AIRPORT VOICE, MARCH 2020 15
Dangerous Goods
Understanding Special Provisions on
the Shipper’s Declaration
BY BUREAU OF DANGEROUS GOODS
Understanding the IATA
DGR requirements
When it comes to compliance with
dangerous goods regulations, a debt of
gratitude is owed to the International
Air Transport Association (IATA) for
presenting the ICAO Technical Instructions
for the Safe Transport of
Dangerous Goods By Air (ICAO TI)
in a user-friendly format as contained
the IATA Dangerous Goods Regulations
(IATA DGR), the current publication
being the 61st Edition (2020).
The IATA DGR is used throughout the
world to ensure that dangerous goods
transported by air are prepared and
transported safely and in compliance
with the ICAO instructions and associated
airline industry policies.
As the trade association of the
global airline industry, IATA works
with their airline partners to formulate
agreed-upon industry policy and
standards, including those that affect
the transportation of dangerous
goods. In some instances, countries,
operators or the airline industry as
represented by IATA have established
policies or standards regarding dangerous
goods transportation which
are more stringent than the ICAO TI.
‘Differences’ which are published by
countries (States) or airlines (Operators)
are included in the DGR as State
and Operator Variations; whereas additional
requirements agreed upon by
the entire IATA membership are indicated
in the DGR with a distinctive
pointing-finger symbol.
One requirement of the DGR that
is identified with a pointing finger is
that of IATA DGR 8.1.6.9.4(a), which
specifies sixteen Special Provisions
(A1, A2, A4, A5, A51, A81, A88, A99,
A130, A190, A191, A201, A202, A211,
A212, A331) that must be shown in the
Authorizations column of the Shipper’s
Declaration form as applicable.
The words “as applicable” in this
reference are often misinterpreted in
ways that have the potential to frustrate
the acceptance of a dangerous
goods shipment, so we at Hazmat University
would like to attempt to clear
up the matter. “As applicable” in this
context does not mean “whenever
shown against an entry in the Dangerous
Goods List”; rather it should
be read to mean “as applied by the
shipper”.
An explanation of Special
Provision A1
For example, Special Provision
A1 of the DGR, when shown in Column
M of the Dangerous Goods List
against an entry that is forbidden for
transport on passenger aircraft but
permitted on cargo-only aircraft, contains
provisions for that substance or
article to be transported on passenger
aircraft, provided that the shipper
has obtained the necessary prior
approval(s) from government authorities
as specified in that special provision.
It also states that the article or
substance may be carried on cargo
aircraft in accordance with Columns
K and L of the List of Dangerous
Goods.
In this instance, if the shipment
is prepared for Cargo Aircraft Only
transportation, Special Provision A1
is not applicable. If it is the shipper’s
wish or need to offer the shipment
for transportation by passenger
aircraft, that transportation is subject
to approval by the applicable authorities.
If the shipper is successful
in obtaining the required approval(s),
the shipment may be offered for transportation
on passenger aircraft in accordance
with the provisions of Special
Provision A1, which further
requires that a copy of the document
of approval showing quantity limitations
and packing requirements must
accompany the consignment. In an
instance such as this, Special Provision
A1 is applicable, and must be
shown in the Authorizations column,
along with a statement indicating that
a copy of the approval document(s) is
attached to the Shipper’s Declaration,
as required by 8.1.6.9.4(b). (Note that
IATA DGR 1.2.5.2 reminds that acceptance
of dangerous goods offered for
shipment under the provisions of an
approval is at the discretion of the
operator concerned, and encourages
shippers to make advance arrangements
with the operator(s) as part of
the transport planning process associated
with any approval application.)
Another example of when
a Special Provision is or
is not applicable
Another example of a special provision
that must be shown when applicable
is Special Provision A51, which
permits packages containing aircraft
batteries (UN 2794 or UN 2795 only) to
exceed the 30 kg limitation shown in
Column J of the Dangerous Goods for
transport by passenger aircraft, permitting
packages of up to 100 kg net
quantity to be transported. As aircraft
batteries are characteristically
heavy, this special provision supports
airline operations in facilitating
movement of aircraft batteries to
where they may be needed.
