In the IATA DGR, an often overlooked but vitally important section in chapter 2.8, are the State and Operator variations. State variations represent government variations and Operator variations represent the variations of the specific airlines. Variations in general are different from the regulations normally used to prepare DG air shipments, and they can affect the way a shipment is prepared. Failure to comply with these variations can and often does, result in rejected shipments. US variation USG-13 in particular is one that is often overlooked by shippers and consequently results in many a rejected shipments and frustrated shippers who, unfortunately, were previously unaware of it for a variety of reasons. IATA online training can help make sure you’re up to date with the regulations to avoid rejected shipments.
What Does USG-13 Apply To?
The main point addressed in USG-13 concerns the loading of DG onto an aircraft. For passenger aircraft, cargo is loaded in compartments that are not accessible to crew members during flight. Most of the cargo holds are located beneath the floor of the passenger cabin. Cargo aircrafts, on the other hand, can be configured to allow crewmembers access to the cargo in-flight in case something needs to be relocated.
Due to these accessibility factors, the amount of DG permitted on a passenger aircraft is considerably more restrictive than that of a cargo aircraft. As this is a United States variation, it applies to the transport of dangerous goods by air to, from, or through all territory of the United States. And this is true on all U.S. certified aircraft regardless of where they are operating in the world. The basis of it can be found in 49 CFR 175.5 and is commonly referred to as the 25/75 kg rule.
This rule limits the overall amount of dangerous goods permitted to be carried on passenger aircraft to a total of 25 kg net weight of dangerous goods, and an additional total of 75 kg net weight of Division 2.2 non-flammable gas loaded in any inaccessible cargo compartment on a passenger aircraft.
What Does USG-13 Not Apply To?
The 25/75 kg rule does not apply to
- Division 1.4S UN 0012, UN 0014, and UN 0055 prepared as Limited Quantity in accordance with 49 CFR §173.63(b). (This specific provision is irrelevant to IATA shipments. This is because LTD QTY provisions are forbidden for these UN numbers in the IATA DGR);
- Dangerous goods in Class 9;
- Articles of UN 3528 (Engine, internal combustion, flammable liquid powered 0r Engine, fuel cell, flammable liquid powered 0r Machinery, internal combustion, flammable liquid powered) or UN 3529 (Engine, internal combustion, flammable gas powered or Engine, fuel cell, flammable gas powered or Machinery, fuel cell, flammable gas powered);
- Dangerous goods in Limited Quantities or Excepted Quantities
- Aircraft batteries (belonging to the operator) carried as items of replacement
How Does USG-13 Affect Shippers?
So how can USG-13 affect a DG shipment prepared for passenger aircraft transport?
Let’s take a look at an example. A shipper prepares a package containing:
- 50 L of UN 1169 Extracts, flavoring liquid, Class 3, PG III
According to columns I & J of the Dangerous Goods List in the IATA DGR, up to 60 L are permitted per package utilizing Packing Instruction 355 on passenger aircraft. But, since the net weight of the material is in excess of 25 kg and class 3 is not among the exceptions permitted under the variation, it would not be permitted in an inaccessible cargo hold of a passenger aircraft and it needs to be placed in a cargo aircraft for transport.
“ Well… then why does the IATA DGR even permit it to be shipped via passenger aircraft in the first place?”. The simplest answer we can give them is that the IATA DGR is international in scope and USG-13 addresses a US requirement. 49 CFR is the law of the land for shipping DG by most modes of transport in the US. Therefore, there are instances where the US regulations are more stringent than those found in the international regulations. Such is the case here.
IATA Online Training
So in conclusion, if you are a US shipper, you need to be aware of USG-13 and the 25/75 kg rule and how it may affect the way you prepare your passenger aircraft shipments. If you are a freight forwarder, USG-13 would need to be taken into account when booking your cargo. Contact us today to learn more about how our online training courses can help you and your organization be competent, be confident, and be compliant.