The Quick Answer:

Adequate instruction is an alternative to full regulatory training for persons who prepare certain lithium cells or batteries for transport by aircraft. The requirement to provide adequate instruction is found in the applicable packing instructions of the IATA Dangerous Goods Regulations.

Summary:

Section II of the lithium battery packing instructions, PI 966, PI 967, PI 969, and PI 970, include a requirement that “Any person preparing or offering cells or batteries for transport must receive adequate instruction on these requirements commensurate with the functions for which they are responsible”. The packing instructions however do not define or describe what is considered as “adequate instruction”.

At 1.6.2 the IATA Dangerous Goods Regulations identifies what – at a minimum – an employer should consider as “adequate instruction”.

A Little Background:

• The Dangerous Goods Regulations of the International Air Transport Association (IATA) are the standard used by the world’s commercial airlines for the transportation in commerce of dangerous goods by air.
• Unless excepted, any person who prepares a dangerous good for transport by air must receive initial and biennial dangerous goods training.
• Lithium cells and batteries of all types, sizes, and packing arrangements are subject to some regulation by IATA as a dangerous good.
• Lithium cells and batteries with higher lithium content are classified as Section I or IA.
• Lithium cells and batteries with a lower lithium content but packed by themselves, i.e., not with or in the equipment they are meant to power are Section IB.
• Lithium cells and batteries with a lower lithium content are classified as Section II and are eligible for an exception from full regulation.
• The packing instructions correspond to the following battery types:
  • PI 966 – Lithium ion cell or battery packed with – but not contained in – the equipment it is meant to power.
  • PI 967 – Lithium ion cell or battery contained in the equipment it is meant to power.
  • PI 969 – Lithium metal cell or battery packed with – but not contained in – the equipment it is meant to power.
  • PI 970 – Lithium metal cell or battery contained in the equipment it is meant to power.

The Regulations:

• The requirement to provide adequate instruction is found in the Section II of the applicable packing instructions in the IATA Dangerous Goods Regulations.
• The minimum requirements for adequate instruction are identified at 1.6.2 of the IATA Dangerous Goods Regulations and detailed below:
  • Classification of lithium batteries being shipped.
  • Documentation of procedures applied to lithium batteries being shipped.
  • Written work instructions or other documentation, including automated controls.
  • Review and understanding of documented procedures as applicable to the job function.
  • Instruction records including date(s) for all employees.
  • Refresher instructions provided at a minimum every two years or as the documented instructions are revised or regulations are changed.
  • Reverse logistics, including transport mode and applicable prohibitions.

The Answer:

A lithium cell or battery that is packed with the equipment it is meant to power (e.g., PI 966 or PI 969) or contained in the equipment it is meant to power (e.g., PI 967 or PI 970) and has a lower lithium content (i.e., Section II) is eligible for an exception from full regulation under the IATA Dangerous Goods Regulations when transported by commercial air. Part of this exception allows the employer of persons who pack or ship the Section II lithium cells or batteries to provide them with adequate instruction instead of full IATA Dangerous Goods Training.

Adequate instruction is not defined, but its minimum requirements are identified. Adequate instruction requires the employer to create work instructions specific to the operations of its employees for the classification, packaging, and hazard communication (e.g., marks, labels, shipping paper) of its lithium cells and batteries. These instructions must be communicated to employees initially and renewed at least every two years. Records must be kept of the date(s) instructions were provided to employees.

I may be biased, but I interpret adequate instruction to include some form of training.

Conclusion:

The regulations for the transportation of lithium cells and batteries are complex and subject to change. It should come as no surprise the regulations for transportation by air addressed in this article are more stringent than for other modes. The regulations of the International Maritime Organization (IMO) and the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) do not require training nor adequate instruction for similar sized and packed lithium cells and batteries when transported subject to their regulations.

I get questions from around the world! Like this one on February 16, 2021:

Hello,

Let me introduce myself,

I am <<Name>> from Belgium. I’m trying to understand the DGR to help a friend who is about to take her IATA category 6 exam. I have no experience in the transportation of dangerous goods.

I found your site by chance while doing a search on the Q Value. Your explanation is interesting. Read: Calculating the “Q” Value for Different Dangerous Goods in a Single Outer Packaging (All Packed in One)

On the other hand, I have a question: in practice, where to indicate on a DGD, that we have an official state authorization to proceed with the air transport of a certain dangerous good. In my example, I am talking about the State variation BEG-02 of Belgium (regarding Class 1) which is also included in the DGR (8.1.6.9.4 Fourth Sequence – Authorizations). Is it in the Authorization column or in the Additional handling information box ?

