Don’t Overlook the Need for Packaging Efficiency and Regulatory Compliance

We all know how busy things can get in the fast-paced world of aviation supply.  You look at the clock and realize you have precious little time before shipments are scheduled for pickup.  It’s tempting to rush through the packaging process, and grab the first box, regardless of the fact that it may be several sizes too big, or inappropriate for a particular product.

This short-term “win” of meeting a pickup deadline can, in fact, have quite serious economic and safety repercussions.  Which is why it’s important – really important – to have a good understanding of packaging “best practices” and regulatory requirements for aviation-related components, parts and supplies.  Most airline repair facilities offer extensive — often mandatory — training for their employees about the importance of packaging, but a little refresher never hurts.

Hazardous Materials and Dangerous Goods

A couple of years ago, Amazon.com Inc. was assessed a $350,000 fine by the Federal Aviation Administration (FAA) for shipping dangerous goods by air.  According to The Wall Street Journal, the internet retailer allegedly shipped an improperly packaged container of drain cleaner that leaked through its packaging and caused harm to several individuals.  “The FAA alleged that the shipment was not properly packaged, was not accompanied by a proper declaration stating the hazardous nature of its contents, and that Amazon had failed to provide emergency response information with the package, and that the Amazon employees who handled it had not received proper training,” the Journal reported.

Amazon is certainly not the only company to have been flagged for improper shipment of hazardous materials.  According to the Dallas Morning News, the value of civil fines issued by the FAA increased from $0 during 2013, to more than $4.5 million during 2015, which underscores the increased attention safety inspectors are giving to hazardous goods.

And U.S. and international aviation safety inspectors should give top priority to these materials, as should any individual charged with preparing such shipments.  This means being thoroughly familiar with not just packaging and labeling requirements, but also with regulatory requirements that strictly control the movement of these materials.

The FAA defines a “dangerous good” (also known as hazardous material or hazmat) as “any substance or material that is capable of posing an unreasonable risk to health, safety and property when transported in commerce.  As anyone remotely involved in aircraft maintenance and repair understands, the industry is chock-full of parts and supplies that qualify as dangerous goods — lithium batteries, fuel pumps, paint, hydraulic fluids and cleaning supplies are top what has become an increasingly long list.  By some estimates, as many as 25 percent of aviation-related shipments contain dangerous goods, and must meet strict packaging, labeling and documentation requirements.

The International Air Transport Association (IATA) is a Canada-based trade association that helps define the rules of the road for shipping dangerous goods.  IATA represents more than 290 airlines in 120 countries that carry 80 percent of total world air traffic. 

With regard to dangerous goods, IATA publishes a “Dangerous Goods Regulations (DGR)” manual that serves as “the global reference for shipping dangerous goods by air and the only standard recognized by airlines.”

The manual details specific packaging requirements for various “classes” of dangerous goods, which include:

Class 1 – Explosives

Class 2 – Gases

Class 3 – Flammable Liquids

Class 4 – Flammable Solids

Class 5 – Oxidizing Substances

Class 6 – Toxic and Infectious Substances

Class 7 – Radioactive Material

Class 8 – Corrosives

Class 9 – Miscellaneous Dangerous Goods.

Once a product’s class has been determined, specific packaging requirements can be found by consulting the appropriate section of the IATA DGR manual.  For example, the North Carolina-based Environmental Resource Center notes “the general requirements for Class 1 Explosives are found in section 5.1 of the IATA DGR, immediately preceding packing instruction 101; the general requirements for Class 2 Gases are found in section 5.2, immediately preceding packing instruction 200; and the general requirements for Class 7 Radioactives are found in section 10.6.”

Anyone shipping dangerous goods must follow IATA’s general packing requirements which include directives such as:

  • The package, including absorbents and cushioning material, must be compatible with its contents;
  • Packages must not be used if they are constructed of materials that can become softened, brittle, or permeable due to temperatures experienced during air transport; chemical reaction with the contents; or the use of a refrigerant;
  • No dangerous residue can be on the outside of the package; and
  • You must use good quality packaging, able to withstand loading/unloading and conditions normal to transport.

Clearly, there’s a lot involved in the safe shipment of dangerous goods.  To ensure full understanding of packaging and documentation requirements, airline and supplier employees must avail themselves of all opportunities to become familiar with most-current requirements.  Those opportunities generally include:

  • Training modules. Proper training is critical to safe shipping of dangerous goods.  IATA mandates different levels of training, depending on employees’ specific duties.  IATA instructor-led training modules are offered around the world, by various IATA partner providers.  In general, an employer must ensure all employees are “competent to perform any function for which they are responsible,” by providing “training and assessment commensurate with the functions for which they are responsible.”

Employees must be re-trained regularly, and companies are responsible for ensuring employees receive updated training, and for keeping detailed records.

In addition, employees can avail themselves of “self-study” courses available through the IATA website as a way to obtain additional expertise, refresh prior learnings, and stay current on changing industry practices.

  • IATA’s “Dangerous Goods Regulations (DGR)” manual. As discussed above, this really is the “bible” for dangerous goods handling.  Any aviation supply shop should provide easy access to this publication, and employees should reflexively look to the manual as the definitive guide for packaging and labeling requirements.

 

  • IATA Dangerous Goods Software. Many aviation repair facilities and suppliers choose to purchase IATA-compliant software, that facilitate compliance with dangerous goods requirements.   Key features include:
    • Easy access to detailed information about all dangerous goods, including packaging and documentation requirements.
    • Graphics that illustrate the proper application of marking and labeling requirements.
    • Automatic updates for all dangerous goods requirements.

