Case Study: IATA Air Shipment – Including Common Mistakes for Single or Combination Packagings & Overpacks – Featuring Upcoming Changes for UN1197, Extracts, Flavoring, Liquid

By Terry Poland, Principal Instructor and Consultant

We recently helped one of our customers with an interesting shipment traveling by air from the US to South Korea. As it turns out, their shipment of UN1197, Extracts, Flavoring, Liquid, just happens to be up against a regulatory change of the proper shipping name which will become effective in 2023. Moreover, the particulars of the packaging turned out to be a real head-scratcher. Is it a combination package or an overpack? Does the UN specification mark have to be removed if it is used as an overpack? Will carrier readily accept single packagings and or overpacks? Read on to learn the answer to these important details.

In a nutshell, the proper shipping name for UN1197, will be changed to simply “Extracts, Liquid” with no other changes to the description, class, packing group, packing instructions, quantity limitations or special provisions. Moreover, UN1169, Extracts, Aromatic, Liquid, is being removed to consolidate materials with this common description (see IATA DG List excerpt below). These changes will be shown in the 2023 Edition of IATA and in the 41st Edition of IMDG. As of now, we are not sure when the DOT change will happen, but it will eventually.

While examining this case study, all the basic requirements had to be assessed including identification, classification, packaging, marking, labelling and documentation and more. Moreover, many additional details involving packaging selection (single versus combination packaging) and the use of overpacks had to be examined very carefully to meet the IATA/ICAO air requirements. Consequently, this article presents an overview and summary of what we discovered while evaluating this shipment using the standard seven-step method for processing dangerous goods as follows.

  1. Identification – Proper Shipping Name (with technical name for N.O.S. entries) & UN/Identification Number.
  2. Classification – Hazard Class and/or Division (subsidiary hazards, if any) & Assignment to Packing Group (PG I, II or III, if applicable).
  3. Packaging – UN Specification, Limited Quantity (LTD QTY), Excepted Quantity (EQ) and/or other exceptions granted by special provisions or packing instructions; use of overpacks.
  4. Marking – Proper Shipping Name, UN/Identification Number, From & To Addresses, Quantity (if applicable), other shipment-specific markings as required.
  5. Labeling – Primary & Subsidiary Hazard Labels & Handling Labels (Orientation Arrows, CAO, others as applicable).
  6. Documentation – Shipping Paper (Dangerous Goods Declaration, Transport Document, Air Waybill, Bill of Lading, etc.).
  7. Other Matters (Special Provisions/State Variations/Operator Variations/Placarding/Routing)

Step 1 & 2: Identification & Classification

Basic Description: UN1197, Extracts, Flavoring, Liquid, Class 3, PG III (not a DOT hazardous substance or marine pollutant)

Step 3: Packaging

Summary: A total of 160 L of the material identified as UN1197, Extracts, Flavoring, Liquid, is presented and packed into ten (10) UN approved plastic drums (UN 3H2) with 16 L each; these are each then overpacked into individual fiberboard enclosures creating ten (10) total overpacks also with a total of 16 L each.

  • Total quantity of material = 160 L
  • Single packaging used = 10 plastic drums (UN 3H2) x 16 L each
  • Note: Each drum will be placed inside a strong fiberboard box deemed to be an Overpack enclosure, effectively creating 16 total Overpacks; all 10 Overpackswill then be placed on a wooden pallet and shrink wrapped together.
  • Total net quantity per Overpack = 16 L each
  • Overpacks identified as “A1, A2, A3, A4, A5, A6, A7, A8, A9, A10”
  • IATA Packing Instruction 355 allows 60 L per package and allows for both combination and single packaging and is Passenger (PAX) & Cargo Aircraft Only (CAO).
  • IATA Packing Instruction 366 allows 220 L per package and allows for both combination and single packaging but is Cargo Aircraft Only (CAO).
  • Operator Variations should be checked to see if they will accept combination packagings on passenger aircraft.

Step 4: Marking

Before beginning the process of package marking, IATA 7.1.1 (b) states, “remove or obliterate any irrelevant mark already on the package.”  In this case, the shipper used fiberboard boxes marked with the UN specification code of “4G” which does not apply to this shipment.