Because there is no example on the DGR and I did not find any example on the Internet. Enclosed, you’ll find my fillable DGD for my question.

And in general, when the same Special provision applies to different dangerous goods in the same shipment, do I have to write the same number of the Special provision for each UN number ? For example A802. Do I have to write it as many times as it applies to different dangerous goods.

Thank you for taking the time to answer my question. And I apologize for my low level of English. I am French-speaking.

My answer that day:

Note: This answer is derived from the 62nd Edition of the IATA Dangerous Goods Regulation, effective for calendar year 2021 only.

I will try to answer your questions below.

• 8.1.6.9.4 requires only one of the following 16 Special Provision codes to be displayed in 4th Sequence Authorization of the Shipper’s Declaration for Dangerous Goods if applicable to that consignment: A1, A2, A4, A5, A51, A81, A88, A99, A130, A190, A191, A201, A202, A211, A212, & A331.
• Other Special Provision codes may be included in 4th Sequence Authorization but are not required to be displayed.
• Per 8.1.6.9.4(b), if a consignment is being shipped under any governmental authorization a statement that the approval is attached to the Declaration must be included in 4th Sequence Authorization. The authorization(s) must include:
  • quantity limitations;
  • packaging requirements;
  • aircraft type, if applicable;
  • any other relevant information.
• BEG-02 requires a governmental authorization. Therefore, a copy of the approval should include the required information and be attached to the Declaration. A reference to it must be included in 4th Sequence Authorizations of the Shipper’s Declaration for Dangerous Goods. Note: BEG-02 is one of many State variations and operator variations that effect 8.1.6.9.4.
• Your last question about how many times to write the Special Provision code is more difficult to answer. There is no clear indication in the IATA DGR. However, my reading of the DGR beginning at 8.1.6.9 tells me that the description is for the entire consignment, not each individual dangerous good. Therefore, the display of the Special Provision Code or other information in 4th Sequence Authorizations would be just once to represent the entire consignment. (This may warrant further research).

I hope this helps. Please contact me with any other questions.

That seemed to do it:

Thank you, Sir, for taking the time to answer my questions.

I understand now.

I will get back to you later if I have any questions.

Regards,

Conclusion:

The IATA Dangerous Goods Regulations – like the Dangerous Goods Code of the International Maritime Organization – are truly international. States, e.g., Belgium, Mexico, China, &etc., and air carriers (operators) have variations to the regulations, but otherwise, the regulations for the international transport of dangerous goods by air are the same in Belgium as they are in the U.S. Learn more about IATA Dangerous Goods Training.

Purpose:

The purpose of this article is to explain the use, restrictions, requirements, & limitations for the display of the Cargo Aircraft Only label for the air transport of dangerous goods.

Introduction:

Perhaps the most unusual in appearance of all hazard communication used by the transportation regulatory agencies is the Cargo Aircraft Only label. Black letters and images on an orange background. An image of a passenger aircraft (notice the seats?) with a cartoon human figure. The human figure has an outlandishly enlarged hand preventing a pallet of dangerous goods from being loaded on the aircraft. To further convey the point, emanating from the human character is a speech bubble that reads “CARGO AIRCRAFT ONLY”. And, at the very bottom of the label, just to ensure we got the point, it reads: “FORBIDDEN IN PASSENGER AIRCRAFT”. Despite, or perhaps because of, its “cartoony” imagery, this is the hazard communication used by international agencies and USDOT/PHMSA to indicate a hazardous material or dangerous good that is forbidden as cargo on a passenger aircraft and must be transported in a cargo aircraft only.

Before we begin…

• The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) creates and enforces the Hazardous Materials Regulations (HMR) for the transportation of hazardous materials (HazMat) by all modes (motor vehicle, rail, vessel, & aircraft) to, from, or through the U.S.
• The Dangerous Goods Regulations of the International Air Transport Association (IATA) are produced in consultation with the International Civil Aviation Organization (ICAO) and are the guide recognized by the world’s commercial airlines for the transportation of dangerous goods by air.
• USDOT/PHMSA authorizes compliance with the IATA Dangerous Goods Regulations for the transportation of HazMat by air to, from, or through the U.S.
• The current version of the Cargo Aircraft Only has been in use since January 01, 2013 when it replaced a label with many similarities but lacking a clear message limiting the transport to cargo aircraft only.

