Breakthrough on rules about sending fishmeal by air
As of 1 January 2021, fishmeal can be shipped as cargo on either a passenger or cargo aircraft as normal dangerous goods without requiring an approval. However, airlines that currently do not accept dangerous goods shipped under an approval may agree to carry fish meal under an A2 approval when they can see that the forbidden status is being changed.
IFFO has been working on ways to stabilize fishmeal when transported via vessels using different antioxidants. This has been done through amendments to the International Marine Organisation (IMO) codes. During this time, IFFO has had to move fishmeal samples for research purposes from Lima to the USA and more recently from Lima to the UK. Time for shipping those samples has not been our best ally, hindering the possibility to move fishmeal in a faster way than a vessel. Logical is to think that we needed to resort to move this fishmeal via air. However, despite multiple attempts to transport fishmeal via couriers, freight forwarders, custom brokers, etc., we saw it as a mission impossible.
Working with the International Civil Aviation Organization
This inconvenience made IFFO to consider contacting the ICAO (the International Civil Aviation Organization, a UN specialized agency as well as the IMO) and the IATA to find out why fishmeal when stabilized with antioxidant cannot be transported via air. It turned out that this was a long-standing prohibition, that had more to do more with “wording” rather than a “real danger” in fishmeal, due to UN 2216 (Fishmeal stabilized) is classified in Class 9*. The reason for its absence from the list in the Instructions was thought to be that there was no need to transport fishmeal via air.
Our contact at the ICAO also referred that this prohibition might have been based on the classification of unstabilized fishmeal in Division 4.2**. This prohibition was originated from ICAO's Technical Instructions for the Safe Transport of Dangerous Goods via Air, having the IATA not responsible to change this.
To drive change, IFFO submitted a proposal to the ICAO Dangerous Goods Panel (DGP) to change the status of the transportation of fishmeal on both passenger and cargo aircraft when stabilized with antioxidant. This proposal included the results of trials that IFFO has been doing and that have demonstrated that when fishmeal is stabilized with antioxidant does not pose a risk for self-heating.
This proposal was presented in the DGP meeting in April this year in Montreal, Canada and was agreed without significant changes. The only modification was that the Dangerous Goods Panel Working Group did not see the need to include the draft special provision A2, UN special provision 300 (see below).
Fishmeal can only be shipped on a cargo aircraft under an “approval” from the authorities of the States of origin and of the operator until 31 December 2020 in accordance with special provision A2α. As of 1 January 2021, fish meal can be shipped as cargo on either a passenger or cargo aircraft as normal dangerous goods without requiring this “approval”. However, airlines that currently do not accept dangerous goods shipped under an approval may agree to carry fish meal under an A2 approval when they can see that the forbidden status is being changed. In other words, operators who won’t accept the approval may be more amenable to do so between now and 2021.
These changes will be incorporated into the next edition of the ICAO Technical Instructions which become effective 1 January 2021 and you can find them on-line here. The detail of the narrative on the discussion on the working paper on fish meal is on page 12. The details of the changes to the Technical Instructions are shown on pages C-32 for the change to the list of dangerous goods and C-52 for the revision to the packing instruction.
Miscellaneous (Class 9*) is for miscellaneous dangerous items. The class does not have any subdivisions but comprises any substance that may pose a danger during air transport that isn't covered by the other classes. This includes items with anaesthetic properties, solid dry ice, asbestos, life rafts and chain saws.
Class 4 dangerous goods include flammable solids, substances liable to spontaneous combustion and substances which, in contact with water, emit flammable gases. There are three sub-divisions:
- Division 4.1: Flammable solids
- **Division 4.2: Substances liable to spontaneous combustion
- Division 4.3: Substances which, in contact with water, emit flammable gases
αSpecial Provision A2: This article or substance may be transported on cargo aircraft, only with the prior approval of the appropriate authority of the State of origin and the State of the operator under the written conditions established by those authorities. Where states, other than the state of origin and the State of the operator, have lodged a variation advising that they require prior approval of shipments made under this Special Provision, approval must also be obtained from the states of the transit, overflight and destination, as appropriate. In each case, a copy of the document(s) of approval, showing the quantity limitations and the packaging requirements, must accompany the consignment.
ΩUN special provision 300: Fish meal or fish scrap shall not be transported if the temperature at the time of loading exceeds 35°C or 5°C above the ambient temperature, whichever is higher.
Photo: Michael Gaida, from Pixabay