and UN 1305 vinyltrichlorosilane from PG I to PG II; and

(f) the revision of the entries for UN 2031 nitric acid, with new concentration cut-off points.

Special provisions Wherever an IATA special provision is directly equivalent to one in the UN model regulations, the UN special provision number will be shown in parentheses after the IATA special provision number. Where a special provision allows a shipment to be carried without restriction, this must now be mentioned on the airwaybill.

The special provisions relating to lithium batteries, until now found in A45, have been moved to six new packing instructions, PI 965 to 970.

A revision to A70 clarifies that if the fuel used in an internal combustion engine does not itself meet the classification criteria for any class or division, then the engine is not subject to the Regulations.

A revision to A112 expands the list of substances that may be assigned to ID 8000 and shipped as consumer commodities to include environmentally hazardous substances of UN 3077 and 3082.

Special provision A146 has been expanded to cover all fuel cell chemistries, not just those containing flammable liquids.

New special provisions A161 and A162 identify that fuel cell cartridges of UN 3478 and 3479, respectively, must meet defined design and test criteria.

A new special provision A163 against UN 3269 polyester resin kits and UN 3316 chemical and first aid kits identify that such articles may qualify for the excepted quantity provisions, and that this applies even if they contain organic peroxides that otherwise would not be able to take advantage of the excepted quantity relief.

A new special provision A164 has been assigned to all battery entries in Table 4.2 and specifies that all batteries must be protected against short-circuits and inadvertent activation.

A new special provision A224 lays down the requirements applicable to the transport of ceremonial flames, including the Olympic torch.

Section 5 – Packing

An amendment in 5.0.2.11 addresses situations in which one or more dangerous goods packed in the same outer packaging are restricted by gross weight rather than net quantity.

Reference to ISO 1114 in 5.2.0.2 has been qualified to highlight that the provisions of any applicable packing instructions take precedence.

Amendments have been made to several Packing Instructions.

200 Several Particular Packing Provisions have been revised to identify that certain materials cannot be used for cylinders and valves. A number of gas mixtures have been added to the list of substances that cannot be carried in aluminium cylinders without the approval of the appropriate national authority. A significant number of amendments have been made to the test pressures and filling ratios for gases in Table 200.B.

202 Cryogenic receptacles manufactured from glass are now permitted.

203/Y203 The provisions relating to plastics aerosols have been amended.

215/216/217 New Packing Instructions have been added to address the preparation of UN 3478 and 3479 fuel cell cartridges.

313 The existing Packing Instruction dealing with fuel cells containing flammable liquids has been deleted and replaced by new Packing Instructions 374, 375 and 376. These have been drawn up in the new format that will apply to all Packing Instructions as from January 1, 2011.

435 This has been deleted and replaced by a new Packing Instruction 499, aligned with the revised wording of P099 in the UN model regulations.

495/496/497 Three new Packing Instructions address the preparation of fuel cell cartridges containing water-reactive substances of UN 3476.

602 References to primary and secondary receptacles being “watertight” has been replaced by “leakproof” to align with terminology used in PI650.

699 A new Packing Instruction deals with water-reactive toxic substances of UN 3123 and 3125, Packing Group I, identical in wording to PI499.

873/874/875 Three new Packing Instructions address the preparation of fuel cell cartridges containing corrosive substances (UN 3477).

903/912/918 These three Packing Instructions have been deleted and replaced by PI 965 to PI 970 to cover lithium ion and lithium metal batteries. The quantity limits per package are more restrictive and different packaging requirements apply.

Section 6 – Packaging Specifications

A revision to 6.4.4 incorporates testing provisions for fuel cell cartridges containing flammable gas.

Section 6.5 has been completely rewritten to reflect changes in the UN model regulations

Section 7 – Marking and Labelling

A clarification has been added in 7.1.4.2 to highlight that the UN specification markings on packagings inside an overpack must not be reproduced on the outside of the overpack.

A new 7.1.6.3 identifies the marking requirements for packages containing UN 3077 or 3082 environmentally hazardous substances, including the new ‘dead fish and tree’ mark. Other dangerous goods with an environmentally hazardous sub-risk do not have to be so labelled, although if already labelled for land or sea transport the label does not have to be removed for air carriage.

The redesigned Cargo Aircraft Only label is specified in 7.2.4.2 (see Figure 1). The old label may continue to be used up to December 31, 2012.

The existing dangerous goods in excepted quantities label has been deleted from 7.4.8. A new 7.4.8 shows the handling label required for packaging containing lithium metal or lithium ion batteries (see Figure 2).

Section 8 – Documentation

The documentation provisions have been amended throughout to allow shippers to use electronic data transmission of information rather than a paper shipper’s declaration, provided the shipper has the agreement of the operator.

Paragraph 8.1.6.9.2(c) has been amended to identify that when Table 4.2 shows “no limit” or has a packing instruction reference, the quantity shown in the shippers’ declaration must be the net quantity (weight or volume) or, for articles, the gross weight.

Section 9 – Handling

The requirements for the acceptance of dangerous goods in 9.1 have been restructured and more specific items have been included in the acceptance checklist.

The provisions for Cargo Aircraft Only (CAO) dangerous goods in 9.3.4 have been significantly revised. It will no longer be necessary for every package bearing a CAO label to be visible when loaded and accessible to the flight crew; CAO dangerous goods that formerly had to be accessible will now be able to be loaded in Class C underfloor cargo compartments.

The loading and securing requirements in 9.3.5 have been amended to reinforce the message that packages containing dangerous goods must be protected by damage, including that caused by the movement of other goods loaded in the same compartment.

The Notice to Captain (NOTOC) requirements in 9.5.1.1 have been revised to allow for the gross weigh per package to be shown for consumer commodities shipped under ID 8000. For dry ice it will be sufficient to indicate the total quantity in each hold.

Following a revision to 9.5.3, notices displayed at airports to give information to passengers must include visual examples of dangerous goods forbidden in passenger baggage. This change takes effect on January 1, 2010.

A note has been added in 9.6.1 to clarify that goods shipped as ‘not restricted’ by virtue of compliance with a special provision are still subject to the reporting requirements if there is a leak, spill, fire or other incident involving the material.

Section 10 – Radioactive Material

The provisions relating to the transport of Class 7 radioactive materials by air have been completely restructured based on changes to the UN model regulations, themselves having been restructured in light of changes to the International Atomic Energy Agency’s (IAEA) Transport Standards. This has resulted in particular in a significant expansion of Subsection 10.3 to identify that the assignment of the proper shipping name is determined by the radionuclide A1 or A2 together with the type of package. The list of A1 and A2 values for common radionuclides will now be found in 10.3 rather than Table 10.4.B. Much of the text from 10.5 has been relocated to 10.3.

Appendices

Appendix B A new paragraph has been added to identify that all gas pressures in the DGR refer to gauge pressure.

Appendix C A number of new inorganic peroxides have been added to the list in Table C.2.

Appendix D The list of IATA member, associate member and other airlines has been deleted. Subsequent appendices have been renumbered.

Appendix D (new) The contact details for competent authorities have been updated.

Appendix E Changes have been made to E.1 and E.2.

Appendix F The lists of sales agents and IATA-accredited training schools have been updated.

Appendix H A new appendix contains the reformatted packing instructions that will come into effect on January 1, 2011 for Classes 3, 4, 5, 6.1, 8 and 9.

Appendix I Another new appendix provides a listing, arranged by UN number of the corresponding old and new packing instruction numbers.