Lithium Batteries and Paint Offered for a Passenger Flight
An A321 passenger flight RPLL–RJAA is loading in Manila. The forwarder presents two consignments. Consignment A is eight fiberboard boxes of UN3480 lithium-ion batteries, 10 kg net each, packed under PI 965 Section IA, state of charge 30%, labelled Cargo Aircraft Only. Consignment B is two steel drums of UN1263 Paint, Class 3, PG II, 20 L each, flash point 18°C, not marked Cargo Aircraft Only. The aircraft has 1,200 kg of cargo capacity left and a lower-deck compartment with smoke detection and fire suppression. The NOTOC has not yet been prepared. The ramp agent says both are "just Class 9 and paint" and asks to load them together near the forward door for quick unloading. The flight is passenger-carrying and the commander has not been briefed.
1. Determine the acceptance status of each consignment on this passenger flight.
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Consignment A must be rejected. UN3480 lithium-ion batteries packed under PI 965 Section IA are cargo-aircraft-only, and the packages are already labelled Cargo Aircraft Only. They are forbidden on a passenger-carrying flight regardless of the 30% state of charge, which is a condition for the cargo-aircraft packing section, not a permission for passenger aircraft.
Consignment B must also be rejected as presented. UN1263 Paint, Class 3, PG II, has a passenger-aircraft package limit of 5 L per package. Each 20 L drum exceeds that limit. The shipment could only move if repacked into packages within the passenger limit, with correct packaging, marks and labels, and if the total aircraft quantity limit is met. A 20 L steel drum is not acceptable on this flight. The ramp agent's description is irrelevant; acceptance is based on the entry, packing instruction, quantity limits and aircraft type.
2. If the operator substitutes a cargo aircraft, what changes for these two consignments?
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On a cargo aircraft, Consignment A may be accepted under PI 965 Section IA if the operator holds the required dangerous goods approval, the packages meet the applicable packing and state-of-charge conditions, and the Cargo Aircraft Only label is present. The 30% state of charge is consistent with the shipped-alone lithium-ion battery requirement.
Consignment B may be accepted in the 20 L drums if the cargo-aircraft package limit for UN1263 PG II is met and the total aircraft limit is not exceeded. The paint remains a Class 3 flammable liquid, so it must be kept away from heat and incompatible materials and secured for flight. The substitution does not remove the need for a NOTOC, commander notification, correct documentation, and checking State and operator variations. The load planner should also confirm the aircraft's cargo compartment fire-protection capability and the operator's DG manual before loading.
3. What NOTOC, loading and emergency information must be provided before departure?
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A NOTOC must be prepared showing, for each consignment: UN number, proper shipping name, class/division, subsidiary risk if any, PG for the paint, number of packages, net quantity, and the loading location. The commander must be notified and given the NOTOC before departure, with a copy available on the ground. The load must be secured, accessible as required, and separated from heat sources and incompatible cargo.
The ramp agent must not load either consignment on the passenger flight. For a cargo aircraft, the loading supervisor should confirm the Cargo Aircraft Only label for the batteries, the correct flammable-liquid label for the paint, and the emergency response information for both. The commander should be briefed on the nature and location of the dangerous goods and the fire-fighting considerations: lithium battery fire and flammable liquid fire require different responses. The dispatcher should also ensure the 24-hour emergency contact is available and that any change is reflected in the final load documentation.