By Andy Altemos, Senior Technical Advisor    November, 2007

The International Civil Aviation Organization’s (ICAO) Dangerous Goods Panel (DGP) has adopted revisions to, and completely reformatted the packing instructions appearing in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (“the ICAO Technical Instructions”). The revised instructions will be applicable under the Technical Instructions beginning from January 1, 2011. They will also be incorporated into the International Air Transport Association’s (IATA) Dangerous Goods Regulations from that date. Mr. Altemos details the history, and reasons for these changes, and the major changes that will be adopted. While there are objections to some of these changes, the DGP has made final decisions and these changes will have a major impact on ICAO’s technical instructions.

At an early November 2007 meeting, the International Civil Aviation Organization’s (ICAO) Dangerous Goods Panel (DGP) adopted revisions to, and completely reformatted the packing instructions appearing in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (“the ICAO Technical Instructions”). The revised instructions will be applicable under the Technical Instructions beginning from January 1, 2011. They will also be incorporated into the International Air Transport Association’s (IATA) Dangerous Goods Regulations from that date.

As a result of this decision, ALL of the current packing instructions applicable to dangerous goods in the ICAO Technical Instructions other than those in Class 1, Class 2 or Class 7, are to be revised and/or reformatted.

History and reasons for the changes
The decision to adopt the revised packing instructions culminated an effort by the DGP that extended over more than five years. It had its origins in the 1999 incorporation of the packing instructions into the UN Recommendations on the Transport of Dangerous Goods (“the UN Model Regulations”). While the original concept was to more closely align the packing instructions in the Technical Instructions with those in the UN Model Regulations, over the years the ICAO effort took on a life of its own.

Proponents of a more comprehensive revision argued that this would result in a more user-friendly system. It would remove existing anomalies, inconsistencies and irrationalities in the current packing instructions (in terms of, for example, the kinds of packaging authorized for various dangerous goods). And finally, it would provide a new structure that would facilitate the assignment of packing provisions to new dangerous goods in a logical manner.

The content and format of the draft revised packing instructions changed considerably as this effort progressed. After several years of work, and a number of iterations, in 2006 a draft of the revised packing instructions was placed on an ICAO public website for review and comment. Comments submitted on that draft were considered by an ICAO working group that met in Memphis in May of this year (see summary on pages 10 and 11 of the May/June 2007 issue of HAZMAT Packager & Shipper).

Major changes adopted
As a result of this review, and apart from a number of detailed changes to the draft packing instructions, the working group agreed that several more fundamental changes should be made. These included a decision to abandon the proposed new alpha-numeric packing instruction identification system and instead to employ a three-digit numbering system similar to the current system.

With regard to the greatly expanded use of absorbent material that would have been required under the draft revised packing instructions, it was decided to limit the requirement for use of absorbent material to combination packages containing Packing Group I materials. As an alternative to provisions in the draft instructions that would have required the use of liners in combination packagings for virtually all liquids, the working group decided to enhance the requirements for the closures of inner packagings (e.g., that secondary means of “positive” closure be employed). Further, it was decided that only when such secondary means were not used would a liner be required within the outer packaging.

Description of the changes
A revised version of the packing instructions then followed and, again, was placed on the ICAO public website for review and comment. It was this version of the packing instructions that was considered by the ICAO DGP at its meeting in early November. Significant changes incorporated into this draft of the packing instructions included the following -

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