2012 IATA Updates

By:  Arthur Mahoney, M.S., CHMM, REA

January 4, 2012

2012 has also brought about some important changes to the IATA Dangerous Goods regulations (DGR) which may impact how you ship dangerous goods* by air.  I have summarized some of the changes below. 
DGR Changes in 2012:

Here are some changes in the 2012 DGR that may impact you. 
  • The provisions applicable to limited quantities have been restructured to bring in all of the requirements for different dangerous goods packed in the same outer packaging into 2.7.5. The text previously was referenced in and

Special Provisions

  • A44 - has been revised to clarify that the chemical kit or first aid kit must not contain substances that will react dangerously. In addition a note has been added to clarify that if the dangerous goods inside the kit are not assigned a packing group, that then no packing group need be shown on the Shipper's Declaration.
  • A802 - is a new special provision assigned to entries in Table 4.2 that are not assigned a Packing Group, but that must, except when in limited quantities, be packed in UN specification packagings that meet Packing Group II performance standards.
  • A803 - is assigned against all Class 8 solid and liquid entries in Packing Group III to reinforce that the substance must, except when in limited quantities, be packed in UN specification packagings that meet Packing Group II performance standards.
  • A804 - is assigned to UN 2803, Gallium and UN 2809, Mercury to reinforce that these substances must be packed in UN specification packagings that meet Packing Group I performance standards.
  • A805 - is assigned to UN1845, Carbon dioxide solid, Dry ice to clarify that it is permitted to be placed directly within an overpack, provided that overpack meets the requirements of Packing Instruction 954.

Packing Instructions

  • 953 - The requirement for the "magnetized material" statement has been clarified to identify that the information must be provided in the appropriate location on the air waybill, when used, or otherwise on alternative transport documentation.
    954 - The requirement for provision of information relating to the dry ice has been clarified to provide for an alternative when no air waybill is used. The information requirements when dry ice is presented in a unit load device have also been made more clear.
  • 965 - 970 - For lithium ion and lithium metal batteries. A note has been added to reinforce that the requirement for all lithium batteries to have successfully passed the UN tests applies to any batteries that have been refurbished or otherwise altered. In addition for lithium batteries meeting Section II it has been clarified that these batteries are subject to the restrictions applicable to carriage in passenger baggage, as provided for in 2.3; lithium batteries are subject to restrictions applicable to air mail as set out in 2.4, and lithium batteries shipped in accordance with Section II are also subject to the provisions for reporting of incidents, accidents and occurrences as set out in 9.6.1 and 9.6.2.

Marking and Labeling

  • - The requirements for marking overpacks have been clarified to show specifically which markings must be reproduced when not visible and which are not required.


  • - In recognition of the growing use of computer systems to generate the information on the Shipper's Declaration, text has been added to provide alternatives to strike out of the non-applicable aircraft limitation and shipments type. This alternative is set out in more detail in,, and
  •, Step 7 - The method of describing multiple overpacks has been expanded upon to align the text with that in Section 7 for marking of overpacks.
  • 8.2.3 - The provisions for information that must be provided on the air waybill for dangerous goods not requiring a Shipper's Declaration has been revised to reflect the changes that have taken


  • - New paragraphs have been added recommending that the distances shown in Tables 9.3.D and 9.3.E should be applied as a minimum to separate persons for temporary storage areas in cargo terminals, warehouses, etc.
  • - This is a new paragraph setting out the recommendations for operators with respect to the management of dangerous goods permitted in passenger and crew baggage where operator approval is required.

Shipping Software Requirements for FedEx:
Since January 10, 2011, FedEx Express has required all Shipper's Declarations originating in the U.S., excluding all 023 air waybill shipments, to be prepared using only the following methods:

  1. FedEx approved vendor software application
  2. Preapproved shipper proprietary software; or
  3. FedEx Express Automated Shipping Solutions that have dangerous goods error checks.

Contact your Fed-Ex account manager for assistance. Fed-Ex has a list of approved software as well.

Emergency Responder Contract Information:
As a reminder, since October 1, 2010, U.S. Department of Transportation regulations require the emergency response information (ERI) provider (e.g., name and contract number) to be entered in association with (immediately before, after, above or below) the emergency response telephone number on shipping papers.  Also remember that you must be registered with the ERI provider and it is your responsibility to provide them with accurate and up to date information (e.g., MSDSs or profiles). 
Training Reminder and Services

Training Requirements
Who Must be Trained:
Have you asked yourself this question? Very often, companies will only train and certify Shipping and Receiving personnel and forget about other employees who have a role in their company's dangerous goods shipping process. 


