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Based on 49 CFR (DOT) and 10 CFR (NRC) as currently published in the eCFR

LSA and SCO by Air: Activity Limits and Industrial Packaging Requirements

How to ship Low Specific Activity material and Surface Contaminated Objects by air under the IATA Dangerous Goods Regulations, with per-aircraft activity limits and industrial packaging requirements.

Quick Answer

Low Specific Activity (LSA) material and Surface Contaminated Objects (SCO) can be shipped by air under the IATA Dangerous Goods Regulations, but with per-aircraft activity limits and mandatory industrial packaging. SCO-III is the one exception — it is completely forbidden from air transport.

  • LSA-I and non-combustible solid LSA-II/III: No per-aircraft activity limit
  • LSA-II/III combustible solids, liquids, gases: Limited to 100 A2 per aircraft
  • SCO-I and SCO-II: Limited to 100 A2 per aircraft
  • SCO-III: Forbidden in air transport
  • All LSA/SCO: Must be in industrial packages (IP-1, IP-2, or IP-3) — no unpackaged shipments by air

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Why LSA and SCO Air Shipment Rules Matter

Most LSA and SCO shipments move by ground. The quantities are often large, the activity concentrations are low, and ground transport is cheaper. But there are situations where air transport is necessary — time-sensitive waste shipments, contaminated equipment that needs to reach a processing facility, or international movements where ground routing isn't practical.

When those situations come up, shippers who are comfortable with LSA/SCO ground rules can get caught off guard by the air-specific restrictions. Ground transport allows unpackaged LSA-I under exclusive use and has generous vehicle limits. Air transport is more restrictive: everything must be packaged, there are per-aircraft activity limits, and SCO-III is completely prohibited.

I have seen facilities that regularly ship LSA waste by ground assume they can use the same approach for an international air movement. The per-aircraft limit of 100 A2 can be a real constraint when you're dealing with large volumes of LSA-II liquid waste, for example. Understanding these limits before you plan the shipment saves you from discovering them at the cargo counter.

Who Needs to Know This

This applies to anyone who:

  • Ships LSA or SCO material and may need to use air transport
  • Manages radioactive waste that requires international or time-sensitive transport
  • Ships contaminated equipment (tools, components, decommissioned parts) by air
  • Plans transport logistics for RAM and needs to evaluate ground vs. air options

Important: This guide covers IATA DGR requirements for LSA and SCO by air. For ground transport rules (49 CFR), see our UN2912/2913: LSA and SCO guide and our LSA vs Type A: When You Have a Choice guide.

Quick Refresher: LSA and SCO Categories

Before diving into the air-specific rules, here's a quick review of the categories. For full details, see our LSA and SCO guide.

LSA Categories

  • LSA-I: Uranium and thorium ores, naturally occurring radioactive material, unenriched uranium, unirradiated depleted uranium or natural thorium. The lowest-risk category
  • LSA-II: Material with activity distributed throughout, limited to 10&sup-4; A2/g for solids and gases, or 10&sup-5; A2/g for liquids
  • LSA-III: Solids (e.g., consolidated wastes, activated materials) where activity is distributed relatively uniformly and the estimated average specific activity does not exceed 2 × 10&sup-3; A2/g

SCO Categories

  • SCO-I: Objects with non-fixed contamination up to 4 Bq/cm² (β/γ) or 0.4 Bq/cm² (α), and fixed contamination up to 40 kBq/cm² (β/γ) or 4 kBq/cm² (α)
  • SCO-II: Objects with higher contamination levels than SCO-I but still within defined limits
  • SCO-III: Large objects that can only be transported under special conditions — forbidden in air transport

Per-Aircraft Activity Limits (Table 10.9.A)

The total activity of LSA material and SCO in industrial packages on any single aircraft must not exceed the limits in IATA DGR Table 10.9.A (IATA DGR §10.9.3.3.3):

Source: IATA DGR Table 10.9.A — Aircraft activity limits for LSA material and SCO in industrial packages
Nature of MaterialActivity Limit per Aircraft
LSA-INo limit
LSA-II and LSA-III — non-combustible solidsNo limit
LSA-II and LSA-III — combustible solids, all liquids, and gases100 A2
SCO (SCO-I and SCO-II)100 A2
SCO-IIIForbidden

The “100 A2” limit is per aircraft, not per package. If you have multiple LSA-II packages on the same flight, their total activity counts against this single limit. This matters when coordinating with the airline — if another shipper already has LSA material on the same flight, you may be constrained.

