Competent Authority Approvals and Notifications for Air Shipments

Why Competent Authority Approvals Matter

Most radioactive material shippers never need to think about competent authority approvals. If you're shipping excepted packages or Type A packages, the regulatory system trusts you to self-certify compliance. But when activities get high enough to require Type B packaging, or when fissile material is involved, the competent authority must independently verify that the package design can safely contain the material under normal and accident conditions.

For domestic ground shipments, this is relatively straightforward — you work with one competent authority (in the US, the NRC for package design and DOT/PHMSA for transport). For international air shipments, the complexity multiplies because every country on the route may need to approve the package design or be notified of the shipment.

I have seen international shipments delayed by weeks because the shipper had the package design approved in the country of origin but didn't realize that a B(M) package requires multilateral approval — meaning every transit country needed to sign off too. Understanding which approval type applies to your package before you plan the route is essential for avoiding these delays.

Who Needs to Know This

This applies to anyone who:

• Ships Type B packages by air (domestically or internationally)
• Ships fissile material that is not exempt under the fissile exemptions
• Ships Special Form radioactive material internationally
• Ships uranium hexafluoride (UF₆) by air
• Needs to arrange transport under special arrangement

Design Approvals: Who Must Approve the Package?

A design approval certifies that the package design meets the safety standards for its type. The key question is whether the approval is unilateral (only the country of origin) or multilateral (country of origin plus every country the shipment passes through).

No Approval Required

• Excepted packages (UN2908–UN2911) — No design approval
• Type A packages — Self-certified by the shipper. No competent authority review of the package design
• Industrial packages (IP-1, IP-2, IP-3) — No design approval for the package itself

Unilateral Approval (Country of Origin Only)

• Special Form radioactive material — The design must be approved by the competent authority of the country where the Special Form capsule or source was manufactured (IATA DGR §10.10.2.1.1)
• Type B(U) packages — “U” stands for unilateral. Approved by the country of origin of the package design only (IATA DGR §10.10.2.1.2)
• Type C packages — Unilateral approval (IATA DGR §10.10.2.1.4)

Multilateral Approval (Every Country on the Route)

• Type B(M) packages — “M” stands for multilateral. Must be approved by the country of origin and every country through or into which the package is transported (IATA DGR §10.10.2.1.3)
• Fissile material packages — Unless exempted under the fissile exemptions, the package design requires multilateral approval (IATA DGR §10.10.2.1.5)
• Type B(U) packages containing fissile material — The B(U) design is unilateral, but the fissile aspect makes it multilateral overall
• Type C packages containing fissile material — Same rule — fissile upgrades it to multilateral
• Low dispersible radioactive material — Multilateral (IATA DGR §10.10.2.1.7)
• UF₆ packages ≥ 0.1 kg meeting certain design requirements — Multilateral (IATA DGR §10.10.2.1.6)

The practical difference between unilateral and multilateral is significant. A unilateral approval means you get one certificate from one authority and you're done — that certificate is recognized worldwide. A multilateral approval means you need each transit country's competent authority to review and approve the design, which can add weeks or months to the planning process for international shipments.

In my experience, the B(U) vs. B(M) distinction is the single most impactful decision in Type B package selection for international air shipments. If your package qualifies as B(U), you avoid the multilateral approval process entirely. If it's B(M), every new transit country means another approval to obtain. This is why most international shippers strongly prefer B(U) designs when the option exists.

Shipment Approvals: When the Specific Consignment Needs Approval

Separate from the package design approval, certain shipments themselves require approval. This is not about the package — it's about the specific consignment being transported (IATA DGR §10.10.2.2).

Multilateral shipment approval is required for:

• Type B(M) packages that do not conform with certain requirements of IATA DGR §10.6.2.4.1.4
• High-activity Type B(M) packages — containing more than 3,000 A1, 3,000 A2, or 1,000 TBq, whichever is lower
• Fissile material shipments where the sum of CSI values in a single freight container or aircraft exceeds 50

A competent authority may waive the shipment approval by including a specific provision in the design approval certificate. This is common for routine shipments of the same package type on established routes.

Special Arrangement Shipments

A special arrangement allows transport of radioactive material that cannot meet all the standard regulatory requirements, provided the competent authority is satisfied that an equivalent level of safety is achieved through alternative measures (IATA DGR §10.0.4).

Key rules:

• Every special arrangement shipment requires multilateral approval
• The overall safety level must be at least equivalent to what the standard regulations would provide
• Special arrangement packages are assigned Category III-Yellow
• Advance notification is required for every special arrangement shipment

Special arrangements are rare in practice. Most shippers will never need one. They come into play for one-of-a-kind shipments — decommissioned reactor components, damaged sources that can't be repackaged into a standard container, or materials with properties that don't fit neatly into the standard classification system. The approval process is lengthy and expensive, so the industry strongly prefers designing packages to meet the standard requirements.

Advance Notification Requirements

For certain high-consequence shipments, the shipper must notify the competent authority of the country of origin and every transit country before the shipment moves (IATA DGR §10.10.2.3). Notification must reach each authority before the shipment begins, and preferably at least 7 days in advance.

