(A shipper wishes to use his own ULD as outer packaging. Is this permissible?)

Q.
A shipper wishes use his own ULD as outer packaging for a shipment of UN 3077 Environmentally hazardous substance, solid, n.o.s. Class 9 PG III. This substance is said to be material for making pharmaceutical products. The ULD is special and capable to control temperature. May an airline accept carriage? (31 Jan 13)

A.
I am assuming that the base of that ULD is not compatible with the aircraft restraining system and it does not have an airworthiness certificate. I am also assuming that this ULD will have to be mounted on an airline-owned airworthy pallet and thence loaded onto the aircraft by having the airline pallet engage the aircraft restraining system. As long as that ULD is in compliance with the requirements of PI 956, the airline can accept that ULD as outer packaging. Transportation charges will be levied on the gross weight of the ULD. In addition, the temperature control system of the ULD must be verified whether dry ice is used or not.


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