• The HMR also make use of the Cargo Aircraft Only label. Its use under those regulations are not within the scope of this article.
• Regulations of the HMR specific to lithium batteries at 49 CFR 173.185(c)(1)(iii) allow for the use of alternative markings to the Cargo Aircraft Only label.
• The IATA Dangerous Goods Regulations identify two different types of labels:
  • Hazard labels (7.2.3) indicate the potential hazards within a package.
  • Handling labels (7.2.4) are used to convey additional information about the dangerous good or its handling restrictions. Handling labels are used alone or in addition to hazard labels. The Cargo Aircraft Only label is a handling label.

Scope and Applicability:

This article will address solely the use of the Cargo Aircraft Only label subject to Edition 63 (Effective January 1, 2022 to December 31, 2022) of the Dangerous Goods Regulations of the International Air Transport Association (IATA).

Specifications:

• An illustration of the Cargo Aircraft Only label showing its approved design and color is at Figure 7.4.B of the IATA Dangerous Goods Regulations.
• The minimum dimensions of the Cargo Aircraft Only label are 120 mm wide x 110 mm high. These dimensions may be halved for small packages of Division 6.2 Infectious Substances.

Applicability (7.2.4.2):

The use of the Cargo Aircraft Only label – its applicability – depends upon the classification of the dangerous good, its quantity per package, the relevant packing instructions, and the presence of any State variations.

• The Cargo Aircraft Only label must be displayed on a package of dangerous goods if the package contains dangerous goods that are permitted only on cargo aircraft.
  • For the dangerous good: UN1402, Calcium carbide, 4.3, PG I the word “Forbidden” appears in columns I (“Pkg Inst” for Packing Instructions) and J (“Max Net Qty/Pkge” for Maximum Net Quantity per Package) of the List of Dangerous Goods. However, a Packing Instruction number and Maximum Net Quantity per Package are displayed in columns K and L applicable to Cargo Aircraft Only. Therefore, when offered for transport by air a package containing this dangerous good must display the Cargo Aircraft Only label.

• The Cargo Aircraft Only label must be displayed on a package of dangerous goods if the package contains a quantity of dangerous goods that exceeds the maximum net quantity per package in column J.
  • The dangerous good: UN1264, Paraldehyde, 3, PG III is permitted for transport on both passenger and cargo aircraft. Its maximum net quantity per package for passenger aircraft is 60 L; therefore, a package containing 61 L of paraldehyde is not permitted for transport aboard a passenger aircraft. However, the maximum net quantity per package for transport by cargo aircraft only is 220 L and therefore allows for this quantity of paraldehyde per package. Therefore, when offered for transport by air a package containing more than 60 L of paraldehyde carbide must display the Cargo Aircraft Only label.

• The Cargo Aircraft Only label must be displayed on a package of dangerous goods if a State variation requires it to be labelled and transported Cargo Aircraft Only when normally permitted on as cargo on a passenger aircraft.
  • State variations of the USDOT/PHMSA (USG-02, USG-10, & USG-13) forbid the transport of certain dangerous goods on passenger aircraft even if the package is permitted to be transported on passenger aircraft per the IATA Dangerous Goods Regulations.

Q: If a State variation requires the display of the Cargo Aircraft Only label, may that package be transported as cargo on a passenger aircraft outside the jurisdiction of that State?

A: Yes. Per 8.1.6.5.3, if the IATA Dangerous Goods Regulations permit its transport as cargo on a passenger aircraft and it is solely a State variation that requires it to be transported by cargo aircraft only, then outside the jurisdiction of the State with the variation it may be transported as cargo on a passenger aircraft under the following conditions:

• • This text must be included in the Additional Handling Information box of the Shipper’s Declaration for Dangerous Goods: “This shipment may be carried on passenger aircraft outside <<State>> jurisdiction.”
  • The Cargo Aircraft Only label must be removed or obliterated before the package is loaded onto a passenger aircraft. If the package is subsequently carried inside the jurisdiction of the State with the variation, the label must be re-affixed.

• The Cargo Aircraft Only label should not be displayed on a package of dangerous goods if the packing instruction number and the maximum net quantity per package are the same for passenger and cargo aircraft in the List of Dangerous Goods.
  • UN3082, Environmentally hazardous substance, liquid, n.o.s. has the same packing instruction number (964) in columns I and K and the same maximum net quantity per package (450 L) in columns J and L.

