Are You Shipping Hazmat? Also, Bonus Video on Shipping Lithium Batteries

Aircraft parts are full of hazmat:

  • Batteries;
  • Squibs;
  • Self-inflating emergency equipment;
  • Compressed gas tanks;
  • Passenger service units with oxygen generators;
  • Residual fuel in a component (even if it is just a small amount);

These are just a few examples of the sort of hazmats that aircraft parts distributors see every day. I have received calls from ASA members whose business models did not involve hazmats; but then they received an air carrier inventory with “extra items.” Extra items that included hazmats.

If you receive unwanted or unexpected hazmat from a business partner, you cannot simply return it without thought. You need to make sure that even a return shipment meets the requirements of the hazmat rules. Civil penalties for getting this wrong can easily exceed $100,000. This means that you need to have trained personnel to identify hazmats, and you need to have trained personnel to classify, package, label and ship the package to wherever it needs to go (the training is required and defined by regulation).

Our next hazmat training class is scheduled for October 4-5, 2022. ASA members get a discount and there is also an additional early registration discount. The deadline for the early registration discount is September 13, 2022.

Our training is offered as a live, online class. You can take the class from the comfort of your desk without any travel. Because it is a live class, we can answer your questions in real-time to make sure you are getting everything you need from the class.

Lithium Batteries

If you are shipping lithium batteries, then you may want to check out our free video on shipping lithium batteries. This video is posted on Youtube.

Make sure you are watching the video for the correct year! We started posting these videos in 2021 and each year we post an updated video reflecting the changing rules surrounding lithium battery shipments. The year is part of the title.

Also please note that the training video is meant to be a supplement to our training class. It is a useful guide for shipping lithium batteries but it is not stand-alone training and it does not take the place of training that meets all of the regulatory requirements.

Shipping Lithium Batteries – Updated for 2022

Lithium batteries can be complicated to ship by air. Most people use the IATA Dangerous Goods Regulations but the lithium battery packing instructions in the IATA book are not like most of the other packing instructions.

To make it easier to ship lithium batteries by air, we’ve prepared a video that goes over the special packaging, marks, labels, and documentation commonly required when shipping lithium batteries by air.

There are changes for 2022 – including the elimination of section II options for shipping batteries under packing instruction (PI) 965! Only section IA and section IB remain in PI 965. But there are still section II instructions in other packing instructions (like PI 966 and PI 967 for batteries packed with and in equipment). So the whole process is just that much more complicated.

As always, I will warn you that the video is only a supplement to our hazmat training. There are required training elements that are covered in the class and are not addressed in the video. But our next class will be held April 19-20, 2022 and you can find out more here. [if you don’t see this until after April 19 then feel free to sign up for our next class]

You can watch the video on youtube or just watch here on our site:

Lithium Battery Shippers Video

Shipping an “As Removed” Oxygen Generator

Recently, an Association member asked us whether one is allowed to ship “As Removed” oxygen generators.

An “As Removed” oxygen generator can be expended or unexpended.  A critical distinction for oxygen generators is whether they have been expended (this is the real question – not whether they are “as removed”).  An expended oxygen generator is typically forbidden from transportation on an aircraft but is permitted to be shipped by highway, rail or maritime transportation.  49 C.F.R. § 173.168(f)(2)(ii).

Oxygen generator typically have a manufacturer’s expiration date printed on them.  It is also illegal to ship an oxygen generator by air after the manufacturer’s expiration date. 49 C.F.R. § 173.168(f)(2)(i).

In the United States, an unexpended oxygen generator (assuming it was unused, undamaged, and prior to the manufacturer’s expiration date) would be eligible for transport by air consistent with section 173.168.  This is true even when the oxygen generator has been removed from an aircraft.  A similar rule applies to international transportation subject to the ICAO rules – the ICAO standards forbid transport by air of oxygen generator that are unserviceable, have been expended (“used”) or have passed the manufacturer’s expiration date.  ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, Special Condition A111.

Even when an oxygen generator is permitted to be shipped by air, it is typically limited to ‘cargo aircraft only’ configurations  – you can only ship an oxygen generator by passenger aircraft if you receive a special permit that allows this unusual configuration.

If you have an oxygen generator that cannot be shipped by air because of its configuration (e.g. expended, unserviceable, beyond manufacturer’s expiration date, etc.) then you should be looking at ground, rail or maritime transportation as options.

Are Freight Costs for Rotor Blades About to Change?

In mid-December the Commodity Classification Standards Board (CCSB) issued a Notice of Proposed Amendment to the National Motor Freight Classification.  Specifically, the proposed amendment seeks to reclassify helicopter rotor blades and leading edge coverings, and make clarifications regarding aircraft propeller blades.  Those distributors that sell and ship rotorcraft blades and leading edge coverings may wish to review the proposed amendment to determine the potential cost effects of the proposed reclassifications.

The National Motor Freight Classification is a voluntary standard that assigns classes based on a product’s transportation characteristics, and provides a comparison of those products when they are shipped via motor carrier.  The transportation characteristics of a product are determined based on its dimensions, density, ease of handling, and potential liability due to damage or other factors.  Products once classified are assigned a class name (e.g., Class 50; Class 100; Class 300) with higher class names generally having a greater cost to ship.

The provisions pertaining to leading edge coverings and rotor blades were initially developed in the 1950s.  Leading edges were assigned item number 12110 and rotor blades 12130, and freight classes 70 and 100, respectively.  In the intervening years, technological advances in manufacturing and materials have resulted in leading edges and blades becoming longer and less dense.  The effect of these advances is that the original freight classes assigned to the item numbers no longer accurately reflect the shipping characteristics of leading edges and blades of increasing length.

The proposed amendment suggests that as edges and blades grow longer and less dense, the costs of handling, practicalities of stowing, and potential liability due to damage increases, and therefore items of increasing length should be assigned differing freight classes to reflect the varying transportation characteristics.  The amendment therefore makes two proposals:  First, it would cancel item number 12110 pertaining to leading edges and redefine item 12130 to include both rotor blades and leading edges.  This is due to the understanding that leading edges and rotor blades have similar transport characteristics.

Second, the amendment would assign different freight classes to blades of increased lengths as follows:

Greatest Dimension Proposed Class
Exceeding 288 inches 300
Exceeding 192 inches but not exceeding 288 inches 175
Exceeding 96 inches but not exceeding 192 inches 100
Not exceeding 96 inches 92.5

These proposed classes greatly exceed the current freight classes assigned to leading edges and blades, and as such have the potential to substantially increase transportation costs.  It should also be noted that the proposed classes exceed the class suggested by CCSB’s own density guidelines.

A final element of the proposal would also specifically exclude rotor blades and edges from category 12280 pertaining to aircraft propeller blades to avoid confusion or ambiguity.

Persons with information regarding the transportation characteristics of rotor blades and leading edge coverings are invited to submit a written statement to CCSB prior to their meeting on Tuesday, January 28, 2014.  Information regarding this proposal may be found at CCSB Docket 2014-1.  Distributors should take the opportunity to review the docket and data therein to determine what potential effects such reclassifications would have on their shipping and transportation costs, as well as to determine if the proposed classes are reasonable based on the transport characteristics of the articles.