When Notification Is Required

• Type B(U) packages with activity > 3,000 A1 or 3,000 A2 (whichever applies), or > 1,000 TBq, whichever is lower
• Type B(M) packages — all shipments, regardless of activity
• Type C packages with activity > 3,000 A1 or 3,000 A2, or > 1,000 TBq, whichever is lower
• All special arrangement shipments

What the Notification Must Include

Each notification must contain (IATA DGR §10.10.2.3.5):

• Package identification and all applicable certificate numbers
• Shipment date, expected arrival date, and proposed routing
• Radionuclide name
• Physical and chemical form (or notation of Special Form)
• Maximum activity in becquerels (or mass of fissile nuclides)

The most common mistake I see with notifications is treating them as optional or as something the carrier handles. They are the shipper's responsibility. If you're shipping a Type B(M) package internationally and a transit country's competent authority wasn't notified, the shipment can be held at a transit point until the paperwork catches up.

Certificates That Must Accompany the Shipment

The applicable competent authority certificates must physically accompany the shipment and be referenced on the DGD in Sequence 4 of the Nature and Quantity box (IATA DGR §10.8.7). Certificates in languages other than English must include an accurate English translation.

The key certificates by package type:

• Type A with Special Form: Special Form approval certificate
• Type B(U): Type B(U) package design approval certificate
• Type B(M): Type B(M) design approval certificate + shipment approval certificate (if applicable)
• Type C: Type C design approval certificate
• Fissile: Fissile material package design approval certificate (unless exempted)
• Special arrangement: Special arrangement approval certificate

In my experience, the most common documentation failure is a shipper who has the certificate on file at their facility but doesn't include a copy with the shipment. The certificate needs to travel with the package — having it in a filing cabinet at headquarters doesn't satisfy the requirement.

How RadShip.com Helps

RadShip.com helps you determine what approvals your shipment requires:

• RAMcalc — Classifies your material and determines whether it requires a Type A, Type B(U), or Type B(M) package, so you know immediately whether competent authority approval is needed
• Identifies fissile material requiring package design approval vs. material that qualifies for fissile exemptions
• Pre-shipment checklists remind you which certificates must accompany the package

My recommendation for anyone planning a Type B air shipment: start the approval process early. Unilateral approvals can take weeks. Multilateral approvals for B(M) packages across multiple transit countries can take months. The classification and route should be locked in well before you plan to ship.

Try it free for 7 days.

Common Questions

What is a competent authority in radioactive material shipping?

A national government agency responsible for regulating the safe transport of radioactive material. In the US, the NRC handles package design approvals and DOT/PHMSA handles transport regulations. Each country on a shipment's route may have its own competent authority that must review and approve the package or be notified of the shipment.

What is the difference between unilateral and multilateral approval?

Scope of approval. Unilateral means only the country of origin's competent authority must approve the design — that certificate is then recognized internationally. Multilateral means the country of origin and every country through or into which the shipment is transported must independently approve it.

Does a Type A package need competent authority approval?

No. Type A package designs are self-certified by the shipper. The shipper must ensure the package meets the Type A design requirements, but no competent authority reviews or approves the design. The only certificates that may apply to a Type A shipment are the Special Form certificate (if the material is Special Form) and fissile material certificates (if applicable).

When is advance notification required for an air shipment?

For high-activity Type B/C packages and all special arrangements. Specifically: all Type B(M) shipments, Type B(U) or Type C shipments exceeding 3,000 A1/A2 or 1,000 TBq (whichever is lower), and every special arrangement shipment. Notification must reach each competent authority before the shipment, preferably 7 days in advance.

What is a special arrangement shipment?

Transport under alternative safety measures when the material or package cannot meet standard regulatory requirements. The competent authority must approve that the overall safety level is equivalent to what the regulations would normally provide. Special arrangements always require multilateral approval and advance notification. They are rare and typically used for unique, one-of-a-kind shipments.

Summary: Your Approval and Notification Checklist

Before shipping radioactive material by air, verify:

• ☐ Determine whether your package type requires competent authority design approval
• ☐ Identify whether the approval is unilateral or multilateral
• ☐ For multilateral approvals: obtain approval from every country on the route
• ☐ Check whether a separate shipment approval is required (high-activity B(M), high-CSI fissile)
• ☐ Determine whether advance notification is required
• ☐ If notification required: send to all competent authorities at least 7 days before shipment
• ☐ Include all required information in the notification (certificate marks, routing, radionuclide, activity)
• ☐ Submit copies of certificates to competent authorities before the first shipment
• ☐ Include copies of all applicable certificates with the physical shipment
• ☐ Reference certificate identification marks in Sequence 4 of the DGD
• ☐ Ensure any non-English certificates include an accurate English translation

Regulatory References

IATA (Air Transport):

• IATA Dangerous Goods Regulations §10.10.2 — Design and shipment approvals and notification
• IATA DGR §10.0.4 — Shipment approval by special arrangement
• IATA DGR §10.8.7 — Competent authority certificates (documentation)
• IATA DGR §10.8.3.9.4 — Sequence 4 of DGD (certificate identification marks)
• IATA Dangerous Goods Regulations — Official publication page

DOT/NRC (US Competent Authority):

• 10 CFR Part 71 — NRC packaging and transport of radioactive material (design approvals)
• 49 CFR 173.471 — DOT requirements for Type B packages (approval references)

Related RadShip Guides:

• Package Types Explained (Excepted, IP, Type A, Type B)
• NRC vs DOT: Understanding Both Sets of Regulations
• UN3321–3333: Fissile Classifications
• Special Form vs Normal Form
• The DGD: Class 7 Guide
• Shipping Radioactive Material by Air: IATA Overview