In dangerous goods training classes, we sometimes like to ask the class why they think some dangerous goods are restricted to “cargo aircraft only.” The usual reply is, “Because there are people on the plane!” After we remind them that pilots are people, there are typically no more answers quickly forthcoming. In reality, many aircraft that transport passengers are also transporting cargo, and dangerous goods may very well be present in that cargo. Here is some information on how this is possible.
Hazmat Air Shipping: What It Means to Transport Dangerous Goods
Any accident involving a passenger aircraft certainly prompts more media coverage and consequently more public attention than one involving a cargo aircraft. With that said, all air safety regulations are designed and intended to protect the life of every person on board, the public at large, and the aircraft itself. The dangerous goods regulations have evolved over many years into what they are now, developed by not only experts in dangerous goods safety, but also experts from the modal industries which transport dangerous goods, whose valuable input and contributions are essential in establishing the mode-specific limitations.
The restrictions for carriage of dangerous goods by air are the most restrictive of the modal regulations, and the restrictions for dangerous goods carried by passenger aircraft are especially conservative. In the event of an in-flight dangerous goods incident or emergency, resources for emergency response are limited. The first actions of the crew will be to try to contain the emergency as much as is possible, and to get the aircraft safely on the ground. There, it can be quickly evacuated, and many more emergency resources are available.
On a passenger aircraft, cargo is typically loaded in a cargo compartment that cannot be accessed during the flight. It is different with cargo aircraft where the cargo loading can be configured in numerous ways to allow accessibility – i.e., where a crew member can get to it, handle it, and relocate it away from other cargo if size and weight permit. It is this accessibility factor that results in the much more limited types and amounts of dangerous goods permitted for transport on passenger aircraft.
The 25/75 kg Rule
The United States takes this philosophy a bit further in the limitations of 49 CFR §175.75, fondly known in the airline industry as the “25/75 kg” rule, which are also outlined in U.S. Variation USG-13(d) of the IATA Dangerous Goods Regulations (DGR). This rule limits the overall amount of dangerous goods permitted to be carried on passenger aircraft to 25 kg net weight of dangerous goods, and an additional 75 kg net weight of Division 2.2 non-flammable gas loaded in any inaccessible cargo compartment on a passenger aircraft. (A typical configuration of a passenger-carrying aircraft will have 2 baggage/cargo compartments – both inaccessible in-flight.)
These restrictions do not apply to:
- Division 1.4S UN 0012, UN 0014, and UN 0055 prepared as Limited Quantity/ORM-D in accordance with 49 CFR §173.63(b). (This specific provision is irrelevant to IATA shipments as LTD QTY provisions are forbidden for these UN numbers in the IATA DGR)
- Dangerous goods in Class 9
- Articles of UN 3528 (Engine, internal combustion, flammable liquid powered OR Engine, fuel cell, flammable liquid powered OR Machinery, internal combustion, flammable liquid powered) or UN 3529 (Engine, internal combustion, flammable gas powered OR Engine, fuel cell, flammable gas powered OR Machinery, fuel cell, flammable gas powered)
- Dangerous goods in Limited Quantities or Excepted Quantities
- Aircraft batteries (belonging to the operator) carried as items of replacement
This section of 49 CFR also establishes quantity limits for certain dangerous goods that are loaded inaccessibly on cargo-only aircraft. However, cargo aircraft can accommodate many more loading configurations, and airline personnel can plan the cargo load following these restrictions.
This is U.S. law – and it applies to the transport of dangerous goods by air to, from or through all territory of the United States. It also applies on all U.S. certified aircraft, regardless of where they are operating in the world.
Why Does This Rule Matter to Shippers?
Some quantities of dangerous goods may be shown in the IATA DGR as permitted on passenger aircraft. However, in reality, they may not be permitted to be transported on passenger aircraft in the U.S. due to this restriction. Take for example:
- UN 1263, Paint, Class 3, Packing Group III, one package containing 50 L
According to the IATA DGR, up to 60 L net quantity per package is permitted to be transported by passenger aircraft. However, Class 3 is not one of the exceptions to the “25/75 kg” rule as it applies to passenger aircraft. Not only that, but 50 L of paint will have a net weight of greater than 25 kg. There is not a place on a typical passenger aircraft where this package can be loaded and transported in compliance with §175.75.
Remember – this is a U.S. variation that is more restrictive than the IATA Dangerous Goods Regulations. In this case, the requirements of U.S. 49 CFR supersede the international standards. (And the U.S. 25/75 kg limits are total cargo compartment quantity limits – not package quantity limits.)
So to summarize: shippers, be aware of this rule and how it might affect the way you prepare your passenger aircraft shipments. Forwarders, be mindful of these restrictions when you book your cargo. And passengers, there may indeed be dangerous goods cargo in the passenger aircraft you are traveling on. There is no need to be alarmed: you can rest assured that your safety is always our top priority.
Undergo Hazmat By Air Shipping Training Today
Anyone involved in dangerous goods transportation must understand the regulations regarding when shippers may and may not transport dangerous goods on passenger aircraft. These may seem complex, as well as the rest of the IATA DGR, which is why all hazmat shippers are also required to receive training. Hazmat University provides online programs designed to enable both new and experienced shippers to acquaint themselves with all the regulations for shipping hazmat by air. When you complete and pass the hazmat shipping by air course, you will be better equipped to discern courses of action for these and other situations in the transportation process. Earn your IATA certification with Hazmat University. Start by visiting us online today.
