The Dangerous Goods Regulations (DGR) of the International Air Transport Association (IATA) at 5.0.2.11 allow for the transportation of different dangerous goods in a single outer packaging (aka: all packed in one). A particular challenge when packing different dangerous goods in a single outer packaging is to comply with the dangerous good’s per package quantity limits found in the following columns of the List of Dangerous Goods at 4.2:

• Column H for limited quantity
• Column J for passenger and cargo aircraft
• Column L for cargo aircraft only

In order to ensure the per package quantity limits are not exceeded IATA requires the shipper/packer of the dangerous good to calculate its “Q” value. The purpose of this article is to explain how to calculate the “Q” value of a package containing different dangerous goods to ensure compliance with the per package quantity limits of the IATA Dangerous Goods Regulations.

Before we begin…

• The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) also allow for the transportation by air of an outer packaging of different hazardous materials (HazMat). The method used by USDOT/PHMSA to ensure the package is within the quantity limits differs from that of IATA. In my experience most persons that offer HazMat / dangerous goods for transport by air comply with the DGR of IATA and not the HMR of USDOT/PHMSA. Therefore, this article will address only the IATA DGR.
• USDOT/PHMSA does not authorize for use in the U.S. the DGR of IATA. Instead, the HMR authorizes the Technical Instructions of the International Civil Aviation Organization (ICAO). However, the IATA DGR are based on the ICAO Technical Instructions and where different are even more stringent. In short: compliance with the IATA DGR will ensure compliance with the ICAO Technical Instructions which will ensure compliance with the HMR of USDOT/PHMSA for transportation to, from, or through the U.S. by aircraft.

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Scope and Applicability:

• This article will only address the DGR of IATA. As noted above, USDOT/PHMSA has its own method for determining if an outer packaging complies with its per package quantity limits.
• The Technical Instructions of ICAO will not be addressed in this article but – again, as noted above – compliance with the IATA DGR ensures compliance with the ICAO Technical Instructions.
• This article will only address the regulations applicable to transportation of a fully-regulated dangerous good by passenger and cargo aircraft (PAX) or cargo aircraft only (CAO). It will not address the calculation of “Q” value for a limited quantity.
• The requirements for calculation of the “Q” value of a limited quantity of a dangerous good are similar – but not exactly the same – as for fully-regulated dangerous goods. Refer to 2.7.5.6(e) of the DGR for calculating the “Q” value of a limited quantity.
• 5.0.2.11 of the IATA DGR contains many other requirements besides determination of the “Q” value when packing different dangerous goods in a single outer packaging. Identification and explanation of the remaining requirements of 5.0.2.11 will have to wait for a later article. They will not be addressed here.

Per package quantity limits?

One of the challenges of transportation of dangerous goods by air are the limits on the quantity of dangerous good permitted in each completed package (aka: outer packaging).

• The maximum net quantity of dangerous good per package (outer packaging) are found in the List of Dangerous Goods:
  • Column J for Passenger and Cargo Aircraft (PAX)
  • Column L for Cargo Aircraft Only (CAO)
• The maximum net quantity of dangerous good per package are indicated as:
  • “L” for liters if a liquid.
  • “kg” for kilograms if solid.
• The value indicated is a net quantity (dangerous good only) and not a gross quantity (dangerous good and packaging).
• The maximum net quantity per package will differ based on the Packing Group of the dangerous good. As the degree of danger expressed by the Packing Group increases (PG I = high danger, PG II = medium danger, PG III = low danger) the quantity of dangerous good permitted per package decreases.
• The maximum net quantity of dangerous good permitted per package will also differ depending on its transportation by passenger and cargo aircraft (PAX) or cargo aircraft only (CAO). The maximum net quantity allowed per package for PAX in column J will almost always be less than, will sometimes be the same, and will never be more the maximum net quantity allowed per package for CAO in column L.
• The maximum net quantity specified in columns J or L may be further limited by the type of packaging used. See Section 5 (the yellow pages) of the DGR.
• If column J or L display a packing instruction number instead of a maximum net quantity per package, refer to the packing instructions in Section 5 for the maximum net quantity per package.
• The permitted maximum net quantity of dangerous good per package displayed in columns J and L may be revised by a special provision code in column M.

Calculating the “Q” Value:

An outer packaging may contain different dangerous goods provided the completed package complies with all of the conditions of 5.0.2.11. This includes 5.0.2.11(g): the calculated “Q” value of the outer packaging may not exceed a value of 1. The “Q” value is calculated using the following formula:

In the above formula:

• n1, n2, n3, etc. are the actual net quantity of dangerous good in each inner packaging.
• M1, M2, M3, etc. are the maximum net quantities of dangerous goods permitted per package in columns J or L of the List of Dangerous Goods.

