Understanding IATA DGR (Dangerous Goods Regulations)

Packing of Dangerous Goods is solely the responsibility of the shipper, however, the cargo agent, freight forwarder and the airline operator’s Dangerous Goods Acceptance Personnel must ensure that the shipper has used the appropriate packing instructions and packaging. These personnel must also be familiar with the acceptable packing requirements under the regulations. Dangerous goods packages are not normally opened by cargo agent, operator and customs authorities to check compliance because of the following reasons:

• Shipper is responsible for compliance
• Integrity of the outer packaging may be compromised and would not pass performance tests.
• It may be potentially dangerous for personnel safety
• If the package is opened, it has to be restored by qualified person for compliance.

Packing Requirements of Dangerous Goods have been explained in IATA DGR Section 5. Packing Instructions provided in this section give maximum permissible quantity per Inner Packaging. The maximum net quantity permitted in each package is shown in the List of Dangerous Goods in IATA DGR 4.2

While Shipping Dangerous Goods, following precautions must be taken:

• Packing must comply with the set of packing requirements appropriate to the type of Dangerous Goods
• Use only the packaging permitted by the applicable packing instructions specified in DGR
• Restrict the overall quantity per package to the limits specified in DGR
• Ensure that external surfaces of assembled packages are clean of contamination
• Ensure that Dangerous Goods are not included in any freight container or ULD unless exempted under DGR
• Ensure that before using authorized for Re-use packaging or over-packs, all inappropriate dangerous goods markings and labels are removed or completely obliterated.

Packing groups: Packing groups are used for the purpose of determining the degree of protective packaging required for Dangerous Goods during transportation.

• Group I: Great danger
• Group II: Medium danger
• Group III: Least danger

General Packing Requirements:  General Packaging Requirements are there for UN Specification Packaging and Limited Quantity Packaging.

• Dangerous goods must be in good quality packaging which must be strong enough to withstand the shocks and loadings normally encountered in transport, including removal from a pallet, ULD or over-pack for subsequent manual or mechanical handling.
• Packages must be constructed and closed as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration or by changes in temperature, humidity or pressure.
• Packaging used, must also be compatible with the dangerous goods to be transported.
• Parts of packaging which are in direct contact with dangerous goods must not be affected or significantly weakened by those dangerous goods and must not cause dangerous effects.
• Wherever necessary, dangerous goods must be provided with a suitable inner coating or treatment.
• Manufacturers and subsequent distributors of packaging must provide information regarding procedures to be followed, a description of the types and dimensions of closures and any other components needed to ensure that packages as presented for transport are capable of passing the applicable performance tests.

Packaging Options: There are generally four available packaging options for dangerous goods other than radioactive material, shipped under the international standards:

1. UN Specification packaging
2. Limited quantities packaging
3. Excepted quantities packaging
4. Other Packaging

UN Specification Packaging: Under the international standards, specification packaging is generally performance-tested packaging, developed and tested under the United Nations packaging specifications. Internationally recognised testing specifications are found in Section 6 in the IATA Dangerous Goods Regulations. 

• Types of packing include box, drum, receptacle, jerrican, IBC etc. which meets prescribed construction criteria as per IATA DGR Section 6.
• All packaging are subject to drop test, stacking test and other specific design & performance requirements.
• Only Outer packaging are marked with Specification Code
• Inner Packaging are not marked with Specification Code, but meet certain construction requirement.
• For Radioactive Materials, different packing requirements apply as per IATA DGR Section 7

Package Performance Testing:

• Package Performance Testing is normally conducted by government authorized testing agencies
• The required tests vary for each packing group.
• The testing of combination packaging must be carried out on packaging as prepared for shipment
• Subsequent use of tested packaging must be as specified in the applicable test report and conform in all respect with the design type that was tested.
• Test report must contain following information:

