Shipping Radioactive Material by Air: IATA DGR Section 10 Overview

Why IATA Air Shipping Matters

If you ship radioactive material by ground, you already know the DOT regulations inside and out. But the moment a shipment needs to go by air — whether it is a sealed source heading to a calibration facility, a medical isotope on a time-critical delivery, or a contaminated instrument returning to the manufacturer — you are operating under a different regulatory framework with its own rules, restrictions, and paperwork.

I have worked with facilities that shipped radioactive material by ground for years without any issues, and the first time they needed to send a sealed source back to the manufacturer by air, they were blindsided. They prepared the shipment exactly as they would for ground — Curies on the shipping paper, no DGD, and a TI of about 5.0 on the package. The carrier rejected it at the counter. The shipper had done nothing wrong for a ground shipment, but three different requirements were wrong for air. That one rejection cost them a week of delays on a time-sensitive calibration schedule.

The good news is that the classification itself does not change. If your material is UN2915, Type A, normal form on the ground, it is still UN2915, Type A, normal form by air. What changes is what happens after classification: which aircraft it can go on, how close it can be to passengers, what paperwork is required, and what materials are flat-out prohibited.

Understanding the Regulatory Chain

Before diving into the details, it helps to understand where the IATA DGR fits in the regulatory hierarchy. There are three layers, and each builds on the one above it:

IAEA: The Source

The International Atomic Energy Agency publishes the Regulations for the Safe Transport of Radioactive Material (SSR-6). This is the international foundation that defines A1 and A2 values, package types, activity limits, and the entire classification framework. Both A1/A2 values in the DOT table (49 CFR 173.435) and in the IATA DGR (Table 10.3.A) come from the same IAEA source.

ICAO: The Legal Authority for Air

The International Civil Aviation Organization translates IAEA safety standards into binding requirements for air transport through the Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284). ICAO member states (including the United States) are legally obligated to implement these requirements.

IATA DGR: The Field Manual

The IATA Dangerous Goods Regulations take the ICAO Technical Instructions and present them in a format that shippers and airlines actually use day-to-day. The DGR adds operator-specific variations (individual airline restrictions), acceptance checklists, and practical guidance. Section 10 is dedicated entirely to Class 7 radioactive material.

My recommendation is straightforward: if you ship by air, learn the IATA DGR and use it as your primary reference. Most of the shippers I work with use the DGR as their day-to-day manual for air shipments because that is what the airlines require for acceptance. I have never seen a carrier ask for a 49 CFR Part 175 citation — they want to see compliance with the DGR. That being said, knowing that 49 CFR 171.22 authorizes ICAO TI compliance is useful background, especially if you are ever asked to justify why you are following an international standard instead of the domestic regulation.

What Stays the Same Between Air and Ground

The most important thing to understand about air shipping is how much does not change. The entire classification engine — the logic that determines your UN number, proper shipping name, and package type — is transport-mode agnostic. Specifically:

• A1 and A2 values: Identical. Both come from the same IAEA tables.
• UN numbers: The same 20 UN numbers (UN2908 through UN2919, UN2977/2978, UN3321 through UN3333) apply to both air and ground.
• Package type hierarchy: Excepted → Type A → Type B → Type C. The same progression applies.
• Fissile exemptions: The exemptions in IATA DGR §10.3.7.2 are identical to 49 CFR 173.453.
• Definition of radioactive material: The same activity concentration and consignment activity thresholds determine whether material is regulated.
• Label categories: WHITE-I, YELLOW-II, YELLOW-III — same criteria, same labels.
• Contamination limits: The surface contamination limits (4 Bq/cm² for beta/gamma and low-toxicity alpha, 0.4 Bq/cm² for other alpha) are the same.

If you have already classified a shipment under DOT 49 CFR, that classification is valid for air. You do not need to reclassify.

