(How to prepare AWB for Radioactive Material Excepted Packages.)
Q.
In preparing AWB for Radioactive Material Excepted Packages, we are guided by a Note appearing under DGR 10.8.8.3.3 (a) which reads: “It is acceptable to have the actual shipper and consignee name and address in another location on the air waybill.” Does this Note mean it is permissible to have the name and address information shown on the House Manifest? When inspecting an actual shipment of consolidated cargo containing a package of Radioactive Material Excepted Package, the names and addresses of the shipper and consignee could not be found on any document.  (31 Mar 17)
A.
DGR 10.8.8.3.3 stipulates as a prerequisite that for Radioactive Material Excepted Package, information listed as (a) through (e) must be provided in the “Nature and Quantity of Goods” box of the air waybill or other similar document.

DGR Figure 10.8.H demonstrates an example of how it should be shown on the AWB. After finding out that an AWB has dedicated columns to show the names and addresses of the Shipper/Consignee, the Note under (a) must have been inserted. The members of IAEA who are drafting the rules may not be aware of the minute details of an AWB format, therefore, the rule was drafted to show all the information in the “Nature and Quantity of Goods” column on the AWB. They may not be aware of a HAWB or House Manifest of a consolidated shipment, therefore entry of the information on such a document was not mentioned.

The starting sentence of DGR 10.8.8.3.3 as well as the wording of the Note concentrates the entry of the information on the AWB in mind. In actual practice, these information of the true shipper and true consignee must be shown on the House AWB. The consolidator is the Shipper of the MAWB therefore the MAWB is not the place to enter such information. Since the Airline is unable to check the HAWB, it is most desirable that these information be entered on the Remarks column of the House Manifest or have the information displayed on an attached sheet to the House Manifest. Even though, the HAWB cannot be checked by the Airline, information (a) through (e) must be shown on the HAWB.

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