• Name and address of the testing facility
• Name and address of the test applicant
• A Unique Test Report Identification
• Date of the Test Report
• Manufacturer of the Packaging
• Description of Packaging in terms of material, dimensions, method of manufacturer etc
• Maximum capacity
• Test Description & Results
• Signature, Name & Status of the Signatory

Types of packaging: There are various types of packaging as follows –

• Combination-Packaging: This type of packaging consists of one or more inner packaging contained in one outer packaging. The inner packaging may require cushioning and  / or absorbent material depending upon the dangerous goods packed. Liquids when packed in an outer package which is not leak-tight, must be provided with a means of containing the liquid in the event of leakage with the use of a leak-proof liner, plastic bag or other equally efficient means of containment.
• Single Packaging- In Single Packaging, article or substance is enclosed in a single container such as drum, jerrican or composite packaging which may be constructed of steel, aluminium, fibreboard, plywood or plastic and may have a removable head.

• Composite Packaging: Composite packaging consists of an outer packaging and an inner receptacle constructed so that the inner receptacle and the outer packaging form an integral packaging. Once assembled, it is a single unit.
• IBC Packaging (Intermediate Bulk Containers): IBCs are rigid or flexible portable packaging that have a capacity of less than 3000 L / 1500 L for different packing groups. They are UN specification packaging that are designed for mechanical handling and permitted only for UN3077 in air transport.

Limited Quantities Packaging: Certain materials in Packing Groups II and III are eligible to be transported under packaging exceptions for "limited quantities." These exceptions allow use of non-specification combination packaging (i.e. packaging that have not been submitted for testing against the UN testing regime) for net quantities of materials that are further limited than for specification packaging, provided that the packages are capable of surviving a 1.2-meter (4-foot) drop test. Materials authorised for packaging under limited quantity exceptions are shown in the IATA Alphabetical List of Dangerous Goods with italicised packing instructions preceded by the letter "Y." Limited Quantity Packaging used in “Y” Packing Instructions must be packed in accordance with DGR 2.7.5 and General Packing Requirements and are subject to all communication and documentation requirements. Each ‘Y” Packing Instruction spells out the requirements, for these packages, including the maximum gross weight limit of 30 Kg.

Excepted Quantities Packaging: Very small quantities of certain dangerous goods are authorised to be shipped without hazard labels or specific dangerous goods documentation under the "excepted quantity" provisions. The eligible materials are shown in Section 2.7 of the IATA DGR. A red-bordered label is presented as the conventional way of satisfying the package marking requirement.

Packing Instructions: General packaging requirements, which apply in virtually every case, are spelled out in the Section 5 of IATA DGR on Packing Instructions in class number sequence. Note that the first number of Packing Instruction (PI) indicates the Class number for primary hazard of the substance being packed. (Examples: Packing Instruction 137 is for Class 1: Explosives, Limited Quantity Packing Instruction Y644 is for Class 6: Toxic & Infectious Substances).  Each packing instruction shows, where applicable, the acceptable single or combination packaging. For Combination Packaging, tables show the acceptable outer packaging and associated inner packaging together with the maximum quantity permitted in each inner packaging. Among these general provisions are requirements that the packaging materials in direct contact with the dangerous goods must be resistant to any chemical or other action of the goods; and the materials of the packaging must not contain substances which may react dangerously with the contents, form hazardous products or significantly weaken the packaging.

Checking the Packaging of Dangerous Goods Shipment: To determine the packaging requirement for a given dangerous goods, under the regulations, following steps are followed:

Step 1: Locate the proper shipping name and UN / ID number

            Note the Packing Group

            Note on which aircrafts, transportation of goods is permitted

            Note the Packing Instruction Number

            Note the maximum net quantity or gross mass for each package

            Note any special provisions which may apply to the packing of the item.

Step 2: Locate and read the appropriate packing instruction.

Step 3: Ensure that the packaging meets all requirements according to the packing instruction / s.