What Changes for Air Transport

The differences between air and ground are all post-classification constraints. Think of them as additional rules layered on top of the classification you already have. Here are the key areas:

1. Transport Index Limits per Package

On the ground, DOT limits the Transport Index per package to 10.0 (49 CFR 173.441). By air, the limits depend on the aircraft type:

• Passenger aircraft: Maximum TI of 3.0 per package (IATA DGR Table 10.9.B)
• Cargo aircraft: Maximum TI of 10.0 per package
• Combined TI on passenger aircraft: Maximum of 50
• Combined TI on cargo aircraft: No limit (under exclusive use)

This means a package with a TI between 3.1 and 10.0 can ship by cargo aircraft but not by passenger aircraft.

2. Prohibited Materials and Configurations

Certain materials and package types that are perfectly legal on the ground are forbidden by air (IATA DGR §10.9.3.3):

• Vented Type B(M) packages — forbidden on all aircraft
• Packages requiring external cooling — forbidden on all aircraft
• Packages subject to operational controls during transport — forbidden on all aircraft
• Packages containing pyrophoric material — forbidden on all aircraft
• Type B(M) packages — forbidden on passenger aircraft (cargo only)
• Exclusive use shipments — forbidden on passenger aircraft
• Packages with surface dose rate exceeding 2 mSv/h — require special arrangement

3. Documentation: The DGD

Ground shipments use a Bill of Lading (or shipping paper) under 49 CFR 172.200. Air shipments require a Shipper's Declaration for Dangerous Goods (DGD) under IATA DGR §10.8. Key differences:

• SI units only: Activity must be stated in Becquerels (not Curies) on the DGD
• English required: The DGD must be completed in English (translations may accompany)
• Two copies minimum: An original for the operator and one to accompany the shipment
• Signature required: The shipper (or authorized representative) must sign — typewritten signatures are not accepted
• Exception: Excepted packages (UN2908, UN2909, UN2910, UN2911) do not require a DGD

The most common documentation mistake I see is shippers using Curies on the DGD. They have been writing “50 mCi” on their shipping papers for years, and they carry that habit straight onto the air form. The airline rejects it because the DGD requires SI units — it needs to say “1.85 GBq.” The second most common mistake is not having a DGD at all. Shippers who are used to the DOT Bill of Lading sometimes assume the same form works for air. It does not. The DGD is a specific document with its own format, and you need two signed copies minimum.

4. Separation Distances

On the ground, separation is handled by vehicle loading limits and placarding. By air, specific separation distances are mandated between radioactive packages and passengers, crew, live animals, and undeveloped photographic film:

• Passengers: Minimum distances based on total TI, measured from package surface to nearest inside surface of the cabin (IATA DGR Table 10.9.C)
• Crew (cargo aircraft): Separate distance table for cargo-only flights (Table 10.9.D)
• Photographic film: Must limit exposure to 0.1 mSv per consignment (Table 10.9.E)
• Live animals: 0.5 m minimum for journeys of 24 hours or less; 1.0 m for longer

5. Training Recurrence

DOT requires recurrent hazmat training every 3 years (49 CFR 172.704). IATA requires recurrent training every 2 years (IATA DGR §1.5). If you ship both ground and air, the 2-year IATA cycle becomes your de facto training interval.

My recommendation for shippers who do both ground and air is to find a training provider that covers both frameworks in a single course. There are good programs out there that address DOT 49 CFR and the IATA DGR together, and that saves you from having to coordinate two separate training schedules. Keep in mind that the IATA 2-year recurrence cycle is the one that drives your schedule — if you train every 2 years for air, you are automatically within DOT's 3-year window. I have seen facilities try to stagger their training, doing DOT one year and IATA the next, and it just creates confusion about who is current on what.

6. Advance Notifications

Certain air shipments require advance notification to the competent authorities of the origin, transit, and destination countries (IATA DGR §10.10.2.3):

• Type B(M) packages
• Type B(U) or Type C packages with activity exceeding 3,000 × A1 or 3,000 × A2 (whichever is lower)
• Shipments under special arrangement

The recommended advance notice period is 7 days before the first shipment.

