Significant changes to IATA DGR

MORE THAN TRAINING

AIR • THE UPDATED VERSION OF IATA’S DANGEROUS GOODS REGULATIONS CONTAINS FEWER CHANGES THAN USUAL BUT A NUMBER OF THEM WILL HAVE A SIGNIFICANT IMPACT

THE NEW, 62ND edition of the International Air Transport Association’s (IATA) Dangerous Goods Regulations (DGR) takes effect promptly on 1 January 2021. As it has done in previous years, IATA has made available a summary of the significant changes that can be found in it, to help those subject to the DGR prepare for the new year’s incoming rules.

It might have been expected that this time around, as it is a biennial update for the International Civil Aviation Organisation’s (ICAO) Technical Instructions, which are incorporated in DGR, there would be a lengthy list of amendments. However, with rulemaking activity hampered like all other business operations by the restrictions on travel and meeting imposed to protect against the spread of the Covid-19 virus, the list of amendments adopted by ICAO’s Dangerous Goods Panel and IATA’s Dangerous Goods Board has been rather shorter than usual.

Neither this article nor IATA’s list of significant changes will be sufficient for those in scope of the rules to be compliant; they will still have to acquire copies of the updated DGR. However, it is hoped that the information presented here will go some way to highlighting those amendments that may have particular impact on air shippers, carriers and others active in the supply chain. SECTION 1 The most obvious change in the 62nd edition of the DGR is the incorporation of a competency-based approach to dangerous goods training and assessment in 1.5. This had been included in the 61st edition in Appendix I to give industry and authorities time to consider how they would address the new requirements; the previous 1.5 is now moved to Attachment A of Appendix H, as there is a two-year transitional period until 31 December 2022, during which time the current training provisions may continue to be used.

Elsewhere in Section 1, the list of exceptions in 1.2.7 has been expanded to include dangerous goods required for the preservation of organs intended for transplant, and dangerous goods to be dropped for pest management purposes. New entries have also been added to the indicative list of high-consequence dangerous goods in Table 1.7.A.

SECTION 2 There are several changes to the provisions covering dangerous goods carried by passengers or crew, all involving batteries and battery-powered equipment. Passengers will now be able to carry up to two spare batteries for mobility aids (2.3.2.2) and up to two personal safety devices (2.3.4.2).

The provisions for portable electronic devices (PEDs) and spare batteries for them in 2.3.5.8 have been amended to amalgamate the provisions for electronic cigarettes and for PED powered by wet non-spillable batteries; that subsection also includes a clarification that it applies to dry batteries and nickel-metal hydride batteries as well as lithium batteries.

There is a change to 2.4.2(a) on the transport of dry ice as a refrigerant for UN 3373 in mail; such articles must be offered separately from other mail to allow the operator to meet requirements for acceptance and for the information to the pilot-in-command.

SECTION 3 In the classification section, new criteria added to 3.6.2.5 address solid medical waste containing Category A infection substances; subsection 3.8.3 has revised criteria for the assignment of packing groups to corrosive substances and mixtures.

SECTION 4 The new DGR will include the new UN entries drawn from the UN Model Regulations; UN 0511, 0512 and 0513 for detonators, electronic and UN 3549 for medical waste, Category A. The proper shipping name Dangerous goods in articles is added to UN 3633.

Elsewhere in the List of Dangerous Goods, UN 2216 Fish meal, stabilised is now permitted for both passenger and cargo aircraft, having formerly been forbidden/forbidden. The word ‘stabilised’ is added to the proper shipping name for UN 2522 2-Dimethylaminoethyl methacrylate. The packing instruction for medical and clinical waste (UN 3291) has been changed from PI 622 to PI 621 following the renumbering of the instruction to align with the UN Model Regulations.

Among the special provisions in 4.4, there are amendments to A88, A99, A107, A145, A154 and A201. A154 has been significantly revised to address damaged and defective lithium batteries; this is accompanied by changes to packing instructions PI 965 and PI 970 to specify that lithium cells or batteries identified as damaged or defective in accordance with SP A154 are forbidden for transport.

A new A219 is assigned to UN 2216 Fish meal, stabilised, to specify that antioxidants must be added to the fish meal to prevent spontaneous combustion. An important new special provision is A215, assigned to UN 3077 and 3082 to allow the shipper to use a listed proper shipping name as the technical name.

SECTION 5 In common with other modes, 5.0.2.5 has been changed to allow packagings that meet more than one tested design type to bear more than one UN specification mark.

There are many and various changes to the packing instructions, many of which follow on from amendments in the UN Model Regulations. Of particular note are changes to PI 650 and PI 959 to clarify that the diamondshaped mark with the UN number must appear on one side of the package; PI 957 has been revised to allow for both combination and single packagings; and PI Y963 now identifies that a unit load device prepared by a single shipper may contain dry ice as a refrigerant for consumer commodities.

SECTIONS 6/7 There are numerous revisions to the packaging specification and performance test provisions, including changes to marking requirements. An important change in 6.1.7.2 revises the maximum capacity for metal aerosols. There are the usual updates to ISO standards for UN cylinders and closed cryogenic receptacles in 6.4.2.

A new provision in 6.2.2.7 and 6.2.7.7 identifies that, for aluminium or other metal drums, suitable internal coatings must be applied if the drum is not compatible with the contents to be transported; this is in line with existing requirements for steel drums and steel and aluminium jerricans.

There are revisions in Section 7 to clarify the height of the UN/ID number and the letters ‘UN’ or ‘ID’ on packages (7.1.4.4.1) and to revise the minimum dimension of the lithium battery mark (7.1.5.5.3), both in line with other modal regulations.

SECTIONS 8/9/10 The requirements on how to describe multiple overpacks on the Shipper’s Declaration have been revised, with a new example added in Figure 8.1.Q. There is also a small change in 8.2.1 to the effect that the statement on the air waybill has been revised to align with the use of electronic documentation; there is a two-year transition period for this change.

In 9.1.9, the recommendation that operators should include the transport of dangerous goods as part of their safety risk assessment has been made mandatory. The requirement in 9.6.4 on the provision of reports no longer refers to the state of origin.

There are a few revisions in Section 10, which deals with radioactive materials, to align with the UN Model Regulations and the International Atomic Energy Agency (IAEA) transport safety standards.

APPENDICES Aside from the changes relating to training (see above), there are a few additions to the definitions in Appendix A, changes to the list of organic peroxides in Table C.2, and the usual updated information in Appendices D, E and F.

A full list of the significant changes, as well as the new DGR itself, can be accessed via the IATA website at www.iata.org/en/ publications/dgr/.

ALL THOSE INVOLVED IN THE TRANSPORT OF

DANGEROUS GOODS BY AIR WILL NEED TO COMPLY

WITH THE NEW EDITION OF IATA’S DG REGULATIONS