T
he wellspring of all air freight dangerous goods regulations is a United Nations subcommittee, which publishes pan-
modal and international recommendations. These in turn are picked up by the regulatory bodies for different modes, including the International Civil Aviation Organization (ICAO), which publishes technical instructions. All 190 of the ICAO member countries must implement the body’s technical instructions in their national legislation for domestic and international transport, covering the complete supply chain from shipper to consignee – including all freight carriers, forwarders and handlers. Legally, the shipper is responsible for
correctly declaring and classifying the goods entering the supply chain. As the chain progresses, there are some goods that may only be moved on cargo-only aircraft; and a few items may be too dangerous to be flown at all, except perhaps under special dispensation. The rules also lay down matters such as orientation of packages and labelling. Furthermore, a dangerous goods (DG) note
must be completed and signed by the responsible person – in most cases this will be one of the shipper’s staff, perhaps the shipping or despatch manager. Although a change in the IATA regulations in 2010 does now allow forwarders to sign the note, in practice few freight forwarders have been willing to take on the legal responsibility, although many will provide help and advice on dangerous goods. A spokesman confirms that Panalpina
would not generally be in favour of signing a DG note on a shipper's behalf, although there are appropriately-insured third parties who can provide this as well as general DG information and advice to shippers. To make matters slightly more complicated,
the International Air Transport Association (IATA) also produces its own rules as part of its conditions of carriage, effectively ‘add-ons’ to the ICAO rules that cover matters such as documentation, marking of packages and packaging types. On top of that, there are also airline and
national ‘variations’ to the rules. Often, these governmental and airline regulations stem from specific past incidents and have been instigated by governments or the carriers themselves. ICAO regulations are published every two
years, but IATA updates its own rules annually. Failing to comply with DG rules could, in the worst scenario, down an aircraft with all the
liability that entails. It is worth noting that there have been very few, if any, instances of crashes being caused where the dangerous goods rules were correctly followed. In practice though, failure to declare DG
properly will most likely lead to consignments being 'snagged' by the airline following the latter's own checks – which means delays and possibly increased costs. A spokesman for Deutsche Post points out, moreover, that each checker from the airlines or the operators can interpret the regulations differently. Brandon Fried, executive director of the
Airforwarders Association (AfA) in the US adds that there have been some discussions about shipper versus forwarder responsibility for dangerous goods compliance but as things stand, the onus still lies on the former. The extent to which the shipper needs DG
training is, he said, a grey area. The US Department of Transportation requirements demand that manufacturers of hazardous materials should seek proper accreditation, but what about wholesalers or agents – or a manufacturer that hardly ever ships by air? As DG-qualified personnel are in demand,
taking the dangerous goods course can be one way of increasing your employability, but the courses are not cheap, especially for an individual who is out of work. The Pipeline and Hazardous Materials
Safety Administration (PHMSA) is currently “rewriting the rulebook” on the issue for air transport within, to or from the US or on US- flagged carriers anywhere in the world, but the AfA’s position is “before you do that, why don’t you start enforcing the existing ICAO regulations properly?”
Lithium batteries The carriage of lithium batteries by air has become the biggest issue of discussion recently, Fried continued. This has become a prominent issue, as these shipments have become subject to increasingly stringent rules. Most mishaps to have occurred have been
as the result of a blatant violation of the existing rules, he pointed out. “We think it is overkill to start imposing rules on batteries that are in the correct packaging or correctly inserted in devices,” Fried said. UPS, which says it is “strongly committed
to the safe transportation of dangerous goods”, expects PHMSA to issue a supplemental notice in early 2012 following its current rule-making process on lithium
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