Air transport Dangerous goods

For the civil transport of dangerous goods (DG) by air the International Civil Aviation Organization (ICAO) has published technical instructions (ICAO-TI) with many specific requirements. The ICAO-TI are referenced in our  national law on the transport of dangerous goods (GGBG) (ris.bka.gv.at) and have to be complied with. Besides this legal basis the International Air Transport Association (IATA) publishes the IATA-DGR as an agreement between the airlines.

If and how a planned transport is possible, must be checked by the undertakings involved in the carriage of DG according to the (international) regulations. Therefore, the regulations mention mandatory trainings and assessments for involved personnel – partially irrespective of whether they are involved in the transport of DG, so they can recognize DG and contact others if necessary.

Approvals and exemptions according to Part 1;1.1.2 and 1.1.3 ICAO-TI

Some dangerous goods need special approvals for air transport. Others are forbidden. For forbidden transports an exemption may be granted, but such an exemption is needed from all involved countries.

The competent authority for those DG-permits (approvals and exemptions) is Department ST3 – Transport of Dangerous Goods (by all Modes) and Container Safety (IV/ST3, see contact) in the Federal Ministry of Innovation, Mobility and Infrastructure (BMIMI).

Applications

To facilitate the procedure a  common application form for exemptions (easa.europa.eu) and its  guidance material (easa.europa.eu) may be used, which both can be found on the  website of the European Union Aviation Safety Agency (EASA) (easa.europa.eu). For the time being, that form may also be used for approvals.

However, Austria can only partially follow the common process that is mentioned in that common application form and the guidance, as the exemption itself requires to be an administrative decision (in German: "Bescheid") following the national law and its formal appearance – so the form is not becoming the exemption itself.

Additionally to all the information/documents mentioned in the common application form and therefore deviating from the common process, also the following information must be provided upfront, so the authority in charge is able to check if there is any doubt regarding safety of the planned transport – according to § 9 GGBG:

• Information has to be given in B2 of the common application form and therefore the relevant documents have to be submitted – e.g. "Risk Assessment" that is mentioned in point 4 of appendix 1 of the common exemption form, "risk mitigation factors", "military standards" and/or "safety control measures"
• Time of departure, if flying from Austria
• Date of planned arrival
• ICAO-Code of the Operator
• Additionally for each UN-Number: summary of not only the UN-Number, but also of the type of Package/s with code (e.g. "2 fibreboard boxes 4G")
• AOC has always to be submitted.
• Certificate of registration (in German: "Eintragungsschein")
• Certificates of training and information about instructions to all involved personnel – especially how the responsibilities from the ICAO-TI for the operator and Loading Personnel / Supervisor are guaranteed
• For Explosives and if the Austrian authority requests: "Safety Case" regarding all safety related areas of the planned transport – e.g. type, quantity, packaging of DG, type of aircraft, modifications, compartments, safety devices (fire-fighting equipment, sensors, other systems regarding safety); together with information/proof that the person issuing the safety case is skilled for this task.

Fees

• Exemption: 174,00 euros (§ 9/4 GGBG)
• Application: 21,00 euros (§ 14 TP 6 GebG)
• Enclosures: 6,00 euros for each electronical submitted document (§ 14 TP 5 GebG)

The payment is only to be done after the exemption is issued as an administrative decision, as it will be described within.