Many of us know that if we are shipping dangerous goods in the air mode, more often than not, we must create a Shipper’s Declaration for Dangerous Goods (DGD). The form is needed to identify and describe a shipment of dangerous goods for air transport in accordance with the IATA/ICAO Dangerous Goods Regulations. Participating in an IATA DGR training which includes how to complete a DGD explains the requirements for entering the quantity on the DGD. However, those of us that have created a DGD also know there are many ways to earn a rejection because of information that was incorrectly entered on the DGD, doesn’t match what is on our packages, or is entered in the wrong place or inconsistent with the DGR.
One of the areas of the DGD that can be most confusing is the Quantity and Type of Packaging information. It seems straightforward, right? Just add the number of packages and what type of packaging was used to put together the shipment. What is so hard about that?
The difficulty often comes in entering the quantity (net or gross) of material on the DGD. It seems straightforward enough. We just enter the amount of material in each inner packaging, or article, right? What happens when we are shipping batteries? What about a car? The task of adding a quantity to the DGD can get confusing quickly.
What is the Shipper’s Declaration for Dangerous Goods?
Before we get too deep into what weight to enter where and when, let’s look at the requirements for documentation in the IATA DGR. Section 8 of the DGR is where the requirements for creating a Dangerous Goods Declaration (DGD) are found. This section includes everything from the mandated design of the form, the information required to be on the form, and several examples for preparing a DGD.
Subsection 8.1.6 “Detailed Instructions for Completing the Declaration Form” is where you’ll find specific information about each section of the form and the information that should be in it. The middle section of the form, below, is where the description of the goods is entered. This information is entered in four sequences outlined in the IATA DGR Sub-section 220.127.116.11.1 – 18.104.22.168.4.
The first sequences outline the basic description or identification of the dangerous goods. The third and fourth sequences are for packing instructions and authorizations. It is in the second sequence “Quantity and Type of Packaging and Quantity of Dangerous Goods” where we will spend the rest of this blog.
Entering the Net Quantity
Sub-section 22.214.171.124.2 requires the number of packages and the net quantity of each item of dangerous goods bearing a different proper shipping name, UN/ID number, or packing group to be entered on the declaration. Known as step 6 in the sequence for preparing the DGD, there are several ways the net quantity can be entered on the form.
What is “net quantity”? Net quantity is defined in Appendix A of the DGR as:
- The weight or volume of the dangerous goods contained in a package excluding the weight or volume of any packaging material
- The weight of an unpackaged article of dangerous goods (e.g. UN3166)
For example, a shipment of 5 – 4G fibreboard boxes of UN1090 Acetone with 4 L of dangerous goods in each package is ready for paperwork. Each package weighs 6 kg. We enter the information on the DGD as shown below.
This example is an illustration of a common shipment made every day. But what happens when the net quantity is a little harder to determine. What is the net quantity for a lead-acid battery? Lithium Batteries? Airbag inflators? Chemical kits? The entry says “No Limit” in column J or L of the Dangerous Goods List.
Let’s find out.
What is an article? That’s a good question. Unfortunately, there is no definition in the regulations for an article. The term “article” has come to be accepted as an object or device that may contain dangerous goods. Examples of articles commonly include batteries and fire extinguishers.
When entering the net quantity of dangerous goods for batteries on the DGD, the weight of the batteries in the package is declared.
Below is an example of a shipment of 3 fibreboard boxes x 10 kg each containing batteries wet non-spillable.
Lithium batteries are treated similarly to non-spillable batteries in that the weight of the battery becomes the net quantity of material in the package. For example, 1 lithium metal battery that weighs 5 kg in a fiberboard box.
The scenario is only slightly more complicated when the batteries are contained in or packed with equipment. The requirement is to show the net quantity of lithium batteries in the package. The weight of the equipment is irrelevant.
The example below is for a lawnmower that contains a fully regulated lithium-ion battery. The piece of equipment weighs 130 kg. The battery weighs 15 kg.
Engines, Vehicles, and “No Limit”
There are several entries for engines, vehicles, and dangerous goods in apparatus. In these cases, the maximum net quantity per package in columns J and L is listed as “No Limit.” No limit simply means there is no maximum net quantity limitation on a packaging. For these entries, the weight of the engine, vehicle, or apparatus is entered onto the DGD. See examples below.
Consumer Commodities and Gross Weight
Some entries in the Dangerous Goods list show the maximum net quantity per package in columns J and L with a “G” after the quantity. The “G” indicates that the gross weight of the completed package must be shown on the DGD.
Gross weight is defined in Appendix A as “the total weight of the package as presented for transport.”
Consumer commodity, ID8000 has a maximum net quantity per package of 30 kg G in columns J and L of the Dangerous Goods List. This means when a DGD is created, we must enter the gross weight of each package as prepared for transport.
For example, perfumes are being packed for shipment. The 0.1 L bottles of perfume are put in a box that weighs 11 kg when completed. The example DGD is shown below.
Chemical and First Aid Kits
The next group of materials is a bit tricky. Chemical and first aid kits are packages that contain small amounts of more than one dangerous good that are used for medical, analytical, or testing purposes. The net quantity listed on the DGD for UN3316, Chemical or First Aid Kits is always shown in kg. If the materials within the kit are liquid, 126.96.36.199.2(e) instructs us to convert liters to kg (1L = 1 kg)
For example, we have a testing kit that contains 0.2 L of one reagent and 0.5 L of solvent. In this case, 0.2 L + 0.5 L = 0.7 L. Using the instructions from 188.8.131.52.2(e), 0.7 kg is entered on the DGD.
As you can see, entering a weight on the DGD is not always a clear proposition. It is important to read Section 8 of the IATA Dangerous Goods Regulations, as well as all appropriate special provisions and packing instructions that apply.
In order to complete a Shipper’s Declaration for Dangerous Goods in accordance to IATA/ICAO requirements IATA DGR training is required to meet Federal and International requirements.
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In order to complete and sign a Shipper’s Declaration for Dangerous Goods in accordance to IATA/ICAO requirements IATA DGR training is required to meet Federal and International requirements.
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