Rosie Bottone is an experienced hazardous materials trainer and subject matter expert with Lion Technology, and an instructor for Lion's Multimodal Hazmat Shipper Certification Workshops. Meet 49 CFR, IATA DGR, and IMDG Code hazmat training mandates in Kansas City, Detroit, Cincinnati, Pittsburgh, and Chicago before 2019 ends.
Dry ice is not regulated by the DOT as a hazardous material when shipped by ground
. But if you’ve ordered flower arrangements and cakes to be shipped overnight for your big birthday bash, the suppliers are going to have to keep those flowers fresh and treats cold for the airplane ride.
Dry ice – also named “Carbon dioxide, solid” with UN identification number 1845 – is
regulated by air as a miscellaneous Class 9 dangerous good.
Why is Dry Ice Hazmat by Air?
What makes dry ice potentially dangerous? As the dry ice sublimates, it releases gas that can build up enough pressure inside a package to cause an explosion. As gas is emitted in a confined space like an airplane, it displaces air and can cause suffocation. In addition, dry ice is a cryogenic; contact can cause severe damage to skin.
If you’re ordering Maine lobsters for your birthday party, the supplier will not
use dry ice to keep them cold. That suffocation problem from displacing oxygen will doom the poor critters before they get to you!
The following is a brief overview of the requirements for shipping carbon dioxide, solid (dry ice) by air with contents that are NOT dangerous goods.
Packaging Dry Ice for Air Transport
According to the International Air Transport Association Dangerous Goods Regulations
(IATA DGR) packing instruction 954, the packaging containing dry ice must be designed and constructed in a way to permit the release of carbon dioxide gas, so the package doesn’t rupture from a build-up of pressure.
One way to accomplish this is to not tape all the seams. UN specification packaging is not required.
For its 2020 edition of the Dangerous Goods Regulations
(DGR), IATA updated the acceptance checklist that air carriers use to accept dry ice air shipments. See the updated acceptance checklist here
Marking and Labeling Dry Ice for Air Transport
In addition to the hazard class 9 label; and the UN identification number, the proper shipping name, and the To and From address, the net weight of the dry ice must be marked on the outside of each package. (If the packages are inside an overpack, the total quantity of dry ice must be indicated on the outside of the overpack.)
Shippers Declaration Not Required
Since the dry ice is accompanying something that does not require shipping papers, a Shippers Declaration is not required. However, the air waybill or alternative shipping paper must show the following in this order:
- UN 1845 Carbon Dioxide, solid (or Dry Ice);
- The number of packages; and
- The net weight of the dry ice in each package.
Hazmat Training to Ship Dry Ice
If you ship dry ice by air or vessel, hazmat training is required for employees who can affect the safety of your shipments in transport (see 49 CFR 172.704).
For personnel who package, mark, label, load, document or sign shipping papers for dry ice shipments, the Shipping Dry Ice Online Course
is built to satisfy hazmat training requirements in 49 CFR, the IATA DGR, and the IMDG Code.