Before offering a dangerous good to an air carrier for shipment, the Hazardous Materials Regulations require YOU, the shipper, to correctly classify, package, mark and label the package to identify the hazard. You must also consider by which mode of transport you will ship your goods (i.e., ground, marine vessel, and aircraft). Remember that express and expedited shipping, like overnight, express, or even two- or three-day shipping, means there is a good chance your packaged goods may end up on an aircraft.

When shipping dangerous goods (e.g., lithium batteries or battery-powered devices, aerosols, oxygen cylinders) or flammable liquids (e.g., perfumery products or alcoholic beverages), review these steps to ensure your package is correctly packed and marked. 

Before you begin, note that some air carriers may have additional carrier-specific requirements, so always check with your carrier before offering your dangerous goods shipment. Air carriers may impose additional limitations or prohibitions. To help mitigate risk and increase safety in their operations, air carriers may reject certain dangerous goods or only authorize smaller quantities than the regulations allow. Always consult with your air carrier before shipping DG/hazmat. 

• These limitations and prohibitions result from air carriers’ safety and risk management systems to ensure safety in their operations. Air carriers work diligently to implement controls that meet their performance requirements for managing risk.
• Always remain transparent, communicate, and work with your air carrier.

Step 1: As a first step, think critically about your product. Does it fall under one of the Department of Transportation’s nine hazard classes? The Safety Data Sheet (SDS) can be a good starting point for determining if an item you are shipping might be a dangerous good. Typically, you can obtain the SDS from the manufacturer of the products you plan to ship by air. Check the transportation information section of the SDS. Pay particular attention to the specific information on shipments by air. Note that some products, like lithium batteries or electronic devices, may not have an SDS.

Even if you locate an SDS, you must still consider whether the product you are offering has changed. Have you modified it? Has it been damaged? Changes like these could indicate that a previous classification is no longer valid. 

If you are shipping a dangerous goods product, you are responsible for the correct classification.

A hazardous material or dangerous good is defined as a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 Code of Federal Regulations (CFR) § 172.101), and materials that meet the defining criteria for hazard classes and divisions in Part 173 of [the Hazardous Materials Regulations].

Step 2: If you determine an item is a dangerous good, the FAA recommends that you perform a needs assessment to determine which employees at your company will perform a hazmat function and identify the level of training required by the regulations.

Step 3: For hazmat employees, training will include general awareness & familiarization, security awareness, safety, and function-specific training. Under the 49 CFR, a hazmat employee is required to receive recurrent training every three years. See 49 CFR 172.704 for training requirements.

In addition, the ICAO Technical Instructions require focused competency-based training and assessment to ensure employees are competent. Recurrent training is required every two years.

Step 4: Have a trained employee look up the material in the Hazardous Materials Table or the ICAO TI, as required, to determine the authorized quantities permitted to be shipped, labels required, and the allowable packaging as per the 49 CFR Part 173 or the applicable ICAO TI packing instruction. Remember, air carriers may impose additional restrictions.

Step 5: Determine the quantities and corresponding packaging requirements for your shipment. There are more stringent packaging requirements for shipping dangerous goods by air. These additional requirements can include secondary means of closure for packaging, additional absorbent packaging material, use of pressure-rated packaging, or use of packaging rated to a more stringent packing group. Packaging used for ground shipments of the same product may not be acceptable for air shipments. Reusing the same packaging for a return shipment may not be authorized, depending on the packaging specification or physical condition.  

UN-Specification packaging may be required depending on the packing group assigned to the hazardous material. 

• The packing group is a grouping according to the degree of danger presented by hazardous materials or dangerous goods. The performance level identifies the performance standard under which the packaging design type has been successfully tested:
  • X – For packaging meeting Packing Group I, II, and III tests. (Packing Group I – Great Danger)
  • Y – For packaging meeting Packing Group II and III tests. (Packing Group II – Medium Danger)
  • Z – For packaging meeting Packing Group III tests. (Packing Group III – Minor Danger)

Step 6: If UN-Specification packaging (PDF) is required, read the package closure instructions carefully and obtain all the materials listed, such as tape, zip ties, poly bags, etc. Be sure to follow the information closely. Furthermore, the additional requirements under 49 CFR Part 173.27 should be reviewed.

Packages meeting UN specifications are tested with the materials listed in the closure instructions. Any variation from the manufacturer's instructions could compromise the integrity of the package and may be considered a violation of the Hazardous Material Regulations (HMR).

Step 7: Once you have the proper packaging, obtain the appropriate hazard communication (i.e., markings, labels, and shipping paper/shipper's declaration). Generally, the Proper Shipping Name, the UN Number, and the shipper or consignee's name and address are required to be marked on the package on the same surface as the hazard class label.

Even if you are familiar with shipping dangerous goods by other modes of transport, note that additional or different marks and labels must appear on packaged dangerous goods shipped by air.

Step 8: Mark and label the package.

Step 9: Following the manufacturer's packaging and closure instructions, package the material in its packaging. 

Step 10: Fill out the shipping paper and affix it to the outside of the package in an unobstructed area. For example, Guidance for Shipper's Declaration (PDF).

Step 11: Your package is ready to be shipped.

Step 12: Keep the Shipper's Declaration on file for a period of two years.