(A question on loading Aircraft Equipment.)

When transporting aircraft maintenance equipment aboard a designated flight as “aircraft equipment”, a list of such items is made. Items discussed are “Batteries, dry” and “UN3496 Batteries, nickel-metal hydride”. Regulations require reference to SP A123 and SP A199 must be noted on the AWB, however there is no AWB issued since these are loaded as “aircraft equipment”. IATA DGR states such wordings as “Not restricted as per Special Provision Axxx” must be noted on the AWB. May we show such wordings on the list of aircraft equipment or on a separate sheet. (31 May 17)

When items are not transported as cargo, naturally, there is no AWB issued. To be eligible to load and transport items as “aircraft equipment”, DGR must be satisfied: “Articles and substances which would otherwise be classified as dangerous goods but which are required to be aboard the aircraft in accordance with pertinent airworthiness requirements and operating regulations or that are authorized by the State of the Operator to meet special requirements.” may be permitted as “aircraft equipment”. Therefore, provided these batteries are legitimately recognized as “aircraft equipment”, there is no need to apply other requirements of the DGR.

The classification of these batteries whether they are legitimate “aircraft equipment” must be addressed first. If negative, AWB must be prepared and the batteries must be shipped as cargo. I feel that you are making a stretched interpretation of the batteries which are not really essential onboard for the flight but is to be used after landing for maintenance purposes.

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