• The Cargo Aircraft Only label must not be displayed on a package that is packed according to the passenger aircraft limitations of columns G and H (for limited quantity) or columns I and J even when it is included on a Shipper’s Declaration for Dangerous Goods marked as “Cargo Aircraft Only” because of other packages in the consignment.
  • A package containing 10 L of Chromic acid solution is not permitted as cargo on a passenger aircraft and must display the Cargo Aircraft Only label. A package containing 5 L of Chromic acid solution is permitted as cargo on a passenger aircraft and is not required to display the Cargo Aircraft Only label. If combined in one consignment, the Shipper’s Declaration for Dangerous Goods must be marked to indicate it is Cargo Aircraft Only (due solely to the 10 L package of Chromic acid solution). However, per 7.2.4.2 and 8.1.6.5.2, it is a violation to display the Cargo Aircraft Only label on the 5 L package of Chromic acid solution.

Conclusion:

It is no exaggeration to say that the Cargo Aircraft Only label is the most recognizable and the most important form of hazard communication used for the air transport of dangerous goods. Make certain you are familiar with the situations you must use it, the times you should not use it, and the times you must not use it.

Question (11.23.21):

Hi Daniel,
I saw your video on YouTube and had a couple questions I was hoping you could answer for me. Regarding Limited Quantities, does the UN number get written on the Limited Quantities sticker?

Answer (11.23.21):

Thank you for contacting me. Please see below.

Before we begin…

This Q&A is based on the 63rd Edition of the IATA Dangerous Goods Regulations, effective in calendar year 2022.

Sent from the Contact Me page of my website:

Message Body:
I have an on-line shipping training on the IATA Dangerous Goods Regulations for researchers at my institution on shipping biologicals and dry ice by air. A test is given and upon passing they get a certificate with my name and the date on it along with a description of the course: Shipping Dangerous Goods training and Class 6.2 Infectious substances and Class 9 Miscellaneous Goods.

Our parent organization wants to have 1 training for many institutions within the system. Currently the biosafety officers at institutions with biosafety programs have their own programs/tests for this certification. And we are available for consult with any questions. I am not sure that the smaller hospitals that have some shipping needs should be certified by myself or one corporate trainer. I don’t even know where these institutions are located.

The question is, what are the requirements for the actual certificate, (Does the trainer’s name need to be on this?) and does each entity/hospital within the larger corporation need to have a trained trainer on site to cover the needs of these hospitals? Is each individual institution liable for their own shippers?

Thank you for your insight.

My reply:

Thank you for contacting me. Please see below.

• IATA (the International Air Transport Association) does not require a certificate for trainees upon completion of training. I provide a certificate with my training because people expect it.
• IATA regulations at 1.5.1.4 require the following record of training and assessment (initial and biennial):
  • Individual’s name.
  • Most recent training and assessment completion month.
  • Description, copy, or reference to training materials used.
  • Name and address of organization providing training. Not the name of the trainer, though I put mine on it.
  • Evidence which shows that personnel have been assessed as competent.
• I created a record of the training separate from the certificate that I use in my training. The record is designed to meet the requirements of 1.5.1.4 described above.
• Beginning with the 62nd Edition, effective from January 01, 2021 to December 31, 2021, the Dangerous Goods Regulations require applicable personnel to be trained as assessed to determine their competence instead of being trained and tested. The requirement for an assessment of competence instead of a test continued with the 63rd Edition in 2022.
• However, the new – and more stringent – requirements do not go become mandatory until 01.01.23. The regulations requiring a test instead of an assessment are found in Appendix H, Attachment A of the IATA Dangerous Goods Regulations and may be used until December 31, 2022.
• Each site does not have to have its own trainer. I provide training for multiple businesses.
• Each employer is required to ensure its personnel receive the required training and are trained or assessed to determine competence.

I hope this helps. Please contact me with any other questions.

Additional concerns:

Thank you.  My concern is if there were an incident, we have our training online, and only admins would have access to the exam results which would need to be presented.  What is the liability for the “owner” of the training?  When there are incidents, who provides the corrective action letter?  I’ve done this for my institution.

I appreciate you advice.

My reply:

Good questions. Legitimate concerns. Please see below.