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Notes on calculating “Q” Value:

• The calculated “Q” value must be rounded up to the first decimal place. Therefore, a calculated value of 0.83 is rounded up to 0.9; a calculated value of 1.03 is rounded up to 1.1.
• The value for “M” is always the value shown in columns J or L of the List of Dangerous Goods regardless if the maximum net quantity of dangerous goods per package is revised by a special provision or limited by the type of packaging. It is always the value in column J – for PAX – or L – for CAO – that is used for the value for “M”. 

Don’t Count These:

The following dangerous goods do not need to be taken into account in the calculation of the “Q” value:

• Carbon dioxide, solid (dry ice) UN 1845.
• Those where columns J or L of the List of Dangerous Goods indicate “No limit”.
• Those with the same UN number packing group, physical state (i.e., solid or liquid) and the same maximum net quantity in columns J or L of the List of Dangerous Goods, provided they are the only dangerous goods in the package and the total net quantity does not exceed the maximum net quantity shown in the List of Dangerous Goods.

Example 1:

The following inner packagings all packed in one outer packaging to be transported by passenger and cargo aircraft (PAX):

• 1 L of UN 1133, Adhesives, 3, PG II (Max Net Qty/Pkg in column J = 5 L)
• 0.5 L of UN 1263, Paint 3, PG I (Max Net Qty/Pkg in column J = 1 L)
• 20 L of UN 1866, Resin solution, 3, PG III (Max Net Qty/Pkg in column J = 60 L)

1/5 + 0.5/1 + 20/60 = 1.03

Rounded up to first decimal place = 1.1. The above inner packagings may not be packed in one outer packaging.

Q: Wait. 1.03 rounds up to 1.1? Wouldn’t it round down to 1.0?

A: No. The “Q” value formula was developed as a way of being able to determine that the limits shown in columns J and L of the List of Dangerous Goods are not exceeded. A calculated value of 1.000001 (assuming that was possible) is greater than 1.0. It would be rounded up to 1.1 and therefore exceed the “Q” value of 1.0.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Example 2:

The following inner packagings all packed in one outer packaging to be transported by cargo aircraft only (CAO):

• 10 L of UN 1133, Adhesives, 3, PG II (Max Net Qty/Pkg in column J = 60 L)
• 20 L of UN 1263, Paint 3, PG I (Max Net Qty/Pkg in column J = 30 L)
• 20 L of UN 1866, Resin solution, 3, PG III (Max Net Qty/Pkg in column J = 220 L)

10/60 + 20/30 + 20/220 = 0.924

Rounded up to first decimal place = 1.0. Since the Q value does not exceed 1.0, the above inner packagings may be packed in one outer packaging.

Example 3 (a second shot at Example 1):

The following inner packagings all packed in one outer packaging to be transported by passenger and cargo aircraft (PAX):

• 1 L of UN 1133, Adhesives, 3, PG II (Max Net Qty/Pkg in column J = 5 L)
• 0.5 L of UN 1263, Paint 3, PG I (Max Net Qty/Pkg in column J = 1 L)
• 10 L of UN 1866, Resin solution, 3, PG III (Max Net Qty/Pkg in column J = 60 L)

1/5 + 0.5/1 + 10/60 = 0.866

Rounded up to first decimal place = 0.9. The above inner packagings may be packed in one outer packaging. (The remaining 10 L of UN 1866, Resin solution may be packed separately and then placed with the “all packed in one” in an overpack).

Hazard Communication:

If compliance is confirmed with all of 5.0.2.11 – including the “Q” value, the dangerous goods may be combined in the same package. This will have an impact on the hazard communication required for the consignment:

• The package must display all the required marks for each dangerous good in the package (7.1.4.6).
• The package must display the required labels for each dangerous good in the outer packaging. However, only one label is required for each class or division in the package (7.2.3.12). In the examples above the packages would display only one Class 3 Flammable Liquid label since each of the dangerous goods is a Class 3 Flammable Liquid.
• On the Shipper’s Declaration for Dangerous Goods:
  • First Sequence – Identification
    • Each dangerous good in the completed package must be described separately on the Shipper’s Declaration as required by 5.1.6.9.1.
  • Second Sequence – Number and Type of Packagings, Quantity of Dangerous Goods (an example is below):
    • The words “All Packed in One” followed by the required description of the package type [8.1.6.9.2(f)].
    • The calculated “Q” value rounded up to the first decimal place [8.1.6.9.2(g)]. However, the “Q” value does not need to be shown on the Shipper’s Declaration for the following:
      • Carbon dioxide, solid (dry ice)
      • Dangerous goods with “No Limit” in columns J or L.
      • Dangerous goods with the same UN Number, packing group, and physical state.

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Conclusion:

The calculation of the “Q” value is unique to the IATA DGR and one of the challenges of the transportation of dangerous goods by air. Of course, good training will not only meet the requirements of 1.5 for shippers and packers of dangerous goods by air but will also instruct you on what you need to know to package and ship your dangerous goods by air.