Lion News March 2021

9 Ways the IATA DGR Differs from 49 CFR

Posted on March 18, 2021 by Roseanne Bottone and Roger Marks

It’s often said that baseball is a game of failure. Succeed just four out of ten times at the plate and you’re a Hall of Fame hitter.

Hazardous materials professionals are not so lucky. In our game, a single mistake can lead to supply chain delays, emergency releases, and costly civil penalties that increase every year. That’s especially true when you ship hazardous materials by air.

While it's not an exhaustive list, here are 9 ways the IATA Dangerous Goods Regulations (DGR) differ from the 49 CFR rules you’re familiar with if you ship hazmat by ground, to celebrate the start of the MLB baseball season. 


1. Shipping paper format

When you ship hazardous materials by highway, US DOT allows you to use any format you like for shipping papers, provided you include all the required information.

Air shippers must use a specific, standardized form to document shipments—the Shipper’s Declaration for Dangerous Goods.

2. Employee training required more frequently  

Every employee who can impact the safety of hazardous materials in transportation must complete hazmat training within 90 days of their hire date and be re-trained at regular intervals. 

US DOT's 49 CFR regulations require training for all hazmat employees once every three years (49 CFR 172, Subpart H). For employees who prepare or offer hazmat air shipments, the IATA DGR requires re-training every 24 months (IATA DGR 1.5). 

Learn more about who needs training on the IATA DGR requirements in our Dangerous Goods Training FAQ. 

3. Punctuation counts

Shipping papers for ground shipments must include a basic description made up of four elements: the UN or ID number, the Proper Shipping Name, the Hazard Class, and the Packing Group (in that order).

Punctuation is optional under the 49 CFR Hazardous Materials Regulations (HMR). You may put a comma between each of the basic description elements, but it’s not required. 

The air shipping regulations, on the other hand, require the use of commas to separate the elements of the basic description on the open format (computerized) version of the Shipper’s Declaration. You must also separate additional required information (e.g., the number and type of packages, quantity per package, and packing instruction) with double slashes (//) or a carriage return on this form.

4. Marking hazmat limited quantities

If you ship by ground, you probably know the limited quantity marking as a square-on-point that’s black at the top and bottom and white in the middle.

When you ship hazmat limited quantities by air, you use a different limited quantity marking. It’s similar to the black and white marking you know, but features a “Y” in the middle.

Limited quantity mark for ground transport Limited quantity mark for air transport

In addition, limited quantities shipped by air are not eligible for package marking and labeling reliefs granted to ground shipments. Limited quantity air shipments must be fully marked and labeled by the shipper as if they are fully regulated packages.

Learn more: The Shipping Limited Quantities and Consumer Commodities online course guides you through the requirements you must know to ship hazmat limited quantities by ground, air, and vessel. 

5. Quantity limits and indicating quantity

The per-package quantity limits for air shipments are much more restrictive than the limits for ground shipments.

Also, while US DOT requires the shipper to indicate the total quantity of material on shipping papers, the IATA DGR requires shippers to indicate the quantity “per package.”

6. An alternate ID number for consumer commodities (ID 8000)

Every proper shipping name for a hazardous material or group of materials is associated with a specific identification number.

The most widely used identification numbers for hazardous materials are United Nations ID numbers or “UN numbers” recognized around the world. A UN number is a four-digit identifier that is linked to transportation provisions, health and safety data, and emergency response information for a material associated with it. 

UN numbers are not the only kind of identification numbers used for hazardous materials, though. While used less frequently than UN numbers, two other kind of identifiers for hazardous materials are:

  • “ID 8000.” Usually associated with air transportation*, ID 8000 is an alternative identification number sometimes used to ship consumer commodities under specific circumstances. The number 8000 is used because UN numbers don’t go that high. ID 8000 is currently the only identification number for a hazardous materials that begins with “ID.”
  • “NA Numbers.”  In most cases, the North American (NA) number and UN number associated with a material are identical. When there is no UN number associated with a material, it may be assigned an NA number only.

The International Civil Aviation Organization (ICAO) implements regulations that govern hazardous materials/dangerous goods air transportation internationally. ICAO is a sub-agency of the United Nations. The Technical Instructions (TI) that ICAO produces are incorporated into the regulatory manual used by major air carriers and DG air shippers—the IATA Dangerous Goods Regulations or DGR.

7. Supplementing generic shipping names

US DOT indicates a “generic” Proper Shipping Name (PSN) with a “G” in column 1 of the 49 CFR 172.101 Hazmat Table. When you use a generic PSN, you must supplement it with a technical name of the constituent that predominately contributes to the hazard.

Star indicates generic shipping names in IATA DGRThe same rule applies to air shipments, but the IATA DGR List of Dangerous Goods indicates generic shipping names with a star icon instead of a “G.” 

8. More on supplementing shipping names

When you supplement your PSN with a technical name, DOT allows you to place the technical name after the PSN or at the end of the basic description. Not so for the international air shipping rules.

The IATA DGR states that the technical or chemical group name must be placed immediately after the PSN (IATA DGR

9. Withstanding vibrations

No matter what mode of transportation you use, your hazardous materials must be packaged to withstand the normal “rigors of transportation” like bumpy roads or extreme weather.

When you ship by air, your package must be able to withstand vibrations that can result from 1g to 8g acceleration.

10. Extra Innings!

Here’s one more difference to keep in mind before we call it a ballgame: The IATA DGR requires you to indicate quantity using the metric system. It is a common error for shippers to mistakenly indicate quantity using gallons or pounds instead of liters or grams.

So brush up on your metric conversions—or keep a cheat sheet handy. Now that you're familiar with some of the differences between 49 CFR and the IATA DGR, you are better prepared to knock your next shipping challenge out of the park! 

Live IATA DGR Hazmat Air Shipper Training

The average home run flies 400 feet. The average hazmat air shipment flies 1,300 miles.*  

Be confident your dangerous goods are packaged, marked, labeled, and documented in full compliance with the latest IATA DGR requirements for shippers. Build on your 49 CFR expertise and get required function-specific training when Lion presents the next Hazmat Air Shipper Certification Webinar.

*Source: Latest US Census Commodity Flow Survey data.

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