IATA DGR Section 10 at a Glance

Section 10 is organized into subsections that mirror the lifecycle of a shipment. Here is a map of where to find what:

In my experience, the sections I reference most are 10.3 (classification), 10.8 (documentation), and 10.9 (handling and loading). Those three cover about 90% of what you need for a routine shipment. My advice for navigating the DGR efficiently is to learn the section numbering system — once you know that 10.3 is classification and 10.9 is handling, you can jump straight to what you need without flipping through pages. I also recommend keeping a copy of Table 10.9.B (TI and CSI limits) and Table 10.9.C (separation distances) printed and taped to the wall of your shipping area. Those are the two tables you will reference on almost every air shipment.

State and Operator Variations: The Wild Card

One of the aspects of IATA air shipping that has no direct parallel in DOT ground shipping is the concept of state variations and operator variations. Individual countries can impose additional restrictions beyond the base DGR requirements, and individual airlines can add their own restrictions on top of that.

You will see these referenced throughout Section 10 as codes like “USG-10” (a US state variation) or “FX-07” (a FedEx operator variation). In practice, this means:

• A shipment that is compliant with the base DGR may still be rejected by a specific airline
• Routes through certain countries may trigger additional documentation or approval requirements
• Some airlines refuse Class 7 material entirely (check before booking)

I worked with a facility that had a fully DGR-compliant Type A shipment — TI under 3.0, DGD completed correctly, everything by the book. They booked it with a major carrier and showed up at the cargo counter, only to be told that this particular airline did not accept Class 7 material on certain routes due to an operator variation. The shipment had to be rebooked on a different carrier that did accept radioactive material on that route. The delay pushed the delivery back two days. The lesson was simple: call the carrier's dangerous goods department before you prepare the shipment, not after. A five-minute phone call would have saved two days.

Type C Packages: The Air-Only Package Type

There is one package type that exists specifically for air transport: the Type C package. Type C packages are designed to withstand the conditions of a severe air crash and are required for high-activity shipments by air that exceed Type B quantity limits.

Type C packages must survive enhanced accident conditions including:

• A puncture/tearing test (250 kg probe dropped from 3 m)
• An enhanced thermal test (800°C for 60 minutes)
• An impact test at 90 m/s onto an unyielding target

In practice, Type C packages are rare and extremely expensive. Most high-activity air shipments are structured to stay within Type B limits. But it is worth knowing that the option exists for situations where other transport modes are not feasible.

In over 15 years of shipping radioactive material, I have never personally handled a Type C package, and I do not know many people in the commercial shipping world who have. They exist, and they are an important part of the regulatory framework, but they are extremely rare and prohibitively expensive for most applications. The vast majority of air shipments stay within Type A or Type B limits. If your activity requires Type C, you are almost certainly working with a specialized transport company that handles the package design, testing, and regulatory compliance for you. For most shippers reading this guide, Type C is good to know about but unlikely to be something you encounter in practice.

How RadShip.com Helps

RadShip.com helps simplify radioactive material shipping for both ground and air:

• RAMcalc — Classifies your radioactive material and determines the correct UN number, package type, and shipping requirements. The classification is the same whether you are shipping by ground or air.
• Regulatory Guides — Plain-language guides covering both DOT and IATA requirements, written by experienced RAM shippers
• LabelCalc — Determines correct label category based on Transport Index and surface dose rate

Here's the reality: the classification is the foundation for everything that comes after — the UN number drives your documentation, your labels, your packaging, and your air eligibility. If the classification is wrong, everything downstream is wrong. And for air, the consequences of a wrong classification are more immediate than ground. On the ground, a carrier might catch an error at pickup or you might get a warning from DOT after the fact. By air, the airline's acceptance check catches errors at the counter, and your shipment does not fly. That delay can mean a missed medical procedure, a stalled calibration, or an expensive rebooking. Having one tool that gives you a verified classification valid for both modes means you classify once and ship with confidence, regardless of transport mode.