Step 4: Ensure that the quantity limitations for specification packaging are met.

Checking the Packaging of Dangerous Goods packed in one outer packaging: To determine the packaging requirement for a given dangerous goods packed in one outer packaging under the regulations, following steps are followed:

Step 1: Observe the details of each item according to the List of Dangerous Goods

Step 2: The Shipper must ensure that the substances do not react dangerously with each other and check that they do not require segregation according to the DGR Table 9.3.A.  Care should be taken to ensure that passenger & cargo aircraft substances are not mixed with “Cargo Aircraft Only” substances.

Step 3: Refer to each applicable packing instruction and make sure that:

• The inner packaging used are permitted
• The maximum quantity limits for the inner packaging have been observed
• The outer packaging meets the requirements for each packing instruction

Step 4: Refer to the List of Dangerous Goods and each packing instruction and determine:

• The most restrictive packing group and ensure that the package meet the performance standards of this packing group.

• The Q value: the highest permitted net quantity per package according to the formula        Q = (n1/M1) + (n2/M2) whereas Q must not exceed 1. The calculated Q value must be rounded-up to the first decimal place and entered on the Shipper’s Declaration.

Step 5: Ensure that the outer packaging does not contain inner packaging of infectious substances with inner packaging of other types of dangerous goods.

Checking the Packaging of Dangerous Goods packed in one Limited Quantity packaging: To determine the packaging requirement for a given dangerous goods packed in one Limited Quantity packaging under the regulations, following steps are followed:

Step 1: Observe the details of each item according to the List of Dangerous Goods

Step 2: The Shipper must ensure that the substances do not react dangerously with each other and check that they do not require segregation according to the DGR Table 9.3.A.  Care should be taken to ensure that shipper does not place any substances other than limited quantity substances with this type of all packed in one.

Step 3: Refer to each applicable packing instruction and make sure that:

• The inner packaging used are permitted
• The maximum quantity limits for the inner packaging have been observed
• The inner packaging meets the criteria of IATA DGR 6.1

Step 4: Refer to the List of Dangerous Goods and each packing instruction and determine:

• For classes other than for Classes 2 & 8, the Q Value

• for Class 2 & 9 ensure that when packed together with other classes, gross weight does not exceed 30Kg.
• Ensure that all Q value compliances are correctly followed.

Step 5: Ensure that the outer packaging meets the construction criteria of IATA DGR 6.2 and the test criteria of IATA DGR 6.6

Step 6: Ensure that the maximum gross weight of any Limited Quantity package does not exceed 30 Kg.

Over-packs: An over-pack is an enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the over-pack must be properly packed, marked, labelled and in proper condition as required by the Regulations. An Aircraft ULD is not an overpack. To be acceptable as an overpack, the following conditions must be met:

• Substances that might react together dangerously must not be packed in the same overpack
• Substances that require segregation according to IATA DGR Table 9.3A must not be packed in the same over-pack

Cargo Only Aircrafts dangerous Goods can only be accepted in over-packs when:

• Only one package is contained in the over-pack
• There is more than one package contained in the over-pack and the over-pack is assembled in such a way that clear visibility and easy access to the Cargo Aircraft Only packages is possible. i.e. it is not a closed over-pack
• The intended function of each package must not be impaired by the over-pack.

Salvage Packaging: Special packaging into which damaged, defective or leaking dangerous goods are placed for the purposes of transport for recovery or disposal, are called as Salvage Packaging. They must be used for substance of Classes 1,2 & 7 and Division 6.2 other than clinical & medical waste falling under UN3291. Metal salvage packaging meeting packing group requirements must not be used to salvage Self-reactive Substances of Division 4.1 or Organic Peroxides of Division 5.2.  Salvage Packaging must bear the mark “SALVAGE” in addition to the UN Specifications Marking described in IATA DGR 4.7. Prior approval from the appropriate national authority must be obtained to ship salvage packaging.