This post was originally published in January 2018 and has been updated in September 2020 for accuracy.
How should you provide quantity on a shipper’s declaration for an engine?
Generating a shipper’s declaration for an engine isn’t exactly new to me. I have been creating shipper’s declarations for engines since the very first time I stepped into the DG packaging world, and that was a long time ago. Therefore, it hit me pretty hard when a client’s shipment, containing an engine, was rejected by their air carrier.
Engines and UN Numbers
For many years the UN number for engines and vehicles were the same and it was classified as hazard class 9. Just recently it was changed so that each type of engine has their own UN number and hazard class. Therefore, internal combustion engines containing flammable liquid is classified as UN3528 and falls under hazard class 3.
My client said there was a small amount of diesel fuel inside (it wasn’t drained). Based on this I classified his engine as UN3528. He provided me with the completed shipment detail form which provided me with all the details of the shipment including net weight of the engine and the amount of fuel inside the engine.
Quantity of the Engine on the Shipper’s Declaration
I started to work on the shipper’s declaration and had to stop at the “Quantity and type of packing” section. There wasn’t an immediate measurement I could use for the engine. As per column “J” and “L” of the IATA regulation it says, “no limit.” I read packing instruction 378 and it didn’t indicate the quantity measurement either.
So I started to think about how I was going to present “quantity”.
Would I use the weight of the engine or the quantity of fuel inside the engine?
I started to rationalize the conundrum and came to the conclusion that the reason the engine is considered a dangerous good is because it contains flammable liquid. Otherwise it would be just a piece of metal; hence, why it is classified as hazard class 3 and class 3 is always provided in litres, because it is a liquid.
Therefore, I prepared the shipper’s declaration stating “1 wooden box x 10 L” in the “Quantity and type of packing” column.
What’s the Hold Up?
3 days later, I get a voicemail from the DG Agent of the carrier transporting the engine that the shipment is rejected because the quantity must be in “kg”. Thankfully he left me a direct number to call him back which I did.
The agent who left me the voicemail wasn’t on shift so I spoke to another agent who knew about the rejection. So, I asked him (in a nice way) why they want it stated as “kg” and not “L”? I gave him my rationalization for providing the quantity in “L” and he agreed with me that it made complete sense; however, since his colleague rejected it he can’t override it. But he said he will check with their senior colleague who is also their trainer about this and he’ll call me back within an hour and he did. Yes, that shocked me too.
He said their trainer was even puzzled because there isn’t any clear indication on how the quantity should be presented. However, the trainer said they want it in “kg,” because it is the whole engine that is considered dangerous goods and he will bring this matter to the IATA folks at the next meeting. At this point I didn’t want to debate anymore on this subject to further delay the shipment; therefore, I revised the declaration. However, I still think my rationale makes more sense. If you took the element of the fuel away from the engine, the engine wouldn’t be considered dangerous goods.
Not that I am an engine expert, but without the fuel tank it’s just a piece of metal.
Check with the Carrier First
So folks if you are shipping an engine containing flammable liquid check with the carrier first as to how they want the quantity provided on the declaration to prevent delays.
We have all the products, services and training you need to ensure your staff is properly trained and informed.
2021 (62nd Edition) IATA Dangerous Goods Regulations,
Perfect Bound, English
Shipping by Air Declaration Form