(Question on a Radioacctive Material shipment.)
Q.
There is a radioactive material shipment to be flown LHR-FRA-JFK by Lufthansa. If it is for medical purpose, US State Variation USG-10 (a) can be applied and passenger aircraft carriage is permissible. However, the shipment is not marked as for medical purpose. The DG declaration was erroneously issued at London for Passenger Aircraft carriage. As result, CAO label was not affixed on the package, and the shipment flew LHR-FRA on a passenger aircraft. Lufthansa’s ground crew at FRA spotted the error, and the shipment was withheld. Please advise how this shipment should have been handled?  (30 Jun 20)
A.
Since the final destination is USA, the shipper should have referred to US State Variation USG-10 (a). Since the material was not marked as for medical use, the shipper should have made the DG declaration for CAO carriage. The shipper could have referred to DGR 10.8.3.5.2 and entered the words: “This shipment may be carried on passenger aircraft outside US jurisdiction” and without applying the CAO label, he could have transported the shipment LHR-FRA on a passenger aircraft since that sector was outside of US jurisdiction. However, the next sector FRA-JFK is within US jurisdiction and obligated to use CAO aircraft. Upon arrival at FRA, you will need to have LH groud crew to add a CAO label, and load it on a CAO aircraft for JFK. For operational impracticality, if it is difficult to have the CAO label added at FRA, the best bet is to have the declaration issued in LHR for CAO carriage, and the shipment flown on CAO throughout the journey.

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