December 2016

IATA Proposes New Changes

The International Air Transport Association (IATA) has incorporated a number of changes into its 58th Edition of the Dangerous Goods Regulations (IATA DGR). This edition will become effective on Jan. 1, 2017. There is also a two-year transition period, until Dec. 31, 2018, for the new lithium battery mark. Following are synopses of the significant changes and amendments to the 58th Edition, grouped by topic:

1 – Applicability

Section 1.4 – Operator Responsibilities. The requirements of Section 1.4.3 have been completely revised to allow for operators to develop a performance-based notification system to advise passengers that reflect the operator’s own capabilities and operations. The details of this notification system must be documented in the operator’s operations or other applicable manual.

Section 1.6 – Adequate Instruction. A new paragraph has been added that outlines the requirements for shippers of Section II lithium batteries to meet the conditions for “adequate instruction” of employees who are responsible for the preparation of packages of lithium batteries offered for air transport.

2 – Limitations

Section 2.6 – Dangerous Goods in Excepted Quantities. The packing provisions have been revised to allow for the absorbent material to be either in the intermediate packaging or the outer packaging for liquid dangerous goods.

Section 2.8 – Operator Variations. There are a number of additions, deletions and amendments to variations submitted by operators.

3 – Classification

Section 3.0.1.5 – A new paragraph has been added to set out the provisions for where a shipper identifies, by testing, that a listed substance has a subsidiary hazard not identified in the list of dangerous goods. The new provision identifies that the shipper must, with the approval of the appropriate national authority, either use a “n.o.s.” (not otherwise specified) entry or ship the substance under the listed entry with the addition of the subsidiary hazard.

Sections 3.2.6, 3.3.6, 3.6.1.9 and 3.8.4 – New provisions have been added to address substances in Class 2, Class 3, Division 6.1 and Class 8, respectively, that may polymerize during normal conditions of transport.

Section 3.4.1.4 – Provisions have been added for the classification of polymerizing substances. The provisions are analogous to those for self-reactive substances.

4 – Identification

4.2 – List of Dangerous Goods. Amendments to the List of Dangerous Goods include:

  • revision to a number of the entries for aerosols to consolidate all aerosols into packing instructions 203 and Y203;
  • addition of special provision A209 against entries with “stabilized” in the proper shipping name;
  • all entries of “engines” have been deleted from UN 3166. UN 3166 in Class 9 now only applies to the proper shipping names “vehicles.” Engines are now assigned to UN 3528 – UN 3530 in Division 2.1, Class 3 or Class 9, based on the classification of the fuel that powers the engine. Also assigned to UN 3528 – UN 3530 are proper shipping names for “machines,” which are also based on the classification of the fuel used to power the machines;
  • UN 3480, Lithium ion batteries has been amended to show “forbidden” across columns I/J to identify that these batteries are now restricted to Cargo Aircraft Only. This change became effective April 1, 2016 through an addendum to the 57th edition of the DGR. There is no change to the entries for UN 3481, lithium ion batteries packed with equipment or lithium ion batteries contained in equipment;
  • all entries for lithium batteries, UN 3090, UN 3091, UN 3480 and UN 3481 have been revised to identify that the hazard label has changed to now be the lithium battery Class 9 label. A new Special Provision A206 has also been assigned to reinforce this new requirement; and,
  • four new entries, UN 3531–UN 3534 have been added for polymerizing substances.

4.4 – Special Provisions. Special Provisions that have changed include:

  • A21 and A134 – Have been revised to address the changes to UN 3166 and the new entries for engines and machinery;
  • A88 – Which applies to prototype or small production run lithium cells and batteries has been revised to now refer to PI 910 in the Supplement to the ICAO Technical Instructions;
  • A104 – Which was assigned to UN 1230, Methanol, and which allowed packages containing methanol to not bear a Toxic hazard label, been deleted. All packages containing methanol must now bear a Division 6.1 hazard label in addition to the Class 3 label;
  • A112 – Has been revised to identify that ID 8000, Consumer commodity can now also include aviation regulated substances, UN 3334 and UN 3335; and
  • A181 – Has been revised to more clearly describe the requirements for packages that contain both lithium batteries packed with equipment and lithium batteries contained in equipment.
  • A331 – Is a new special provision assigned against UN 3480, Lithium ion batteries to identify the possible requirements for a shipper to meet to obtain an approval to ship lithium ion batteries at a state of charge in excess of 30% of the rated capacity of the battery.

5 – Packing

Section 5.0.1.3 – Dangerous goods in unit load devices and freight containers. The provisions have been revised to allow for unit load devices (ULD) that contain UN 3373 or ID 8000 to also contain dry ice as a refrigerant.

Section 5.0.1.12 – New provisions have been added to allow, with the approval of the authorities of the States of origin and of the operator, for the use of UN specification large packagings for articles that weigh in excess of 400 kg.