Package Markings:

  • UN Number: UN1997
  • Proper Shipping Name: Extracts, Flavoring, Liquid
  • Shipper Name & Address: FROM
  • Consignee Name & Address: TO
  • Quantity Per Package: Net Qty 16 L
  • UN Specification Code:  UN Symbol/package type code (3H2)/PG I, II or III (X, Y or Z), relative density limit (i.e., 1.3), pressure (>95 kPa)  – verified by shipper.

Overpack Markings:

  • The word “Overpack,” Identification Number and Quantity each (i.e., “OVERPACK #A1, Net Qty: 16L)

Step 5: Labeling

IATA requires that any irrelevant labels on the packaging or outside of the overpack must be removed. Other than this, it is important to emphasize that there are no shortcuts when labeling packages within an overpack. To be sure, there is a temptation to only label (and mark) the outside of the overpack – especially in a situation where each package is individually overpacked much like an outer packaging of a combination packaging and is unlikely to be removed during transport. The bottom line is that all package labels must be clearly visible or reproduced on the outside of the overpack. Finally, even though there are single inner packagings that do not require the package orientation labels (upright arrows), IATA clearly states that these are required on the outside of overpacks containing single packagings with liquids.

Package Labels:

  • Class 3 Flammable Liquid Label (same surface and near the UN Number and Proper Shipping Name)
  • Cargo Aircraft Only Label only if IATA Packing Instruction 366 is used (applied to same surface and near the Class 3 Flammable Liquid Label)
  • Package Orientation Labels (upright double arrows on two opposite sides pointing in the correct direction) are OPTIONAL on the packages as they are considered single packagings

Overpack Labels:

  • Class 3 Flammable Liquid Label (same surface and near the UN Number and Proper Shipping Name)
  • Cargo Aircraft Only Label only if IATA Packing Instruction 366 is used (applied to same surface and near the Class 3 Flammable Liquid Label)
  • Package Orientation Labels (upright double arrows on two opposite sides pointing in the correct direction) are mandatory on overpacks containing packages with liquids whether they are single or combination packagings.

Step 6: Documentation

The shipper must provide standard documentation in the form of the IATA Shipper’s Declaration for Dangerous Goods (DGD). This document must be prepared with a minimum of two copies provided to the operator with the shipment (note, many operators require three copies). An excerpt from IATA, Figure 8.1.L, for multi-overpacks with identical contents is provided below to show the additional requirements and formatting. It is then followed by a truncated version of the DGD completed with the specifics for this case study.

IATA DGR Excerpt:

IATA DGD Sample:

Step 7: Other Matters (Special Provisions/State Variations/Operator Variations/Placarding/Routing)

  • The only Special Provision (SP) that applies to this shipment from Column M in the IATA DG List is SP-A3 which reads as follows below:

Essentially, this is a warning to shippers that materials listing in Column C of the IATA DG List, such as Class 3 (Flammable Liquids in this case), must be compared the properties of the material being shipped. In this case, the flash point of the chemical must be not more than 60 C and not less than 23 C to be considered as Class 3, PG III.  If the flash point were greater than 60 C, it would not be regulated according to IATA/ICAO standards (or US DOT for that matter).

  • State Variations for this shipment are not applicable as South Korea does not publish any variations directly affecting Class 3 shipments or UN1197 specifically.
  • Operator Variations would be dependent on the carrier selection in which case all variations published by the operator should be reviewed. Since this shipment is destined for South Korea, it is of particular importance to check the Operator Variations in IATA, Section 2.8.3.  For example, Asiana Air (code OZ) and Korean Air (code KE) have variations on file that essentially do not allow for single packagings containing liquids to be accepted unless they are overpacked in a “strong wooden crate” meaning that this shipment would not be acceptable as the overpack is fiberboard. Even United Airlines, which does offer service to South Korea (code UA), does not allow single packagings even if overpacked! See the Operator Variations noted below:
  • In the US, placarding requirements for Class 3 materials essentially becomes effective (for non-bulk packagings such as this shipment) when more than 1,000 pounds is offered per shipment (container or truck load) at one time.
  • Carrier routing for flights providing Cargo Only Aircraft should be reviewed for packages prepared as such. In this particular case study, the shipment was prepared under IATA PI 366 (CAO). However, it should be noted that it would be possible to use IATA PI 355 (Passenger & Cargo Aircraft) if the shipper wished.