• Any training – at least mine – will provide you with the required record of the training. This may include documents to print or save as pdf.
• The Dangerous Goods Regulations do not require the employer to provide access to the exam results to an inspector or anyone else. H.A 1.5.5.1 of Attachment A of Appendix H requires the record of the training to include: “evidence, which shows that a test has been completed satisfactorily.” While providing access to exam results is one may to meet this requirement, it is not the only way.
• There is no liability for the owner of the training (if by that you mean the training provider). Regulations of IATA & USDOT/PHMSA put the responsibility for ensuring training and testing are adequate on the employer.
• Not quite sure what you mean by “incidents”. If you mean an inspection by a regulatory agency, then the employer must make records of training available for inspection. These records may be a hardcopy or electronic.
• If applicable, a corrective action letter would be written by the company faced with the non-compliance. Likely the employer. However a corrective action letter won’t be necessary if training and assessment (or testing) are adequate and records available for inspection.

Please contact me with any other questions.

That settled it!:

Hi Daniel,
Thank you for your help.

I have another issue, I’d like to run by you.

…but that will have to wait for another Q&A.

Conclusion:

This person is right to be vigilant about their training records. The best training accomplishes little if an accurate record is not kept demonstrating compliance with the applicable regulations. That’s why I assist my customers until they have completed the recordkeeping for the training I provide them.

Introduction:

The 63rd Edition of the IATA Dangerous Goods Regulations (effective January 1 through December 31, 2022) includes significant changes to the packing instructions for lithium cells and batteries when packed alone (UN3480 for lithium ion or UN3090 for lithium metal). The purpose of this article is to explain the removal of Section II from packing instructions 965 and 968 from the 2022 IATA Dangerous Goods Regulations for lithium cells and batteries.

Background:

IATA is the International Air Transport Association. It is a trade association of the world’s airlines. It supports aviation with global standards for airline safety, security, efficiency and sustainability. The IATA Dangerous Goods Regulations is a “field manual” version of the ICAO Technical Instructions. Written and edited by airline dangerous goods experts, the Dangerous Goods Regulations present the requirements for shipping dangerous goods by air in a user friendly, easy to interpret format.

1.1.4 of the IATA Dangerous Goods Regulations, states that the IATA Dangerous Goods Regulations contain all of the requirements of the ICAO Technical Instructions and include additional requirements and industry standards that are more restrictive.

ICAO is the International Civil Aviation Organization. It is a specialized agency of the United Nations. The ICAO Technical Instructions are a list of requirements for the transportation of hazardous goods by air. The technical instructions are based on the recommended procedures for the transport of dangerous goods created by the UN Sub Committee of Experts on the transport of dangerous goods (TDG Sub-Committee).

The Pipeline and Hazardous Materials Safety Administration within the United States Department of Transportation (USDOT/PHMSA) is responsible for developing and enforcing regulations for the safe, reliable, and environmentally sound transportation of nearly 1 million daily shipments of hazardous materials by land, sea, and air.

At 49 CFR 171.22(a) of the Hazardous Materials Regulations, USDOT/PHMSA authorizes the transport of hazardous materials (aka: dangerous goods) within the U.S. in accordance with the ICAO Technical Instructions with certain restrictions and limitations.

Scope and Applicability:

This article is applicable solely to the 63rd Edition of the IATA Dangerous Goods Regulations. These regulations are in effect from January 1, 2022 to December 31, 2022.

Compliance with this revision is mandatory after March 31, 2022. Until that date the Section II provisions of PI 965 and PI 968 may be used as they are found in the 62nd Edition (2021) of the IATA Dangerous Goods Regulations.

This revision applies solely to the following packing instructions:

• PI 965 for lithium ion cells and batteries packed alone (UN3480) on cargo aircraft only (CAO).
• PI 968 for lithium metal cells and batteries packed alone (UN3090) on cargo aircraft only (CAO).

Both PI 965 and PI 968 have a multitude of State and Operations variations that may effect the transport of a lithium cell or battery. The effect of these State and Operator variations are not considered in this article.

What is the Significant Change?

From page xxiii of the 63rd Edition: SIGNIFICANT CHANGES AND AMENDMENTS TO THE 63RD EDITION (2022)

PI 965 and PI 968 – Have been revised to remove Section II from these two packing instructions. To provide shippers with time to adapt their logistics processes to ship lithium cells and batteries in accordance with Section IB of Packing Instruction 965 and Packing Instruction 968, as applicable, there is a 3-month transition period until 31 March 2022, during which time shippers may continue to use Section II.

