BADG - 09

Bulletin & Alert | Dangerous Goods

Ref: AVSEC-OIN/30100/ 81564/23

Date: 05th May 2023

Classification: URGENT

Subject: New Mandatory Requirements for UAE Originating Dangerous Goods Shipment(s) Offered or Prepared
to be Offered for Air Transport.

Purpose: The aim of this BADG is to share GCAA observation concerning the identification of a deficiency/gap
in the process followed by numerous dangerous goods certified freight forwarders/cargo agencies when
offering UAE originating dangerous goods shipments for air transport as cargo. The said deficiency/gap in the
process has resulted in dangerous goods incidents and the discovery of undeclared dangerous goods, which
were identified, stopped and reported to GCAA. If the shipments had been accepted and transported on an
aircraft, this could have potentially compromised the safety of the aircraft and its occupants.

Elaboration: The recent investigations conducted by GCAA on dangerous goods reported occurrences,
revealed that the UAE State Variations included in the current editions of the ICAO Technical Instructions for
the Safe Transport of Dangerous Goods by Air (AE 2) and the IATA Dangerous Goods Regulations (AEG-02) is
being misinterpreted by numerous Freight Forwarders and Cargo Agents regardless whether they are a
dangerous goods certified entity by GCAA or not and Shippers. In several occasions, though the dangerous
goods transport documents appeared to be prepared in accordance with the provisions of the UAE Civil
Aviation Regulations “CAR Part VI”, unfortunately the implemented process with regards to tendering the
physical dangerous goods shipment(s) to the air operator or ground handling agent acceptance docks,
contained a safety deficiency because the shipments referred to in the said occurrences were tendered to the
acceptance docks by a Non-Certified Entity.

It is very unfortunate that this process also resulted in occasions of non-compliance with the provisions of
Subsection 5.3.11 of CAR Part VI “Accurate and Correct Declaration of Cargo”, as has provided the opportunity
to some Non-Certified Entities/Shippers to offer or caused to offer (whether intentionally or unintentionally)
undeclared or mis-declared dangerous goods for air transport, by taking advantage of the absence of the
dangerous goods trained employee of the certified entity, after the latter completed their physical inspection
and documentation check and left the facility of the Non-Certified Entity/Shipper.

The lack of dangerous goods training continues to be one of the main contributing factors which resulted in
the conduct of such malpractice by the involved Freight Forwarders, Cargo Agents and Shippers.

BADG 09 | Dated 5th May 2023 Department of OIN | AVSEC Affairs Sector
(Cont’d) Elaboration: In the same context, some Entities also unintentionally believed and or assumed that;
dangerous goods which are not subject to all requirements of the ICAO Technical Instructions for the Safe
Transport of Dangerous Goods by Air or the IATA Dangerous Goods Regulations are not falling within the
scope of the UAE Civil Aviation Regulations CAR Part VI and or the State Variations referenced above. This
interpretation is NOT CORRECT! The UAE State Variations apply to any and all articles and substances listed in
Table 3-1 of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air or in Section 4.2
of the IATA Dangerous Goods Regulations.
It is a matter of extreme importance to remind ALL ENTITIES and emphasize once again that NO ENTITY shall
offer or prepare to be offered UAE originating dangerous goods shipment(s) for transport by air unless the
Entity is Dangerous Goods certified by the UAE General Civil Aviation Authority and meets all of the provisions
of the CAR Part VI of the UAE Civil Aviation Regulations.

Required Action:
1- GCAA Dangerous Goods Certified Freight Forwarders/Cargo Agents shall ensure;

1.1 That the physical inspection and documentation check and any other activity (as applicable) related to
dangerous goods shipment(s) offered or prepared to be offered for air transport, is conducted by a
dangerous goods trained employee.

1.2 That the dangerous goods shipment(s) is tendered to the acceptance docks at cargo acceptance area at the
concerned airport by their dangerous goods trained employee(s).

1.3 That their employee(s) possesses a proof/evidence of their dangerous goods current training, and share it
with the acceptance staff of the Air Operator or Ground Handling Agent (as applicable).

1.4 That their employee(s) possesses a valid ID proving that they are an employee of the same certified entity
of which their GCAA Dangerous Goods Certification Number shown/reflected on the Handling Information
Column of the Air Waybill, and share their valid ID with the acceptance staff of the Air Operator or Ground
Handling Agent (as applicable).

1.5 That the mandatory requirements referred to above in paragraphs 1.1,1.2,1.3 & 1.4 shall apply to all
dangerous goods shipment(s), regardless the shipment(s) or part shipment(s) require Dangerous Goods
Declaration or not, including dangerous goods which are not subject to all requirements of the ICAO Technical
Instructions for the Safe Transport of Dangerous Goods by Air or the IATA Dangerous Goods Regulations.

1.6 To provide GCAA with a proof of dangerous goods training for all their operations staff to reconfirm their
compliance with the provisions of Subsection 4.1 of CAR Part VI. Such proof must be shared with GCAA, no
later than 26th May 2023, at dangerousgoodsteam@gcaa.gov.ae

1.7 That in the absence of the proof of training referred to in paragraph 1.6, shall provide GCAA with a
detailed dangerous goods training plan showing the scheduled training dates, names of staff and name of
the training provider for all their operations staff who must be trained commensurate with the functions
they perform. This is in order to reconfirm their understanding to the importance of compliance with the
provisions of Subsection 4.1 of CAR Part VI. Such detailed plan must be shared with GCAA, no later than
26th May 2023, at dangerousgoodsteam@gcaa.gov.ae

1.8 To disseminate this information to all their concerned employees and customers, for compliance and
implementation.

BADG 09 | Dated 5th May 2023 Department of OIN | AVSEC Affairs Sector
2- Air Operators & Ground Handling Agents shall;

2.1 Disseminate this information to all their concerned employees and customers, for compliance and
implementation.

2.2 Emphasize the importance of dangerous goods training by circulating the mandatory dangerous goods
training requirements as defined in Subsection 4.1 of the UAE Civil Aviation Regulations “CAR Part VI” to
all their customers regardless if they are dangerous goods certified by GCAA or not.

2.3 Report observed non-compliance with the new requirements referred to in this BADG, to GCAA.

3- All Freight Forwarders/Cargo Agents operating in the United Arab Emirates regardless if they are
dangerous goods certified by GCAA or not, must ensure;
3.1 That ALL THEIR CARGO OPERATIONS STAFF are dangerous goods trained commensurate with the function
they perform as defined in Subsection 4.1 of the UAE Civil Aviation Regulations “CAR Part VI”.
https://www.gcaa.gov.ae/en/epublication/civil-aviation-regulations

3.2 NOT to offer or prepare to offer UAE originating dangerous goods shipments for air transport, including
dangerous goods which are not subject to all requirements of the ICAO Technical Instructions for the Safe
Transport of Dangerous Goods by Air or the IATA Dangerous Goods Regulations.

It is a matter of importance to reemphasis that all entities must approach matters related to the transport of
dangerous goods by air with utmost discipline and responsibility!

Non-compliance with the Civil Aviation Regulations (CARs) “CAR Part VI” shall result in stricter legal
consequences. Therefore, deviation is NOT PERMITTED!

Contact us: for further clarifications regarding this BADG, email at dangerousgoodsteam@gcaa.gov.ae

This BADG shall take effect from 15th May 2023

“This information shall be incorporated into the next revision of CAR Part VI”

For/ Expert Dangerous Goods

Aviation Security Sector

Ahmed Wagih Wahbi

BADG 09 | Dated 5th May 2023 Department of OIN | AVSEC Affairs Sector