Packaging Selection Narrative:

The packaging selection in this case study is the most complex part of the process. Both combination and single packagings are authorized, and options to ship the material on passenger and cargo aircraft (PAX & CAO) or cargo aircraft only (CAO) are possible based as shown in IATA Packing Instruction (PI) 355 and PI 366 respectively. The complexity of using an overpack is also discussed in this summary.

IATA PI 355 (PAX & CAO):

In evaluating IATA PI 355 for transport aboard passenger and cargo aircraft, it is important to note that the eventual overpack “enclosure” just happens to be a UN approved 4G fiberboard box. But this does not automatically authorize its use as combination packaging under PI 355 even though the 4G is listed as acceptable. The fact remains that a qualified inner packaging must also be used together with a qualified outer packaging. To meet this standard, the inner packaging must first be of the type authorized and within the quantity limits shown in PI 355. Secondly, it must also be authorized in the package assembly/closure instructions provided by the packaging supplier to the shipper. Since these plastic drums are 16 L each, they are not within the packing instruction quantity limit of 10 L each for plastic inner packagings. Therefore, combination packaging would not be authorized for air shipments in this configuration regardless of what the package assembly/closure instructions may allow. In summary, these plastic drums are qualified as acceptable single packagings and with a total limit of 60 L each. Since these plastic single packagings (inside the fiberboard overpacks) are clearly marked as UN 3H2, and they are within the package limit of 60 L, it means that they can be used according to PI 355 and the shipment would qualify for transport aboard passenger and cargo aircraft. On a final note, even though that technically this shipment is authorized aboard passenger-carrying aircraft in the configuration and quantity presented, it is a common Operator Variation (airline policy) to disallow single packaging on passenger-carrying aircraft regardless of what the regulations authorize. For this reason, it is prudent to process the shipment using the CAO packing instruction (PI 366).

IATA PI 366 (CAO):

In evaluating IATA PI 366 for CAO carriage, it is again important to note that the eventual overpack “enclosure” just happens to be a UN approved 4G fiberboard box. But this does not automatically authorize its use as combination packaging under PI 366 even though the 4G is listed as acceptable. To be sure, the same hurdle exists in using a combination packaging as plastic inner packagings are limited to 10 L each. In summary, this means that the plastic drums must be qualified as acceptable single packagings in PI 366 and must be within the total package limit. Since the plastic drums are clearly marked as UN 3H2, and they are within the package limit of 220 L, they can be used according to PI 366 and the shipment would qualify for transport aboard cargo aircraft.

Overpack Discussion:

In this case study, we have a unique situation where individual plastic drums (which are UN approved 3H2, single packagings) are used and are overpacked inside of fiberboard boxes (which just happen to be marked as UN approved 4G). Because of this, the temptation for shippers to identify the complete packages as UN specification “combination packagings” is a common misconception. Moreover, if left to this distinction, when ten such packages are combined on a pallet and enclosed with shrink wrap, the pallet would appear to represent a single Overpack. However, this shipment must be declared as ten (10) overpacks as each drum meets the description and requirements of the applicable packing instruction as individual packages (single packagings) which were arbitrarily “enclosed” into strong fiberboard boxes (that just so happened to be mark as UN 4G symbol and code).

To understand this better, it may be helpful to start with the definition of the word “Overpack” as a refresher to this topic.

Overpack: This is an enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly packed, marked, labelled and in proper condition as required by these Regulations.

While it may seem redundant to mark the packages and overpacks with all the same markings and labels, the regulations require it. However, pay close attention to the package marking requirements versus the overpack marking requirements. There are some very subtle differences such as arrows are not required on the single packagings (plastic drums) inside of the overpack.