Consequential amendments have been made to 1.6.1, Special Provision A334, 7.1.5.5.1, Table 9.1.A and Table 9.5.A to reflect the deletion of Section II of Packing Instruction 965 and Packing Instruction 968.

Prior to the revision the Packing Instructions for lithium ion (PI 965) or lithium metal (PI 968) cells or batteries packed alone contained three sections:

• Section IA applied to:
  • Lithium cells or batteries with a lithium content above the threshold amount. (see Lithium Content table below)

Or…

• • Lithium cells or batteries packed in a quantity that exceeded that allowed in Section IB, Table 965-IB or Section IB, Table 968-IB, respectively.

Lithium Content

Section IB, Table 965-IB

Section IB, Table 968-IB

• Section IB applied to:
  • Lithium cells or batteries with a lithium content at or below the threshold amount packed in a quantity that exceeded that allowed in Section II, Table 965-II or Section II, Table 968-II, respectively.

Section II, Table 965-II

Section II, Table 968-II

• Section II applied to:
  • Lithium cells or batteries with a lithium content at or below the threshold amount and packed in a quantity that did not exceed that allowed in Section II, Table 965-II or Section II, Table 968-II, respectively.

After the revision the Packing Instructions for lithium ion (PI 965) or lithium metal (PI 968) cells or batteries packed alone contain only two sections:

• Section IA remains unchanged.
• Section IB now applies solely to lithium cells or batteries with a lithium content at or below the threshold amount and in a quantity that does not exceed that allowed in Section IB, Table 965-IB or Section IB, Table 968-IB, respectively.
• Section II has been removed.

What’s it mean?

After the effective date (March 31, 2022), the packing instructions for a lithium ion or lithium metal cell or battery packed alone (PI 965 or PI 968, respectively) will no longer include the packaging exception from full regulation in Section II. Under the packing instructions of Section IB, a lithium ion or lithium metal cell or battery packed alone is subject to all of the applicable provisions of the IATA Dangerous Goods Regulations (including the General Requirements) except for the requirement to use a specification (UN Standard) packaging.

Consequential Amendments to Reflect the Deletion of Section II of PI 965 and PI 968:

• 1.6.1 Adequate Instruction for Shipping Section II Lithium Batteries removed the reference to PI 965 and PI 968 since these packing instructions no longer contain a Section II.
• Special Provision A334 was revised to remove the reference to Table 965-II and Table 968-II. However, the values from those tables were added to A334 resulting in no effective change to the special provision.
• 7.1.5.5.1 for the lithium battery mark was revised to remove the reference to Section II for both PI 965 and PI 968.
• Table 9.1.A Applicable Acceptance Procedures Summary (9.1.3.3) was revised to remove the reference to Section II for PI 965 and PI 968.
• Table 9.5.A Dangerous Goods Not Required to Appear on the Information to Pilot-in-Command (9.5.1.1.3.4) was revised to remove the reference to Section II for PI 965 and PI 968.

Conclusion:

Compliance with the IATA Dangerous Goods Regulations for the transportation of lithium cells or batteries just got harder. Or did it? While the Section II packing instructions offered some relief from full regulation, having three sections (IA, IB, & II) for both PI 965 and PI 968 made the classification of lithium cells or batteries packed alone very difficult. And while the Section IB packing instructions are more stringent than those of Section II (e.g., Section IB requires initial and biennial training whereas Section II does not), Section IB does not require specification packaging which means a shipper of these batteries can still save money on packaging and transportation costs.

Before we begin…

The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) creates and enforces the Hazardous Materials Regulations (HMR) for the transportation of hazardous materials (HazMat) to, from, or through the U.S.

The Dangerous Goods Regulations of the International Air Transport Association (IATA) are produced in consultation with the International Civil Aviation Organization (ICAO) and are the guide recognized by the world’s commercial airlines for the transportation of dangerous goods by air.

The content of this Q&A is based on the 63rd Edition of the IATA Dangerous Goods Regulations, effective January 01, 2022 until December 31, 2022.

The question:

Subject: IATA certification requirements

Message Body:
I have an on-line shipping training for researchers at my institution on shipping biologicals and dry ice. A test is given and upon passing and they get a certificate with my name and the date on it along with a description of the course: Shipping Dangerous Goods training and Class 6.2 Infectious substances and Class 9 Miscellaneous Goods.