Several Packing Instructions including the following have been updated:

  • PI 200 – Has been revised to include new provisions for liquefied gases charged with a compressed gas to require the shipper to take both components into account when calculating the internal pressure in the cylinder. There are also additional provisions to require that shippers when charging cylinders must use qualified staff;
  • PI 203 and PI Y203 – These packing instructions have been revised to incorporate the provisions in PI 204;
  • PI Y204 and PI 212. These packing instructions have now been deleted;
  • PI 220 – Is a new packing instruction added for engines and machinery powered by a flammable gas;
  • PI 378 – Is a new packing instruction added for engines and machinery powered by a flammable liquid;
  • PI 459 – Has been revised to include polymerizing substances (UN 3531 and UN 3532) with self-reactive substances;
  • PI 965 – PI 970 – Section IB of PI 965 and PI 968 and Section II of all of the lithium battery packing instructions have been revised to remove reference to the need for an additional document to accompany consignments of Section II lithium batteries. As of Jan. 1, 2017, this document is no longer required. The lithium battery handling label, which is required on packages, has been replaced by a new lithium battery mark. The dimensions and color of the new lithium battery mark are the same as for the lithium battery handling label, but all words have been removed and the UN number(s) is required to be applied. There is a two-year transition period until Dec. 31, 2018 to allow shippers to implement the lithium battery mark; and
  • PI 972 – Is a new packing instruction added for engines and machinery powered by a fuel classified only as environmentally hazardous.

6 – Packaging Specifications and Performance Tests

Section 6.4.2 – This subsection has been revised to bring in reference to new International Organization for Standardization (ISO) standards and also to identify the period during which the ISO standards may be applied for manufacture and also after which time the standards may no longer be used.

7 – Marking & Labeling

There are numerous editorial amendments to change the word “marking” or “markings” to read “mark” or “marks”. This reflects the correct English usage where what is applied to a package is a “mark”, whereas “marking” is the act of applying the mark. However, the greatest number of these editorial changes is in Section 7.

Section 7.1.5.5 – Are the new provisions that set out the requirements for the lithium battery mark. The specification of the lithium battery mark is shown as Figure 7.1.C in the IATA DGR 58th Edition. The new mark comes into effect as of Jan. 1, 2017 with a two-year transition period during which time either the lithium battery mark or the lithium battery handling label may be applied to packages containing lithium batteries prepared in accordance with Section IB or Section II of the lithium battery packing instructions.

Section 7.2.4.4 – The provisions on additional text on hazard labels have been revised to identify that for the new Class 9–Lithium Battery hazard label the only information permitted in the bottom half of the label is the pictogram and the class number.

Section 7.3.18 – The specification of the new Class 9–Lithium Battery hazard label has been added as a new Figure 7.3.X. The new hazard label comes into effect as of Jan. 1, 2017 with a two-year transitional period during which time either the existing Class 9–Miscellaneous Dangerous Goods hazard label or the new Class 9–Lithium Battery hazard label may be applied to packages containing lithium batteries prepared in accordance with Section I, IA or IB of the lithium battery packing instructions.

8 – Documentation

Section 8.1.6.9.1 – A note has been added to identify that notwithstanding the change to the UN numbers and division/class for “engines,” shippers may still consign engines as UN 3166 in Class 9 until March 31, 2017.

Section 8.1.6.9.2 – Clarification has been added on how the identification number for multiple overpacks should be shown.

Section 8.1.6.9.4, Step 9 – The list of special provision numbers that are required to be shown in the “authorizations” area of the Shipper’s Declaration has been revised.

Section 8.1.6.11.7 – The paragraph identifying that for shipments of lithium batteries prepared under Section IB of PI 965 and PI 968 that the information required on the additional document may be included on the Shipper’s Declaration or may be on an additional document has been deleted as the additional document is no longer required.

Sections 8.1.6.13 and 8.1.6.14 – Have each been revised to remove the mandatory requirement for title of the signatory and the place that the Shipper’s Declaration was signed. This information may still be provided, but is no longer mandatory.

9 – Handling

Notes have been added under 9.0 to reference Annex 19–Safety Management Systems and the ICAO Safety Management Manual. All operators are required to implement a Safety Management System (SMS) and the carriage of dangerous goods is included within the scope of the operator’s SMS.

Section 9.1.3.2 – A new paragraph has been added to require that the operator must be able to identify the person who performed the acceptance check.

Section 9.1.4.1 – The provisions for acceptance of a shipper loaded unit load device (ULD) containing dry ice have been revised to also allow UN 3373 or ID 8000 to be in the ULD with dry ice. 9.1.9 – A new paragraph has been added recommending that operators conduct a safety risk assessment for the transport of dangerous goods.

Section 9.5.1.1.3 – The information required on the written information to the pilot-in-command (NOTOC) has been revised to clarify that for ID 8000 the gross weight of each package may be the average gross weight when this is what has been declared on the Shipper’s Declaration.

Section 9.8.2 – The acceptance checklist retained on file must now include identification of the person who performed the acceptance check.

For questions regarding the new IATA Dangerous Goods Regulations, contact [email protected] or +1 (310) 370-3600, or contact IATA’s Dangerous Goods Section at [email protected]