It’s early September, the frost is on the pumpkin, and everyone in the air transport food chain is holding his or her breath for the upcoming changes to the annually published IATA DGR.
System and database admins pray changes can be accommodated in system logic, training managers revamp their training materials, and airlines, handlers, and shippers alike struggle in communicating these changes to their staff in order to prevent rejections of shipments not in compliance with the latest edition.
No Grace Period!
While changes in the UN Model Regulations will prompt changes in all modal regulations, the maritime sector (covered by the IMO’s IMDG code) has a grace period of one year (meaning the changes which went into effect January 1st, 2015, must be implemented until December 31st, 2015) and ADR (the European road transport framework) still allows for 6 months (changes had to be completed effective June 30th, 2015).
It’s just the air transport sector—actually the most demanding transport mode—with a DG acceptance document covering any and all packages that do not have a grace period.
What’s more, while all other modes update in bi-annual cycles, following the UN Model regulations, the air mode doesn’t. Although the legal base, ICAO’s “Technical Instructions for the Safe Transport of Dangerous Goods by Air” is also published biannually, in excess of 98 percent of DG shipments transported by air are prepared in accordance with IATA’s “Dangerous Goods Regulations.”
For this reason, the biannual task of incorporating a—sometimes more, sometimes less—changed regulatory framework is an annual one for the air transport sector, and has always been.
Changes You Need To Know
So what’s going to change?
Actually, not much.
As it is, IATA (most often in even number years, when there is no new legal foundation document cum ICAO TI) produces a document noting plenty of housekeeping—replacing one term here and shuffling a few sentences there.
For example, the upcoming 57th edition of the IATA DGR going into force January 1st, 2016, will add a definition for the term “consolidation.”
Also, the provisions applicable to the carriage of lithium battery-powered devices are clarified somewhat, although an expressed requirement has been added that devices in checked baggage must be secured against accidental activation.
It is also made clear that so-called “power banks” are not really devices as their primary purpose is to provide power to another device and thus must be treated as stand alone batteries and be moved in carry-on baggage only.
New to DGR and a dubious improvement at best is the requirement that Dangerous Goods permitted within passenger and crew baggage now appear in alphabetic order within Table 2.3.A (which is summarizing what is permitted within passenger and crew baggage and one of the core documents in the IATA DGR) and the indicator boxes (Yes, No, N/A) have moved from the left to the right.
More than a few training professionals and airline staff we talked to have indicated that they find the new format of table 2.3.A “irritating.”
New state variations from Nepal and Venezuela will likely not affect the industry much, but the significant increase in operator (airline) variations, especially regarding total or partially embargoing Lithium batteries, will be something shippers of Lithium batteries will find hard to accommodate and incorporate into their shipping procedures.
IATA Housekeeping Works S/H
The housekeeping IATA has done with the packing instructions is actually beneficial since it improves structure and adds clarity. The latter is important, since IATA has dubbed their DGR a “field manual of the industry” and such a field manual must be readily comprehensive even to a less seasoned user.
Probably the most noteworthy change is that IATA moves to prohibiting multiple packagings of devices incorporating Lithium batteries that are not subject to any marking or labeling requirements within the provisions of Packing Instructions 967 or 970 into likewise unmarked overpacks; however, the practice will be tolerated until January 1st, 2016 (unless particular airlines require otherwise).
It must be highlighted that another IACO DGP meeting is scheduled for Fall 2015, and depending upon whether or not the far-reaching suggestions brought forward by ICCAIA and IFALPA will find a majority of significant and fundamental changes applicable to the transport of lithium batteries may either come in the 58th edition of the IATA DGR for 2017 (in line with the 2017-2018 ICAO TI) or, unlikely but possible, in the form of an addendum.
FT has already covered what this joint initiative of ICCAIA and IFALPA is about here:
Pack It In
One clerical change which may have very far reaching implications is a change in Packing Instructions 965, 966, 968, and 969 covering the transport of Lithium batteries as such and when packed with equipment:
Instead of requiring that “cells and/or batteries must:
- be placed in inner packagings that completely enclose the cell or battery and then placed in an outer packaging;”
the 57th edition of the IATA DGR mandates that “cells and/or batteries must:
- be completely enclosed in inner packagings and then placed in an outer packaging.”
Although the meaning appears to be identical, some regulators see so-called “blister packs” commonly used to pack retail batteries not as qualifying inner packagings, since where more than one battery or cell is contained in a blister pack, the grouping does not enclose the individual batteries completely, although it does provide the required sufficient protection against short circuiting.
Here Is The Rub
As mentioned, although the changes in the IATA DGR are minimal and this fact will significantly reduce the workload for trainers, system admins, and other stakeholders in the air transport chain, the 56th Edition of the IATA DGR is in force until midnight of December 31st and the 57th Edition effective 0:00 h on January 1st, which makes the switch from the 56th to the 57th edition without any grace period a significant but well-known challenge (since it is repeated annually).
To many in the air cargo business, the wonder is why the entire air cargo industry should be required to purchase tens of thousands of manuals at a list price of US$319, and then air-ship these with a certain urgency between October and December.
Sure, the annual revamp of the IATA DGR is a practice that has been in place forever, but does a practice that has lived for decades, going back before the existence of the ICAO TI (whose 1st edition was published in 1983), need to continue in this form?
IATA has kept the prices of the 57th edition revamp at the 2015 cost level of the 56th edition, obviously responding to industry criticism that the price hikes in the past were too steep.
Still, IATA may be well advised to enter a dialogue with all stakeholders involved—which will definitely include the shippers—to move to biennial publication dates, plus addendums and corrigendums issued as required.
While this may remove some revenue from IATA and resellers, it might free up some funds within the industry that, hopefully, might be spent on industry safety initiatives.
Looking a bit deeper into the situation of IATA publishing just as longer product cycles have come into reality, perhaps a two-year validity of the DGR would also improve the effectiveness of training and allow stakeholders the ability to devote needed focus on core process items, rather than devoting time and money implementing minimum annual DGR changes.
The Good Work
It must be noted that IATA makes training (not just limited to the DG sector) available to non-developed nations at significantly less cost and the price of DGR manuals in certain non-developed areas are kept at bay; for example, the price of the Russian language version of the IATA DGR is about half the price of the English version.