A.
Who must sign the Declaration form is spelled out in DGR 8.1.4.1.1: “The declaration form must be signed and dated by the shipper or a designated representative as described below.” The term “designated representative” is further defined in the latter part of DGR 8.1.4.1.1 as follows: ”It is acceptable for persons or organizations (including consolidators, freight forwarders and IATA cargo agents) employed by the shipper to act on their behalf to undertake the shipper’s responsibilities in the preparation of the consignment provided that they have been trained as required by Subsection 1.5 to sign the Shipper’s Declaration for Dangerous Goods.”

So, you need a “Handling Agreement” between the Airline and the Forwarder or Cargo Agent to verify his capacity. Furthermore, there are cases stemming from the organizational structure of a company where all outgoing formal documents such as the Shipper’s Declaration for Dangerous Goods, some firms exercise the practice of having the declaration prepared by a DG license holder but signed by a company officer having the authority to place signatures on outgoing formal documents. Depending on the importance of the document, the signatory can be the president, the vice president-in-charge, department directors, managers or supervisors.

With the foregoing in mind, let me answer your questions.

(1) It is the general practice that the Declaration are to be signed by the Shipper appearing in the Shipper’s box. If there is a designated representative “employed by” the shipper, such designated representative may sign the declaration on behalf of the shipper. The words “employed by” does not mean that the cargo agent is on the airline’s payroll. “Employed by” has the same meaning as “engaged by” or “under contract”.

(2) In the case of consolidation, the House AWB shipper prepares and signs its own declaration. If the House AWB shipper has a handling agreement with the forwarder, then the forwarder may sign the Declaration on behalf of the House shippers.

(3) If you use the forwarder’s name as the “shipper” instead of the airline, you will lose all the privilege granted to the airline, such as stipulated in DGR 2.5.2.1 Aircraft Spares where airlines are permitted to use special containers for aircraft components/parts designed by Airbus or Boeing, whereas if you do not use the airline’s name as shipper, you must use UN certified packagings to ship all such items.

A simple handling agreement concluded between the Airline Maintenance group and the Forwarder giving the authority to sign AWBs and Declarations on behalf of the airline will solve this issue. AWBs and declarations will carry the airline’s name in the shipper/consignee columns, and the forwarder will be given the authority to sign the documents on behalf of the airlines.