A common situation that puts companies out of compliance and at risk occurs when employees (e.g., lab personnel) without the proper training and certification package or even partially package a dangerous good.  The DOT has made it clear that employees who even "partially" assemble a dangerous goods package must be properly trained and certified.  This means that even employees who place sealed primary containers (e.g., a bottle of a regulated dangerous good) in an outer shipping box, which they provide to Shipping and Receiving personnel to inspect, close, and mark and label, are themselves required to be trained and certified.  


As a reminder, per 49 CFR and HM-223**, all employees who affect hazardous materials/dangerous goods* transportation safety must be properly trained and certified.  This includes employees who:

  • Determine a material's hazard class(es);
  • Select the packaging;
  • Fill and close a packaging;
  • Mark and label a package;
  • Prepare or review shipping papers and emergency response information;
  • As an importer of hazardous materials/dangerous goods*, provide the shipper with shipping requirements that will apply to the transportation of the material within the United States;
  • Certify that a hazardous material/dangerous good* is in proper condition for transportation;
  • Load, block, and brace a hazardous material/dangerous good* package in a freight container or transport vehicle;
  • Segregate a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
  • Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that it contains a hazardous material/dangerous good*.
How Often is Training Required:
Initial training is required within 90 days of the job function.  Retraining is required with 24 months (air) and 36 months (highway) of initial training.  Additionally, employees must be retrained when there are changes in the regulations which impact them.
What is the Required Content of the Training:
  • General familiarization training
  • Function-specific training
  • Safety training
  • Security awareness training
Testing and Certification:
Employees must be tested and certified.  But the testing can (and should) be customized to the functions of the employee.  It has been my experience that the most effective training includes the actual packaging materials, shipping software, etc that your employees use. 

Our Training Solution
Focused on What You Ship:
Save money and time and improve compliance by making the training applicable to your employees.  Employees do not need to go to a 2 or 3 day offsite training course which may cover many irrelevant topics and completely miss the ones that your employees really need to know well.  The program I offer can often be completed in a single 1-day session (or several 3-4 hour sessions) at your facility.  In addition, the testing and certification can also be customized to the specific job functions and even include applicable practical exercises using the actual packaging, software, etc that your employees use.     


Added Value: Find and Fix Problems

A valuable outcome of onsite training is discovering and fixing problems in shipping programs during the training.  


Added Value: Your Very Own Shipping Guidelines:
Included in the training can be shipping guidelines/checklists customized to the types of materials you actually ship.  These can also include procedures and forms for carriers that you use (e.g., FedEx, World Courier, UPS, DHL).  These are included in a customized manual for your shipping personnel.
More Added Value: Packaging Solution Consultation:
Working with a number of packaging vendors over the years, I can assist your organization in developing customized packaging solutions.

An Easy Way to Comply
Contact me and I would be happy to provide you a quotation for dangerous goods/hazardous materials training program.
What makes my program especially valuable is that it is specific to the dangerous goods/hazardous materials that you ship and it is presented by me, an expert in the field.

 Other commonly requested services include:
  • Chemical safety audits
  • Safety training, both in person and hosted web-based
  • Onsite and special project support
  • HMBP and chemical inventory services (including uploads to CERS)
  • Hazardous waste auditing, minimization and reporting
  • Bloodborne Pathogens (annual requirement)
  • Hazard Communication 
  • Chemical Hygiene Plan 
  • Laser Safety
  • Biological Safety 
  • Radiation Safety
  • Shop Safety
  • Many others, please contact me
artServed by an Expert
Arthur Mahoney, Principal Consultant

For 19 years, he has been assisting public and private companies to comply with safety, hazardous material management, transportation and safety concerns. He also provides chemical inventory database services.
Feel free to contact us at 650-347-0417 or by email

Arthur Mahoney
Hazard Solutions LLC
*Dangerous goods includes articles or substances which may be hazardous (in air transport).  The definition of dangerous goods is found in the Dangerous Goods Regulations, published by the International Air Transport Association (IATA) .  Dangerous goods are synonymous to hazardous materials, which is the term used to describe hazardous substances in 49 CFR. 
**HM-223 clarifies the many pre-transportation functions which necessitate training.
Disclaimer:  The information presented above should not be construed in any way as legal advice or an interpretation of regulations.  It is meant to provide basic information about topics that may affect clients and colleagues.


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