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What are State Variations in the IATA DGR?
State variations differ from the typical regulations applied in the IATA Dangerous Goods Regulations. Non-compliance with these variations frequently leads to rejected shipments and fines when shipments are transported to, from or within a country that has a state variation filed.
What is State Variation USG-13?
Chapter 2.8 of the IATA DGR contains a crucial section that is often disregarded but has significant importance, namely the state variations. State variation USG-13 in the IATA DGR points to 49 CFR 175.75 (Quantity limitations and cargo location). USG-13, a US variation, is commonly neglected by shippers, resulting in numerous rejected shipments and frustrated shippers who were unaware of it for various reasons.
The basic synopsis of USG-13 is that a shipper can prepare a shipment within passenger aircraft limits under table 4.2 of the IATA DGR, but must check the restrictions under USG-13 to see if further limitations are applicable.
When does USG-13 apply?
USG-13 applies to passenger aircraft traveling from, to, or within the United States jurisdiction. This state variation calls for the limiting consignments shall not exceed 25 kg of dangerous goods (solids and liquids) or 75 kg net quantity of non-flammable gas. Additionally, for liquid dangerous goods, it is important to note that one liter is equivalent to one kilogram for the purposes of this regulation.
It is important to highlight that these limitations are mandatory, regardless of any limitations specified for passenger flights in the IATA Dangerous Goods Regulations. The safety of passengers and crew members on any flight should always be of utmost priority, and following these limitations is one way to ensure this. Failure to comply with these regulations can have serious consequences, including the rejection of the shipment and legal penalties.
It is also crucial to note that the 25 kg limit for dangerous goods applies to each individual compartment on the aircraft, and not just the overall consignment.
When Does it Not Apply?
Fortunately there are a number of situations where USG-13 does not apply, which are outlined in 49CFR 175.75 (e).
For transport aboard cargo aircraft, the requirements of paragraphs (c) of this section do not apply to the following hazardous materials:
Class 9 (examples include ID8000, Consumer Commodity and UN3082, UN3077)
UN Numbers UN0012, UN0014, or UN0055 also meeting the requirements of § 49CFR 173.63(b)
UN Numbers UN3528 or UN3529
Limited quantity shipments
Excepted quantity shipments
Alternative solutions to USG-13
If the shipment is further restricted under USG-13 the freight forwarder / logistics company must book the hazardous material shipment on cargo flight leaving or entering the United States. This can usually be accomplished by having the shipper send the shipment without an overpack provided that the packages meet the 25 kg / 75 kg limitation for inaccessible compartment requirement.
If that is not possible the logistics company must break the shipment up to multiple packages and possibly multiple air waybills to keep within the limits of those that are outlined in USG-13. This is not typical but some freight does need to move to a consignee that is only serviced by passenger aircraft.
If you have any questions about this state variation or anything dangerous goods related please contact DGM New York or DGM Philadelphia to speak with one of our knowledgeable dangerous goods specialists.