In looking at the List of Dangerous
Goods, the entries for UN 2794
and UN 2795 indicate a per-package
limit of “No Limit” when transported
on cargo-only aircraft in accordance
with Column L. Therefore, in order
for Special Provision to be applicable
and required to be shown in the Authorizations
column:
• The batteries identified as UN
2794 or UN 2795 are aircraft batteries;
• The batteries are being offered
for transportation on passenger aircraft;
• The net quantity contained in
each package(s) exceeds 30 kg.
If the batteries are being offered
for transport by cargo-only aircraft,
A51 is not applicable, as Column L
does not limit the per-package net
quantity. Likewise if the batteries are
being offered for transportation by
passenger aircraft and the net quantity
per package does not exceed 30 kg,
A51 is again not applicable.
A helpful suggestion
regarding Special
Provisions
There is a note provided by IATA
to 8.1.6.9.4(a), which states “Other
special provisions that have been applied
by the shipper may be included
in the authorizations column.” It
means just that – “that have been
applied” – it doesn’t mean that special
provisions that are shown in
Column M but are not applied are to
be included. Some shippers employ
the unfortunate practice of including
every special provision shown in
Column M, whether it is relevant or
has been applied or not, perhaps with
the notion that “more is better”. In
this instance, it is not. Your operator’s
acceptance staff is rigorously
trained in the IATA requirements
and they know what they are looking
for. Showing a special provision that
is not applicable may cause them to
question the accuracy of your information,
and could result in delay or
rejection.
Be confident, competent
and compliant!
Nothing is more valuable than
thorough and efficient training when
it comes to navigating and implementing
the dangerous goods regulations.
Hazmat University offers
online training choices that will provide
you with a better understanding
of not only the regulatory language,
but also the regulatory intent. Our
online courses are designed to make
you confident, competent and compliant
when shipping your dangerous
goods by ground, air or sea. Visit
our website at HazmatUniversity.
com and browse our offerings; we’re
sure you’ll find a course to meet your
needs!
IATA & IPC cooperation
Seek safe, secure deliveries
The International Air Transport
Association (IATA) and the International
Post Corporation (IPC) have
today signed a Memorandum of Understanding
(MoU) to reinforce cooperation
between the two organizations.
The aim for both IATA and IPC
is to promote the development and
expansion of safe, secure, accessible
and high-quality airmail and air
cargo services to help their respective
members provide quality solutions
aligned to consumer needs.
“International e-commerce is
growing at around 20% per year,
leading to rapidly changing market
conditions for airlines and
posts. Ensuring customers get
their packages on time while
safety and security in postal air
transport is maintained is the
main priority for posts and air
transport operators alike. Cooperation
across the supply chain is a
must and our MoU with IPC is an
important step toward strengthening
our activity in this area,”
said IATA’s Director General and
CEO, Alexandre de Juniac. “With
this agreement, we want to further
strengthen our ties and identify
further opportunities for cooperation
and joint developments.
Both of our sectors can win from
a reinforced cooperation in terms
of competitiveness and quality of
service. Ultimately, this agreement
will benefit consumers
through more reliable and faster
delivery of cross-border mail and
packets transported by air,” said
Holger Winklbauer, CEO of IPC.
IATA and IPC intend to work together
on seven specific areas:
1. Improving the security, handover,
carriage, delivery and settlement
of airmail between postal
operators and air carriers. This includes
e-commerce, economic and
commercial matters.
2. Developing and maintaining
industry standards and procedures
as well as services and solutions for
both physical flows and electronic
data interchange relating to airmail.
3. Aligning existing services
and solutions, along with developing
new ones to ensure harmonized
compatibility and efficient application
of resources.
4. Finding technology-based
standards and solutions for piece
level tracking in airmail.
5. Addressing volumetric challenges,
through initiatives such as
Air Packet Box, and allocation and
booking procedures for airmail.
6. Developing regional onboarding
initiatives and global campaigns
on airmail process optimization
and standardization.
7. Improving the involvement of
ground handlers and other industry
stakeholders on matters concerning
airmail.