Thursday, July 28, 2011

Common misapplication of the UN packing group number for IATA/ICAO dangerous goods shipments

As most of us have been taught by our dangerous goods instructor, the UN Packing Group Number (I, II or III) denotes the degree of danger for a particular dangerous goods. UN Packing Group I, II or III means respectively, high, medium or low danger.

Criteria for these groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8. Whenever a UN Packing Group Number is reflected in Column F of the Alphabetical List in the IATA Dangerous Goods Regulations (and Column 8 of the ICAO Technical Instructions), with a few exceptions, this number must then be reflected on the shipping document.

A frequent misapplication of this requirement happens when a shipper will notice a UN Packing Group Number reflected in the text of a Packing Instruction Number (PIN) that is not reflected in either Column F or Column 8.

For example, a Class 1 material, UN0456, Detonators, electric, is referenced to PIN 131 for either Passenger or Cargo Aircraft Only preparation in the Alphabetical List of Dangerous Goods and Column F is blank for the Packing Group (Column 8 in ICAO for the same Class 1 material is also blank). The reasoning for the blank packing group column is that Class 1 dangerous goods have not had packing group criteria developed yet by IATA and ICAO.

In the text of PIN 131, it states, "Unless otherwise provided for in these Regulations, packagings must meet Packing Group II requirements". In general, this statement refers to the degree of integrity that the packaging must have, not the degree of danger of the dangerous goods.

The UN Committee of Experts uses the letter of X, Y or Z to denote what UN Packing Group Numbers are authorized in a UN package.
  • Using the letter X, means that the package is authorized to contain a Packing Group I, II or III material.
  • Using the letter Y, means that the package is authorized to contain a Packing Group II or III material.
  • Using the letter Z, means that the package is authorized to contain a Packing Group III material only.
In the case of PIN 131, the letter Y is to be reflected in the UN Specification Mark as a minimum. The letter X is also authorized because it is meant for Packing Group I and II materials.

Unfortunately, this misapplication isn't normally caught until after the shipment has been delivered to the airline, and has been inspected by the airline's dangerous goods specialist or technician utilizing a checklist. Upon detection of the error, the shipment has now automatically incurred a delay until corrected by the shipper. Upon inspection of the airline's dangerous goods file (kept by the airline for a period of 1-2 years depending on the country concerned) of dangerous goods shipments by a regulatory officer, the shipper may be asked additional questions regarding the shipment.