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Common Questions

Is the IATA DGR legally binding?

Not directly, but effectively yes. The IATA DGR is an industry standard that implements the ICAO Technical Instructions, which are binding on member states. Airlines require IATA DGR compliance for acceptance, which makes it the de facto standard for anyone shipping radioactive material by air.

Do I need a separate classification for air vs ground?

No. The classification — UN number, proper shipping name, package type — is identical. Air transport adds post-classification constraints (TI limits, prohibitions, documentation format) but does not change the classification itself.

Can all radioactive material be shipped by air?

No. Several materials and configurations are prohibited, including vented Type B(M) packages, packages requiring external cooling, and pyrophoric materials. Type B(M) packages and exclusive use shipments are also forbidden on passenger aircraft specifically. See our prohibited materials guide for the complete list.

Where can I get a copy of the IATA DGR?

From IATA directly. The DGR is published annually and available for purchase at iata.org. There is no free online version. Section 10 covers Class 7 radioactive material specifically.

Do I need different training for air shipments?

Yes. IATA DGR requires training specific to air transport of dangerous goods, with recurrent training every 2 years (vs 3 years for DOT ground). Training must cover air-specific restrictions, DGD preparation, and acceptance procedures. See our training requirements guide for a comparison.

If I could give one piece of advice to someone shipping radioactive material by air for the first time, it would be this: call the carrier first. Before you prepare the DGD, before you survey the package, before you do anything — pick up the phone and talk to the airline's dangerous goods department. Confirm they accept Class 7 material on your route, ask about any operator variations, and verify what documentation format they expect. That one phone call will save you more headaches than any amount of regulation reading. The DGR is your rulebook, but the carrier is your gatekeeper.

Summary: Your Air Shipping Readiness Checklist

Before shipping radioactive material by air, ensure:

• ☐ Material is classified (same process as ground — UN number, PSN, package type)
• ☐ Material is not on the prohibited list (no vented B(M), no pyrophoric, no external cooling required)
• ☐ TI per package is within aircraft limits (≤ 3.0 for passenger, ≤ 10.0 for cargo)
• ☐ DGD is prepared in English with SI units (unless excepted package)
• ☐ Carrier has been contacted and will accept Class 7 material (check operator variations)
• ☐ Advance notification sent if required (Type B(M), >3000 A1/A2, special arrangement)
• ☐ Training is current under IATA DGR (recurrent every 2 years)
• ☐ Separation distance requirements are communicated to the carrier

Related IATA Air Shipping Guides

This overview is part of RadShip's IATA air shipping guide series. For deeper dives into specific topics:

• IATA vs DOT: What Changes When You Ship by Air — Side-by-side comparison of all differences
• Passenger vs Cargo Aircraft Rules — TI limits, prohibitions, and separation distances by aircraft type
• Materials Prohibited from Air Transport — The complete list of what cannot go by air

Regulatory References

IATA DGR (Air Transport):

• IATA DGR §10.0 — Scope, radiation protection, management systems
• IATA DGR §10.3 — Classification (A1/A2, LSA, SCO, fissile, package categories)
• IATA DGR §10.8 — Documentation (DGD requirements)
• IATA DGR §10.9.3.3 — Loading limitations and prohibitions
• IATA DGR Table 10.9.B — TI and CSI limits per aircraft type
• Purchase the IATA DGR

DOT Requirements (Ground / US Domestic):

• 49 CFR 171.22 — Authorization to use ICAO TI for international air
• 49 CFR Part 175 — Carriage by aircraft (US domestic air requirements)
• 49 CFR Part 173, Subpart I — Class 7 radioactive material requirements

International Standards:

• IAEA SSR-6 — Regulations for the Safe Transport of Radioactive Material
• ICAO Technical Instructions — Doc 9284, binding requirements for air transport