IAEA-CN-187-3B/3

Denials of Shipments for

Radioactive Material – Indian
Perspective

R.K. Singh
Radiological Safety Division
Atomic Energy Regulatory Board
Mumbai, India
E-mail:rksingh@aerb.gov.in
Indian Transport Regulations

AERB Safety Code on Safe Transport of

Radioactive Material
- based on IAEA transport regulations

- adoption of IAEA regulations in toto

under process
International Transport Regulations

UN Model Regulations
- IAEA regulations (TS-R-1)

- IMDG Code

- ICAO technical instructions

- IATA DGR

Uniform and harmonious for class 7

Regional regulations/agreements
Denials & Delays of Shipment (DoS) of RAM

A denial is a refusal (explicit or implicit) to carry a

shipment of radioactive material though it conforms
to all the applicable international AND national
Regulations.
 non-compliance with regulations CANNOT lead to Denial
Reporting/Notification.
 accurate definition of delay yet to come
 Often, delay is a form of disguised denial
 the concept of denial covers the delay also
 IMO adopted the word “difficulty” to cover unexpected
events, like denials and delays.
Reasons of DoS of Shipment of RAM
Feedback from stake holders of an awareness
programme, reasons of DoS varied in nature :
(1) Perception of unnecessary fear for transport of RAM

(2) Lack of confidence and awareness on the

procedures for acceptance of shipment of RAM

(3) Fear of risk during accidents with packages

containing RAM

(4) Alleged policy of the carriers not to accept

consignment of dangerous goods
Reasons of Denials & Delays ......
(5) Inadequate infrastructure at the major/transit
ports

(6) Problems of trans-shipments

(7) Shippers not having access to undergo dangerous

goods training.

(8) Lack of awareness on how important movement

of RAM for human welfare

(9) Deficit of enthusiasm at Corporate Level

 Resolving the Issues
Reasons cited in (1), (2) and (3) decreasing due to
increased awareness

In the last three years, four cases of denials of shipments

(one for import and three for export)

All the cases were due to reasons cited in (4), (5) and (7)

Cases with reasons in (4) & (5) difficult to deal with

Cases with reason in (7) are comparatively easy to

resolve.
 Case study 1
Background
- Two old brachytherapy units deploying Cs-137
sources (cat. 4) decommissioned in 2007
- NOC for export issued in 2009
- Hospital approached two airlines through forwarding
agents. Both refused

Operator (1) ‘s views

- Strictly follows IATA DGR manual while accepting
Class 7 cargo
- Shipper should be Cat. 1 DG training qualified
- Cargo should meet all points given in check list
 Case study 1...
Regulator’s views
● Shipper authorised by the CA to forward the radioactive
material for transport in accordance with national regulations
● Category 1 DG Certified person certified after a course lasting
one week
● Radiological Safety Officer (RSO) of the hospital approved by
CA after completing a comprehensive course taking more
than one year in radiological safety
● Shipper in the case of the said hospital fully compatible to the
norms prescribed in the IATA guidebook
Results
● Operator agreed with AERB’s view
● Informed the shipper to submit all the relevant papers
regarding the eligibility of the shipper to export Class 7 cargo
● Agreed to take further action
 Case study 1...
Operator (2) ‘s views
Policy decisions on DG taken by the Manager (DG)
located abroad (HQ).
Two kinds of embargoes – (1) Station-based embargoes (2)
Global embargoes.
Procedure followed on DG shipment
- shipper submits the DG shipper’s certification along with
AERB’s permission
- concerned official alerts Regional Head, located at an
Indian city
- DG qualification of shipper to be compatible to
what given in IATA DGR
- DG qualified person should handle the shipment at
the consignor’s side
 Case study 1.....
Regulator’s View
● In case of Class 7 cargo, RSO at the shipper’s
institution is more qualified than a Category 1 DG
certified person

Results
- Operator’s official asked the shipper to submit copy of
his RSO certificate
- Agreed to forward to HQ of the operator to seek one-
time clearance.
- Shipper and the agent of the brachytherapy unit
agreed to provide this to enable the export of the
decayed sources
 Case study 2
Background
- Consignment of Co-60 source (Category 1) to be
imported in 2009
- Consignment by nature of its over-dimension and
considerable weight preferred to be transported by
sea mode
- Consignment cleared from both the competent
authorities of the two countries for import and export
as required in IAEA Code of Conduct
- Shipment could not take place due to the objections of
from both the international carrier and port authority
in India
- Importer approached AERB to sort out the matter
 Case study 2...
Carrier’s and Port Authority’s Views
- Consignment is inside a freight container of open
top and side type
- Will allow all radiation coming out from the container
- Exposures at large to the people around and
particularly the workers who would handle it
Regulator’s View
● Source container is a Type B(U) Package;
package fixed to a specialized freight container for
ease of handling
● Openings of the freight container on top and
side for sufficient air circulation around consignment
● Prepared with proper documentation as required by
the IMDG Code
 Case study 2...