Moving dangerous goods via air is about as serious as it gets.  But shipping via ground is also subject to strict packaging and compliance requirements.  The Federal Motor Carrier Safety Administration has designated nine different classes of hazardous materials:  Explosives; gases; flammable liquid and combustible liquid; flammable solid; oxidizer and organic peroxide; poison; radioactives; corrosives; and miscellaneous/dangerous.

For packaging purposes, FMCSA has established three “packing groups,” based on the degree of danger posed by the material.  Packing Group I is for materials that pose “great” danger; Packing Group II is for “medium” risk materials, while Packing Group III is for items that carry “minor” risk.  Shippers are responsible for determining the appropriate packing group, and meeting all commensurate packing requirements.

Container Standards help Identify Appropriate Packaging

Way back in 1960, the Air Transport Association (ATA) adopted “recommended specifications” for the packaging of airline supplies.  Those recommendations, known as “Specification 300” (Spec 300), have been periodically updated and remain the industry standards.

Specifically, the recommendations provide guidance for three categories of reusable shipping containers.  Although Spec 300 provides very detailed guidance for every aspect of the containers, general provisions include:

  • Category I containers are usually made from fiberglass, glass, or custom-fit plastic, and are used to protect high value materials such as fuel pumps, oxygen bottles and hydraulic components. Category I containers generally have an unlimited life span.
  • Category II containers tend to be less expensive, and often consist of fiberboard/cardboard containers with custom foam inserts. This category applies to “medium value” materials and can be reused for five-to-eight trips.
  • Category III containers are used to protect lower-value materials and are generally made from cardboard. In most instances, Category III containers are single use.

Several software systems are programmed to automatically identify the proper “container category” for a particular product.  This certainly makes the process easier, but it’s useful for employees to have a basic understanding of the origins of the container classification system, and the differences between each category.

Non-Dangerous Goods Offer Opportunities for Packaging Efficiency

A good chunk of aviation supply shipping involves materials that could aptly be described as “ordinary,” or “mundane.”  Shipments of things like passenger seats and brake disks present opportunities for aviation-related shippers to add efficiency to the shipping process, and reap savings along the way.  Potential sources of efficiency include:

  • Dimensional Weight Pricing – Airlines typically impose a 194 cubic inch limit on domestic shipments, and a 166 cubic inch limit on international shipments. Packages exceeding these dimensions are hit with an expensive oversize charge. 

A few years ago, ground transportation providers shifted to this “dimensional weight” (DIM) pricing strategy, whereby freight costs are based on a product’s weight and the amount of space it takes up on a truck.  Previously, costs were based on weight, distance and its freight “classification.”  With DIM pricing in effect, packaging becomes very important.  Packages full of Styrofoam peanuts, or other types of “filler” suddenly resulted in inflated prices.  And many shippers, unaware of the shift in pricing strategies, found themselves with increased freight bills.

Shippers can mitigate the impact of the DIM pricing strategy in several ways.  Packaging efficiency is an obvious place to start, but for smaller suppliers that have limited inventories of different package sizes and filler materials, this can be a challenge.  Technology can assist by optimizing packaging practices, and for many, has become a valuable part of an integrated warehouse/transportation solution.  It’s also possible to negotiate with a carrier to try and minimize the effect of the new pricing strategy.  At the time the new pricing strategy was rolled-out, The Wall Street Journal estimated it could cause freight costs to spike by as much as 30 percent for certain businesses.  Finding ways to avert these extra costs can be an obvious place to look for savings.

  • Beware of Costly Insurance Programs – Parts suppliers must also decide if it makes sense to insure their shipments, by accepting coverage options offered by most transportation providers. But similar to consumers’ experiences in taking the insurance option when renting a car, aviation parts insurance can often be an unnecessary expense. 

For one thing, it’s possible that shipments are already covered by a supplier’s existing policy, which means the additional coverage would be unnecessary.  Another consideration is whether the cost of having to replace a product, should it become lost or damaged, justifies the cost of the insurance premium.  This is especially true since most policies come with a high deductible.  And, if a shipper demonstrates good packaging practices, then chances are a shipment will arrive undamaged. 

Whether or not to buy insurance from a transportation provider is a question each supplier will have to answer for itself.  But many suppliers buy the insurance, almost as a knee jerk reaction, when a little research might determine it simply isn’t needed. 

  • Recycling Initiatives. Aviation parts suppliers can – and should – adopt good sustainability initiatives, both as a way to demonstrate good citizenship and achieve efficiencies.  This includes taking advantage of opportunities to find value for used or obsolete parts on a secondary market.  Market Study Report estimates the global value of the commercial aircraft parts aftermarket will exceed $51 billion by 2026, with an annual growth rate of 6.6 percent.  The aftermarket then, presents a strong opportunity for carriers and suppliers to recoup at least some of a product’s cost, while also allowing a usable part to find a second life.

Clearly, there’s a lot involved when shipping aircraft parts.  On the one hand, virtually all parts and components are subject to regulatory requirements which can determine the type, quality and composition of packaging materials.  But within these requirements, smart  shippers can often find opportunities for efficiency and savings.

If you think your operation could benefit from an analysis of your packaging processes, give your logistics provider a call.  An aviation-savvy provider will understand your unique shipping needs, but have good ideas for adding efficiency and identifying possible savings opportunities.


About the Author

Mario Rojas is a Business Development Executive – Aviation Logistics Services with Purolator International . Prior to that, he spent his career working in various operational roles expediting international shipments for companies such as DB Schenker and UPS Air Cargo. Mario comes from a family of Aviation experts. He enjoys traveling the world for business and pleasure and his favorite destination is Innsbruck-Austria.

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