Tip: The “no limit” entries for LSA-I and non-combustible solid LSA-II/III don't mean there are zero restrictions. The package still has to meet dose rate requirements (≤ 2 mSv/h surface, or exclusive use/special arrangement), and the dose rate at 3 meters from the unshielded material cannot exceed 10 mSv/h. “No limit” just means there's no aggregate activity cap for the aircraft.

In my experience, the combustible vs. non-combustible distinction catches shippers off guard. If your LSA-II waste is in a combustible matrix — paper filters, resins, organic solvents — you're in the 100 A2 column even though the specific activity is low. The IATA rules are conservative about combustible material on aircraft for obvious reasons.

Industrial Packaging Requirements for Air

All LSA and SCO material shipped by air must be in industrial packages (IATA DGR §10.5.9.1). This is more restrictive than ground transport, where certain LSA-I materials can be shipped unpackaged under exclusive use conditions.

The industrial package type depends on the material category and whether the shipment is exclusive use:

  • IP-1: Acceptable for LSA-I (all forms) and SCO-I under exclusive use
  • IP-2: Required for LSA-II, LSA-III (liquids and gases), and SCO-II. Also required for LSA-I and SCO-I when not under exclusive use
  • IP-3: Required for LSA-III solids and for SCO-II when not under exclusive use

Critical: A single package of non-combustible solid LSA-II or LSA-III material must not contain an activity greater than 3,000 A2 (IATA DGR §10.5.9.2). This is a per-package cap that applies regardless of the “no limit” per-aircraft allowance.

The most common mistake I see is shippers conflating the per-aircraft “no limit” with the per-package limit. You can put unlimited total activity on the aircraft for non-combustible solid LSA-II, but each individual package is still capped at 3,000 A2. For high-activity decommissioning waste, that package limit can be the binding constraint.

Dose Rate Requirements

LSA and SCO packages for air transport must meet two dose rate requirements:

  • Surface dose rate: Must not exceed 2 mSv/h (200 mrem/h) on any point on the external surface of the package (IATA DGR §10.9.3.3.1). Packages exceeding this require special arrangement approval
  • 3-meter unshielded dose rate: The dose rate at 3 meters from the unshielded LSA or SCO material must not exceed 10 mSv/h (1 rem/h) (IATA DGR §10.5.9.6). This is a property of the material itself, not the package

The 3-meter unshielded limit is a ground transport requirement too, but it's worth emphasizing for air because shippers sometimes assume the industrial packaging provides enough shielding that they don't need to check the unshielded dose rate. The IP might reduce the surface dose rate well below 2 mSv/h, but the 3-meter unshielded check is about the material, not the package.

Exclusive Use and Special Arrangement by Air

Exclusive use shipments and consignments under special arrangement have additional restrictions for air transport (IATA DGR §10.9.3.3.2):

  • Exclusive use consignments must not be transported on passenger aircraft — cargo aircraft only
  • Packages with a Transport Index greater than 10 must be transported under exclusive use
  • Packages with surface dose rate greater than 2 mSv/h require special arrangement approval from the competent authority

In practice, most LSA/SCO air shipments I've seen don't require exclusive use. The activity concentrations are low enough that TI stays well below 10 and surface dose rates stay well below 2 mSv/h. The exclusive use requirement becomes relevant mainly with large-volume shipments of higher-activity LSA-II material.

What Changes from Ground to Air?

If you're used to shipping LSA/SCO by ground under 49 CFR, here's what changes when you switch to air:

Key differences between ground (DOT) and air (IATA) for LSA/SCO shipments
RequirementGround (49 CFR)Air (IATA DGR)
Unpackaged LSA-IAllowed under exclusive useNot allowed — IP required
SCO-IIIAllowed under conditionsForbidden
Per-vehicle/aircraft limitVehicle activity limits per 49 CFRTable 10.9.A (100 A2 for combustible/liquid/SCO)
DocumentationShipping paper (BOL)DGD + Air Waybill
Exclusive use on passenger aircraftN/ANot allowed — cargo only
Activity on DGDActivity as multiple of A2 on shipping paperActivity as multiple of A2 in Sequence 4 of DGD (for LSA-II, LSA-III, SCO-I, SCO-II)

The biggest practical change is that unpackaged shipments are off the table for air. If you've been shipping bulk LSA-I ore in a lined cargo container by ground, that same approach won't work for air — it needs to go into an industrial package.