Results

- Both the sea carrier and the port authority

convinced that it was a case of unfounded
fear of radiation
- Consignment was imported into the country
 Case study 3
Background
- An Indian agent/vendor wanted to export in 2011
two defective parts containing Ni-63 sources
(category 5) used in ECD to foreign supplier for
replacement

- Agent approached both the foreign airlines which

transported earlier similar sources to the country

- Both the airlines refused

- Agent approached AERB to sort out the matter

 Case study 3....
Carriers’ Views
- Shipper should submit the DG declaration,
be a DG trained person
- Shipper not a DG trained person

Regulator’s View
● Consignment a low level radioactive source with
UN No 2911,RADIOACTIVEMATERIAL,EXCEPTED
PACKAGE – INSTRUMENTS
● Neither Shipper’s DG Declaration nor Notification
(for DG Goods) to Captain (NOTOC) required
● Source has been packed in the original container
and the shipper has got all the necessary
clearances for export from AERB
 Case study 3...

Results

- Airlines accepted the consignment for transport

New Issues
Understood from the feedback of participants in an
awareness programme held in March 2011
 Concept of cooling period for cargoes before loading
into the aircraft has become almost obsolete
 Airlines now want faster and efficient screening of
cargoes including Class 7
 Facility for such fast and efficient screening system
not available at every major airport
 As such the shipper, sometimes, requires to present
the Class 7 cargo just two to three hours before the
aircraft departs
 Creates an extremely difficult condition for the
shippers to follow while getting the consignment
accepted
 New Issues...
 Common perception that the airlines reject the shipment
at the last moment on flimsy grounds.
 Understood that the airlines forced to reject the
shipments (complying with all other regulatory
requirements) at the last moment due to :
 Unavailability of DG trained pilot
 Improper documentation
- rejections are also due to improper documentation
coming to the airlines without proper scrutiny
through at least 2/3 agents taking 4/5 days
- airlines do not accept consignment directly from
the shippers/consignors.
- when the mistake found out by the airlines the
shipment assumed to be rejected at the last
moment
 New Issues...
 One of the main reasons of rejection of shipment
- No connecting flight and consignment to be carried
up to transit station
- A single airline does not fly in all sectors
- On many occasions they have to rely on the
service provided by other code sharing/partner
airlines
- Acceptance for shipping from transit stop(s) to
final destination depends solely upon other airlines
and getting such confirmation prior to shipment
takes a long time
- Ultimately discourages the shipper as well as the
official of the initiating airline to pursue further
Suggested Tips for Regulators (negotiators)
 Expected to be well conversant with IAEA transport
regulations(TS-R-1)
 Be thorough with IATA DGR and IMO IMDG Code
 Show respect to others’ Regulations
 Try to get the explanations of requirements first from the
carriers’ side
 Don’t hesitate to accept the lapses on the part of shipper
 See always whether the lapses can be corrected in some
way or other
 Try to allay the fear of radiation if felt necessary
 Explain the potential grave consequences of DoS
 Never force your idea to the carrier, misuse your power
 Say always ”thank you for educating me about your
regulations “with a big smile,”we ‘will come back to you”
 Consequences of DoS of Shipment of RAM
Some of the consequences of denials and delays of shipment
are
 Financial implications due to non-commissioning/operation of
big industrial facilities for want of source (applicable in case
of fresh source)
 Unnecessary radiological hazard that may be caused due to
improper and/or long storage of the source
 User may lose interest over the safe custody of the disused
source which is a great potential to become orphan
[Ref: IAEA RCA RAS/9/042, Report on “Sharing Best Practices in Managing
Disused Sources and Networking, Dec 7 -11, 2009, Jakarta]
 Depriving the users of the useful application of RAM
particularly for health
 Re-tuning of International Efforts
 The denials and delays of shipment of RAM is a global
problem as well
 IAEA took the initiative to address the issue by
constituting an International Steering Committee of Denials
and Delays of Shipments through the resolution of General
Conference in September 2005
 Involved other organizations like ICAO, IMO, IATA etc.
Moreover, there are National Focal Points (NFP) in member
countries and Regional Co-ordinators for reporting such
incidents of denials and delays to IAEA
 IAEA conducted throughout 2007, 2008 and 2009 many
regional workshops, involved approximately 300 participants
and dealt with the issue of denials and delays of radioactive
material
 Set goal to eliminate DoS by 2013
 Re-tuning of International Efforts...
Re-tuning of the international efforts suggested by way of
(1) Involving directly the representatives of major
international airlines/sea carriers in the meetings
(2) Creating a common pool of airlines(similar to alliance
partners) having a mechanism for easy access and
prompt response to the queries raised by an initial
operator accepting Class 7 cargo requiring further
transport via transit stops(s)
(3) Permitting Radiation Protection Officers (RPO)
/Radiological Safety Officers (RSO) to sign the DG
Declaration (for Class 7) as required by IATA DGR
and IMO IMDG Code; and
(4) Replicating internationally Indian model of training
with no costs to the participants which have many
advantages
 Conclusion
 Transport of RAM complied with all regulatory
requirements expected to be as smooth as transport of other
classes of dangerous goods
Any difficulty of shipment of RAM matter be better
discussed amongst all stake holders to sort out the lapses, if
any
 A genuine reason for denial and delay should be reported
to the designated National Focal Points in the specified
format
 Shippers are expected to fulfil the requirements of the
concerned airlines and sea carriers as specified in IATA DGR/
IMO IMDG Code at the time of booking class 7 cargo
 Carriers also expected to tell the reason for denial, if any
 Building up mutual trust and co-operation amongst all will
be the key to the success of goal to make sure that DoS of
RAM would be reduced to a level not worthy of reporting
 Conclusion...

 From the Indian experience it can be inferred that the

intervention of the regulatory body in case of any stalemate
helps a lot to resolve the issue
Thank You
Merci
Gracias
Danke