Our parent organization wants to have one training for many institutions within the system. Currently the biosafety officers at institutions with biosafety programs have their own programs/tests for this certification. And we are available for consult with any questions. I am not sure that the smaller hospitals that have some shipping needs should be certified by myself or one corporate trainer. I don’t even know where these institutions are located.

The question is, what are the requirements for the actual certificate, (does the trainer’s name need to be on this?) and does each entity/hospital within the larger corporation need to have a trained trainer on site to cover the needs of these hospitals? Is each individual institution liable for their own shippers?

Thank you for your insight.

The answer:

Thank you for contacting me. Please see below.

• IATA does not require a certificate for trainees. I provide a certificate with my training because people expect it.
• IATA Dangerous Goods Regulations at H.A.1.5.5 (Appendix H) require the following record of training (initial and biennial):
  • Individual’s name.
  • Most recent training completion month.
  • Description, copy, or reference to training materials used.
  • Name and address of organization providing training. Not the name of the trainer, though I put mine on it.
  • Evidence which shows test completed satisfactorily.
• 1.5.1.4 reads differently than the above as the regulations now require an assessment of competence instead of just a test. However, the new – and more stringent – requirements (those found in 1.5.1.4) do not become mandatory until 01.01.23.
• I provide a record of the training separate from the certificate.
• Each site does not have to have its own trainer. I provide training for multiple businesses.
• Each employer is required to ensure its personnel receive the required training.

I hope this helps. Please contact me with any other questions.

A concern:

Thank you. My concern is if there were an incident, we have our training online, and only admins would have access to the exam results which would need to be presented. What is the liability for the “owner” of the training? When there are incidents, who provides the corrective action letter? I’ve done this for my institution.

I appreciate your advice.

My reply:

Good questions. Legitimate concerns. Please see below.

• Any training – at least mine – will provide you with the required documents to record the training. This may include documents to print or save as pdf.
• There is no liability for the owner of the training (if by that you mean the training provider). Regulations of IATA & USDOT/PHMSA put the responsibility for ensuring the adequacy of training and testing on the employer.
• Not quite sure what you mean by “incidents”. If you mean an inspection by regulatory agency, then employer must make records of training available for inspection.
• If applicable, corrective action letter would be written by the company faced with the non-compliance. Likely the employer. However corrective action letter won’t be necessary if training and testing adequate and records available for inspection.
• IATA training requirements will become more strict as of 01.01.23.

Please contact me with any other questions.

Any more questions:

The contact actually had another question, but it was related to the Materials of Trade exception and not the training requirements of IATA. The content of that email exchange will be handled in a separate Q&A.

Per Section 8 – Documentation of the International Air Transport Association (IATA) Dangerous Goods Regulations, a “Shipper’s Declaration for Dangerous Goods” must be completed by the shipper of each consignment of dangerous goods, except for the following:

• UN3164, Articles, pressurized, hydraulic (see Packing Instruction 208(a)).
• UN3164, Articles, pressurized, pneumatic (see Packing Instruction 208(a)).
• UN3373, Biological substance, Category B (see Packing Instruction 650).
• UN1845, Carbon dioxide, solid (Dry ice) when used as a refrigerant for other than dangerous goods (see Packing Instruction 954(c)).
• Dangerous goods in excepted quantities (see 2.6.8).
• UN3245, Genetically modified organisms, Genetically modified microorganisms (see Packing Instruction 959).
• Lithium ion or lithium metal cells or batteries meeting the provisions of Section II of Packing Instructions 965-970.
• UN2807, Magnetized material (see Packing Instruction 953).
• Radioactive material, excepted packages (RRE) (see 10.5.8).

The Dangerous Goods Regulations of the International Air Transport Association (IATA) is the guide recognized by the world’s airlines to ensure compliance with the Technical Instructions of the International Civil Aviation Organization (ICAO). The transportation of dangerous goods (aka: hazardous materials or HazMat) by air must done in compliance with the ICAO Technical Instructions. Compliance with the IATA Dangerous Goods Regulations is one way to ensure compliance with the ICAO Technical Instructions.

At 49 CFR 171, subpart C the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) authorizes compliance with the ICAO Technical Instructions – along with some limitations and additional restrictions of its own – for the transportation by air of dangerous goods to, from, or anywhere through, the U.S.

In short: if you offer for transportation a dangerous good by air anywhere in the world (international or domestic) it will likely require that you comply with the Dangerous Goods Regulations of IATA.

