Make it your Mission to Look at Special Provisions

ICC_IATASpecialProvisions

Make it your Mission to Look at Special Provisions  

If you are familiar with shipping dangerous goods by air, I’m sure you have spent time in the “blue” pages of the IATA Dangerous Goods Regulations, known as the List of Dangerous Goods located in section 4.2. Here is where you will find important information such as the hazard class, proper shipping name, as well as the relevant packing instructions to reference before shipping your dangerous goods. But before you look to choose the correct label and UN rated packaging and ship it off to its destination, be sure to check column M to see if there is any special provision referenced that may impact your dangerous goods shipment.  

What are Special Provisions?  

Essentially, special provisions are additional information located in IATA that are relevant to the dangerous goods you are looking to ship. When you are looking at the Dangerous Goods list in Section 4.2 in IATA, if you look at column M, you may see a code which begins with the letter A and is followed by a number. For example, if you are shipping UN1486, Potassium Nitrate, in column M you will see it says A803. In some cases, there will be multiple special provisions listed such as Lithium-Ion Batteries, and in other cases there will be no special provisions listed at all. If there are special provisions listed for your dangerous goods, it is important that you check all of them to make sure you are fully compliant.  

Where Can I find the Special Provisions? 

When you go to section 4.4 in IATA, you will find each of the special provisions listed in Column M. For example, as mentioned above, UN1486 Potassium Nitrate, which is a packaging group III dangerous good, refers us to A803 in column M. When you go to section 4.4 in IATA, you have to search for A803. Once you find it, it says that substances assigned to this entry must be packaged in a PG II UN specification packaging. In this case, this is very pertinent information because Potassium Nitrate has a packing group III.  If you had not seen this special provision and shipped it in a PGIII approved (Z rated) packaging, it would not be compliant. There are also some cases where Special Provisions can provide you with relief. For example, as mentioned in one of my previous blogs, Special provision A197 provides relief when shipping marine pollutants under certain circumstances.  

Do I need to Reference Special Provisions on My IATA Shippers Declarations? 

Per IATA 8.1.6.9.4(a), it lists 16 special provisions that would have to be referenced under the Authorization column on your shipper’s declaration if it is applicable. Those special provisions are listed below: 

A1, A2, A4, A5, A51, A81, A88, A99, A130, A190, A191, A201, A202, A211, A212, A331. 

There may be times when the Special Provision is not applicable. For example, if you are shipping a UN3480 Lithium-Ion battery and look at all of the special provisions, one of them listed is A88. Special Provision A88 is for Prototype batteries. If you are not shipping a prototype battery it wouldn’t be applicable to your shipment, so you wouldn’t need to reference SP A88 on your shipper’s declaration. If you are looking for training in the IATA regulations, feel free to contact us.

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Michael Zendano

Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Regulatory Packaging Expert where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.

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