How RadShip.com Helps

RadShip.com helps you navigate LSA and SCO air shipment requirements:

  • RAMcalc — Classifies your material as LSA-I, LSA-II, LSA-III, SCO-I, or SCO-II and determines the appropriate industrial package type
  • Calculates total activity as a multiple of A2, so you can immediately check against the 100 A2 per-aircraft limit
  • Identifies when your shipment qualifies for the LSA vs Type A choice — sometimes a Type A package is simpler for air than dealing with industrial packaging limits

My recommendation for anyone shipping LSA or SCO by air for the first time: run the classification through RAMcalc, then check the A2 multiple against Table 10.9.A before committing to the air routing. If you're over 100 A2 for combustible material, you either need to split the shipment across flights or consider whether a Type A classification is available for your scenario.

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Common Questions

Can LSA material be shipped by air?

Yes. All three LSA categories can be shipped by air in industrial packages. LSA-I and non-combustible solid LSA-II/III have no per-aircraft activity limit. Combustible solids, liquids, and gases are limited to 100 A2 per aircraft (IATA DGR Table 10.9.A).

Can SCO be shipped by air?

SCO-I and SCO-II can; SCO-III cannot. SCO-I and SCO-II are permitted in industrial packages, limited to 100 A2 per aircraft. SCO-III is completely forbidden from air transport (IATA DGR §10.3.6).

What is the per-aircraft activity limit for LSA and SCO?

It depends on the material type. LSA-I and non-combustible solid LSA-II/III have no per-aircraft limit. All other LSA materials (combustible solids, liquids, gases) and all SCO are limited to 100 A2 per aircraft. Each individual package of non-combustible solid LSA-II/III is also capped at 3,000 A2.

Can LSA or SCO be shipped unpackaged by air?

No. All LSA and SCO material must be in industrial packages for air transport (IATA DGR §10.5.9.1). The ground transport option for unpackaged LSA-I under exclusive use does not apply to air shipments.

What's the difference between combustible and non-combustible for Table 10.9.A?

It's about the matrix, not the isotope. A non-combustible solid is material like metal, glass, or concrete. A combustible solid includes paper, resin, wood, or organic materials. The distinction matters because combustible material poses an additional fire risk on aircraft, so IATA applies the 100 A2 limit.

Summary: Your LSA/SCO Air Shipment Checklist

Before shipping LSA or SCO material by air, verify:

  • ☐ Material is correctly classified as LSA-I, LSA-II, LSA-III, SCO-I, or SCO-II (SCO-III is forbidden)
  • ☐ Material is in the appropriate industrial package (IP-1, IP-2, or IP-3)
  • ☐ Total activity per aircraft does not exceed 100 A2 (for combustible LSA-II/III, liquids, gases, or SCO)
  • ☐ Per-package activity does not exceed 3,000 A2 (for non-combustible solid LSA-II/III)
  • ☐ Surface dose rate does not exceed 2 mSv/h (or special arrangement is approved)
  • ☐ Dose rate at 3 m from unshielded material does not exceed 10 mSv/h
  • ☐ If exclusive use: cargo aircraft only (not passenger aircraft)
  • DGD includes total activity as a multiple of A2 in Sequence 4 (for LSA-II, LSA-III, SCO-I, SCO-II)
  • ☐ Package is marked and labeled appropriately with IP type specification
  • ☐ No unpackaged material — all LSA/SCO must be in industrial packages for air

Regulatory References

IATA (Air Transport):

  • IATA Dangerous Goods Regulations §10.3.5 — Low Specific Activity (LSA) material definitions
  • IATA DGR §10.3.6 — Surface Contaminated Objects (SCO) definitions
  • IATA DGR §10.5.9 — Requirements and controls for transport of LSA material and SCO
  • IATA DGR §10.9.3.3 — Air transport limitations (includes Table 10.9.A)
  • IATA DGR Table 10.9.A — Aircraft activity limits for LSA and SCO in industrial packages
  • IATA Dangerous Goods Regulations — Official publication page

DOT Requirements (Ground Transport Comparison):

Related RadShip Guides:

About the Author

Scott Brown is the Subject Matter Expert and co-creator of RadShip.com. He has been a trained hazmat shipper for over 15 years and specializes in DOT Class 7 radioactive material shipping.

This guide is based on the requirements of the IATA Dangerous Goods Regulations and 49 CFR (DOT) as of the publication date. As regulations are amended, RadShip.com is committed to keeping its guides current with the latest requirements.

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