The purpose of this article: Explain the requirements of Section 3.10 the IATA Dangerous Goods Regulations for the classification of a dangerous good with more than one hazard. (more…)

I get questions from all over the world. Like this one on October 19, 2020:

Hi Daniel,

I am trying to make sense of all the regulations regarding shipping dangerous goods for my PhD study and ended up on your website.
Would you perhaps be able to clarify some things for me?

Not sure if this is a problem if you specialize more in US regulations: I am looking for West/Central Africa to Europe exchanges! I am just going to start with what I hope to be a simple question: what are the restrictions for transporting ethanol (>70%) from Europe to West Africa, in terms of volume, packaging and paperwork?

I got really confused with technical details when reading up on things, so your help will be much appreciated!

Kind regards,

My reply the same day:

I can assist you. Please advise on the following:

• Will transportation be by air or vessel?
• If by air, what is the air carrier?
• What is the volume of ethanol you intend to ship? Per inner packaging? Per outer packaging?

I look forward to assisting you.

More information was quickly provided:

Dear Daniel,

Thank you very much for your swift reply.

So, on the way there, right now it looks like I will have to take 5 to 6 bottles of 1L “with me” when travelling by plane to West Africa. Is that allowed, what arrangements should be made?

On the way back, it gets a bit more complicated:

• we are looking at perhaps 5 to 10 samples of lion tissue in 50mL tubes (so ethanol < 500ml) per box
• but with many more (~100) faecal samples in same tubes but with silica beads (I’m specifying this as I believe this will impact your answer)

Many thanks for your time,

My reply later that day:

Please see below.

• That quantity of dangerous good you indicate: 5-6 x 1L of Ethanol, cannot be transported by air as a passenger’s checked or carry-on baggage per 2.3 of the International Air Transport Association Dangerous Goods Regulations (IATA DGR). It must be shipped as a fully-regulated dangerous good.
• You must contact a commercial air carrier (UPS, FedEx, other) to arrange for its transport by air as a dangerous good.
• The samples coming back may be easier as they may be transported as passenger baggage without air carrier approval if it can meet the requirements of 2.3.5.12 of the IATA DGR:
  • Non-infectious specimens.
  • Wrapped in paper or cloth and then heat-sealed bag w/ no more than 30 mL of free liquid or vials or rigid container in heat-sealed bag of no more than 30 mL free liquids.
  • Placed in another plastic bag with absorbent.
  • Finished bag placed in strong outer packagings with suitable cushioning.
  • No more than 1 L of ethanol in completed packaging.
  • Package marked: “scientific research specimens, not restricted”

I hope this helps. Please contact me with any other questions.

The next day, October 20, 2020 (maybe it was the same day in Europe, I don’t know.):

Dear Daniel,

Thank you very much for all the info, this is very helpful!

• Any chance zip-lock bags can be accepted instead of heat-sealed ones? I think I know your answer but I have to ask just in case.
• You also say no more than 1L of ethanol in completed packaging. Does this also mean that just a 1L bottle ethanol, maybe in particular packaging, in passenger baggage is fine? Just checking where the limits are.

Many thanks for your time and help,

My reply:

Please see below.

• The regulations require a heat-sealed bag (and more) for the samples as baggage.
• The limit of no more than 1 L of ethanol (or other flammable liquid used as preservative) is just for the samples as baggage. It requires the inner packagings within the completed package to contain no more than 30 mL of ethanol as free liquid. You may not transport a 1 L bottle of ethanol as baggage on an aircraft, no matter the packaging.
• The 1 L bottles you intend to bring to Africa must be packaged and shipped as a dangerous good with a commercial air carrier.
• Depending on its Packing Group it may be eligible for the limited quantity exception which will make transportation by air somewhat easier and perhaps less expensive.
  • Packing Group II may be transported as a limited quantity pursuant to packing instructions Y341.
  • Packing Group III may be transported as a limited quantity pursuant to packing instructions Y344.

Please note, my email was only a brief summary of the complete regulations. You must research and comply with the complete regulations.

I hope this helps. Please contact me with any other questions.

That seemed to make things crystal clear (10.21.20):

Dear Daniel,

Thank you very much, crystal clear. This has been incredibly helpful!

Have a nice day,

That should help international relations!

It’s important to remember that the transportation of hazardous materials (aka: dangerous goods) takes place all around the world. Transportation by air will likely be subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA). IATA has a biennial training requirement for shippers and packers of dangerous goods.