(Please clarify the Radioactive Material AWB requirements spelled out in DGR 10.8.8.3.)

Q.
In 10.8.8.3.3(a) it specifies that the name and address of the shipper and consignee must be entered in the “Nature and Quantity of Goods” box. It is followed by a Note saying: “It is acceptable to have the actual shipper and consignee name and address in another location on the air waybill.” Please clarify what does this mean.For straight shipments, will the information of the shipper and consignee on the AWB suffice? If in consolidations, does it mean that the shipper/consignee information on the HAWB need to be shown on the MAWB? Is my interpretation correct?  (31 Jan 17)

A.
Let us review how this requirement came into being. Most likely the technical experts of IAEA may not have detailed knowledge on how an AWB is formatted. They may not have clear information about straight shipments or consolidations which brings a doubt whether they understood House AWBs and Master AWBs. One vital element is that there is a “half life” deterioration nature with radioactive material which make mass production unpractical. You cannot shelf stock radioactive material as they decay with time.

Pharmaceutical radioactive material are ordered from an overseas hospitals. Production is based on orders received and rushed to the airport just in time barely making the flight. As such, radioactive material shipments are all “urgent priority shipments”. They do not fit into consolidations where shipments from multiple shippers are staged to form a consolidation. Radioactive material cannot stand staging because of deterioration due “half life”.

The entries required per 10.8.8.3.3 (a), (b), (c), (d), (e) which is illustrated on the AWB image shown in Figure 10.8.H, must be shown in the “Nature and Quantity of Goods” box. As aforesaid, it is unlikely that radioactive material shipment would be in a consolidation, it is therefore assumed that this requirement is aimed for straight AWBs. Obtaining information that there are dedicated boxes on an AWB for shipper and consignee names and addresses, a Note was added in sub-paragraph (a) exempting duplicate entries.

But if a radioactive material shipment is included in a consolidation which normally would not happen, thence the required data 10.8.8.3.3 (a) through (e) must be shown on the HAWB. Since the airline cannot inspect the HAWB, the entire data must be reproduced on the MAWB showing the names and addresses of the true shipper and consignee as appearing on the HAWB. If there are multiple radioactive material shipments in a consolidation, reproducing all such data will simply become impractical. Radioactive material shipments plainly do not fit into a consolidation due to its “half life” and its “urgency” not allowing staging.


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