Shipper & Operator Responsibilities in Air Transport

Shipper & Operator Responsibilities in Air Transport

The air transport safety chain depends upon a strict legal division of responsibilities between the party offering dangerous goods for shipment (the Shipper or Consignor) and the airline carrying the freight (the Operator). Under IATA DGR Section 1.3 and Section 1.4, statutory duties are non-delegable: neither party can assume or waive the primary obligations of the other.

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1. Shipper (Consignor) Responsibilities

The shipper is legally defined as any person or organization offering dangerous goods for air transport. The shipper retains sole statutory responsibility for correctly preparing the package before it enters the air logistics chain.

Primary Shipper Obligations (DGR Section 1.3)

1. Full Identification & Classification: The shipper must determine whether a material meets the criteria of any of the 9 IATA hazard classes or divisions, assigning the accurate UN/ID number, Proper Shipping Name (PSN), Class/Division, and Packing Group (PG I, II, or III).
2. Prohibition Verification: The shipper must confirm that the substance is not forbidden for air transport under any circumstances (Section 2.1) or forbidden without specific State approvals.
3. Packaging Compliance: The shipper must select and assemble UN specification packaging authorized by the specific Packing Instruction (PI) in Section 5. The shipper must ensure all inner containers are compatible and that liquid packagings meet pressure differential standards (at least 95 kPa).
4. Marking & Labelling: The shipper must apply all mandatory package markings (UN number, PSN, full shipper/consignee address, net quantity) and hazard class labels (primary, subsidiary) alongside handling labels (Cargo Aircraft Only, Orientation Arrows).
5. Documentation Execution: The shipper must accurately complete and sign the Shipper's Declaration for Dangerous Goods (SDDG), certifying under penalty of law that the consignment complies with all regulations.
6. Staff Training & Competency: The shipper must ensure that all staff preparing dangerous goods are trained and assessed under the Competency-Based Training and Assessment (CBTA) framework.

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2. Operator (Carrier) Responsibilities

The operator is the air carrier accepting and transporting the cargo. While the operator relies on the shipper's declaration, it maintains independent statutory duties under DGR Section 1.4 to verify safety and manage aircraft stowage.

                               DANGEROUS GOODS LOGISTICS SAFETY CHAIN

 [ SHIPPER ]  ════>  [ FREIGHT FORWARDER ]  ════>  [ OPERATOR ACCEPTANCE ]  ════>  [ FLIGHT CREW ]
  • Classify          • Consolidate                 • Execute Checklist             • Review NOTOC
  • Pack (UN Spec)    • Intermediate Check          • Inspect Packages              • Inspect In-Flight
  • Mark & Label      • Tender to Carrier           • Load & Segregate              • Emergency Resp.
  • Sign SDDG                                       • Issue NOTOC

Primary Operator Obligations (DGR Section 1.4)

• Acceptance Verification: Operators must not load dangerous goods cargo onto an aircraft without completing a formal acceptance check using a standardized IATA Dangerous Goods Acceptance Checklist (DGR 9.1.3).
• Package Inspection: Operators must inspect every package, overpack, and freight container immediately prior to loading to verify structural integrity, absence of leaks or damage, and valid marking/labelling.
• Loading, Stowage & Segregation: Operators must stow packages securely to prevent movement during flight, enforce Table 9.3.A (Segregation Matrix) to isolate incompatible hazard classes, isolate toxic or infectious materials from foodstuffs, and restrict Cargo Aircraft Only (CAO) shipments to authorized main-deck freighter holds.
• Notification to Captain (NOTOC): Operators must deliver a written or electronic NOTOC to the Pilot-in-Command prior to departure, detailing exact UN numbers, PSN, hazards, net quantity, exact hold locations, and emergency response codes.
• Emergency Response & Incident Reporting: Operators must provide flight crews with emergency handling information (ICAO Emergency Response Guidance Doc 9481) and report incidents to national authorities.

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3. Comparative Responsibility Matrix

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4. Dangerous Goods Incident & Occurrence Reporting

When safety breaches occur, both shippers and operators face statutory reporting mandates under DGR Section 9.6 to inform National Civil Aviation Authorities (NCAAs).

Mandatory Reportable Events

1. Dangerous Goods Accidents: Events associated with air transport resulting in fatal or serious injury to any person or major property/structural damage.
2. Dangerous Goods Incidents: Events (other than accidents) involving dangerous goods—such as package leakage, fire, spillage, toxic vapor release, or compromised packaging integrity on board an aircraft or at cargo facilities.
3. Undeclared or Misdeclared Dangerous Goods: Discovery of dangerous goods cargo that was offered without an SDDG, hidden inside general cargo, or improperly labelled.
4. Forbidden Dangerous Goods: Discovery of cargo containing substances completely forbidden for air transport.

Operators and freight forwarders must submit initial written reports to their local NCAA (such as the FAA Hotline or Transport Canada CADORS) within 72 hours of the occurrence (or immediately in severe emergencies). Failure to report undeclared dangerous goods constitutes a criminal offense in most jurisdictions.