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Q&A: Can a limited quantity of a hazardous material be transported by air in a non-specification packaging?

Q&A: Can a limited quantity of a hazardous material be transported by air in a non-specification packaging?

A follow-up question from one of my recent Onsite Training customers (11.18.16):

Hello Daniel,

Can you please confirm that a Limited Quantity Air Shipment can go in a non-specification package?

Thank you,

My reply that same day:

Correct.

The IATA regulations at 2.7.1.1 for a limited quantity includes the following:

It is recognized that many dangerous goods can be safely carried in good quality combination packagings which meet the construction requirements of Subsections 6.1 & 6.2 but which have not been marked and tested in accordance with the requirements of 6.0.4.

6.1 = Requirements for inner packagings
6.2 = Specifications for UN Outer Single and Composite Packagings.
6.0.4 = Markings of UN Specification Packagings.
In other words, the packaging must be able to meet the construction requirements of specification packaging but do not have to be tested and marked as such.
Package performance tests for limited quantity packaging by air are documented in 2.7.6 which include a drop test and a stacking test.
I hope this helps.
Please don’t hesitate to contact me with any other questions.

The transportation of a hazardous material (aka: dangerous good) by air – even within the U.S. – will likely be subject to the regulations of the International Air Transport Association (IATA).  These regulations are authorized for use within the U.S. by PHMSA/USDOT (at least, the technical instructions of the International Civil Aviation Administration are authorized for use by PHMSA/USDOT and since the IATA Dangerous Goods Regulations are very similar to the ICAO technical instructions and are even a little bit more strict, compliance with IATA results in compliance with ICAO and PHMSA/USDOT.  Got it?) and are adhered to by most of the world’s airlines.

Questions like this arise because, while similar in many ways – the regulations of IATA and PHMSA/USDOT differ in several key areas.

Daniels Training Services, Inc.

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Contact me if you have questions about how to ship HazMat by air, highway, rail, or vessel.