Based on 49 CFR (DOT) and 10 CFR (NRC) as currently published in the eCFR
Passenger vs Cargo Aircraft: IATA Rules for Radioactive Material
The complete guide to IATA DGR aircraft-specific rules for radioactive material. TI limits, prohibitions, separation distances, and how to know which aircraft your shipment can go on.
Quick Answer
The IATA DGR imposes different rules for radioactive material depending on whether the aircraft carries passengers. The key difference is the Transport Index limit per package: 3.0 on passenger aircraft vs 10.0 on cargo aircraft. Beyond TI limits, certain package types and configurations are prohibited on passenger aircraft entirely.
- Passenger aircraft: Max TI 3.0 per package, max 50 combined, no Type B(M), no exclusive use
- Cargo aircraft: Max TI 10.0 per package, no combined TI limit (exclusive use), Type B(M) allowed
- Both aircraft: Max surface dose rate 2 mSv/h, no vented B(M), no pyrophoric, no external cooling
- Separation distances: Mandated minimum distances from passengers/crew based on total TI (Tables 10.9.C/D)
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Try It FreeWhy Aircraft Type Matters
When shipping radioactive material by ground, there is one set of rules. Your package goes on a truck, and the regulations are the same regardless of whether the truck carries other cargo. By air, the rules split based on whether passengers are on the aircraft. This is not a minor distinction — it determines whether your shipment can go at all, and if so, on which flights.
I worked with a facility that needed to return a sealed source to the manufacturer on a tight deadline. They booked the cheapest available flight, which was a passenger service. When they surveyed the package, the TI came in at 4.2. That is well within the ground limit of 10.0 and the cargo aircraft limit of 10.0, but it blew past the 3.0 passenger aircraft threshold. They had to cancel the booking, find a cargo-only service on a different carrier, and the source arrived two days late. The manufacturer charged a rescheduling fee for the calibration slot. A TI survey done before booking would have avoided the entire situation.
Understanding these rules up front lets you book the right service from the start. A medical isotope that needs to arrive within hours may need to go on a passenger flight — which means it must meet the tighter passenger aircraft limits. A calibration source with a higher TI might be perfectly fine on a cargo flight but ineligible for passenger service.
Who Needs to Know This
This guide is essential for anyone who:
- Ships sealed sources, medical isotopes, or instruments containing radioactive material by air
- Prepares the DGD and needs to mark the correct aircraft limitation
- Books air freight and needs to specify passenger-eligible vs cargo-only
- Works as a freight forwarder or cargo agent handling Class 7 shipments
- Manages logistics for time-sensitive radioactive material deliveries
Important: Even when a shipment meets all IATA DGR requirements for a passenger aircraft, individual airlines may impose additional restrictions through operator variations. Always verify acceptance with the carrier before preparing your shipment.
Transport Index and CSI Limits by Aircraft Type
The core difference between passenger and cargo aircraft comes down to quantitative limits on Transport Index (TI) and Criticality Safety Index (CSI). These limits are specified in IATA DGR Table 10.9.B:
| Type | Max TI (non-exclusive) | Max CSI (non-exclusive) | Max CSI (exclusive use) |
|---|---|---|---|
| Small freight container | 50 | 50 | No limit |
| Large freight container | No limit | 50 | No limit |
| Passenger aircraft | 50 | 50 | N/A — exclusive use forbidden |
| Cargo aircraft | No limit | 50 | No limit |
Per-Package TI Limits
In addition to the combined limits in the table above, there are per-package TI maximums:
- Passenger aircraft: Maximum TI of 3.0 per package
- Cargo aircraft: Maximum TI of 10.0 per package
This per-package limit is the most common reason a shipment gets restricted to cargo aircraft. A single package with a TI of 4.0 is perfectly legal on a cargo flight but cannot go on any passenger aircraft, period.
In my experience, the majority of routine radioactive air shipments — excepted packages, medical isotopes in Type A packages, and most instruments — have a TI well under 3.0 and are passenger-eligible. Excepted packages have a TI effectively at zero, and most medical isotope shipments I have seen come in under 1.0. Where you start running into the 3.0 threshold is with higher-activity sealed sources, particularly calibration sources and industrial gauges. If your TI is in the 2.0 to 4.0 range, I recommend surveying the package and knowing the exact number before you book, because you are right on the edge of the passenger/cargo split.
What Triggers “Cargo Aircraft Only”?
Your shipment must be marked “Cargo Aircraft Only” on the DGD if any of the following apply:
- TI per package exceeds 3.0 (but is ≤ 10.0)
- Package is Type B(M) (IATA DGR §10.9.3.3.2)
- Shipment is under exclusive use (IATA DGR §10.9.3.3.2)
- Any package or overpack with TI > 10.0 (exclusive use only, IATA DGR §10.9.3.6.4)
Tip: On the DGD, Step 7 asks you to mark the aircraft limitation. If your shipment is eligible for passenger aircraft, you leave it as “Passenger Aircraft” (which also means it can go on cargo aircraft). If it is cargo-only, you mark “Cargo Aircraft Only.” Getting this wrong can result in a rejected shipment at acceptance.
What Is Prohibited on Each Aircraft Type?
Beyond TI limits, the IATA DGR prohibits certain materials and configurations based on aircraft type (IATA DGR §10.9.3.3):
| Restriction | Passenger Aircraft | Cargo Aircraft |
|---|---|---|
| TI per package > 3.0 | Prohibited | Allowed (up to 10.0) |
| Type B(M) packages | Prohibited | Allowed |
| Exclusive use shipments | Prohibited | Allowed |
| Vented Type B(M) | Prohibited | Prohibited |
| External cooling required | Prohibited | Prohibited |
| Operational controls required | Prohibited | Prohibited |
| Pyrophoric material | Prohibited | Prohibited |
| Surface dose rate > 2 mSv/h | Special arrangement | Special arrangement |
The most common mistake is the TI limit, hands down. Most shippers I work with know that Type B(M) is cargo-only — if you are shipping a Type B package, you are usually working with a specialized carrier and the restrictions are part of the conversation. But the TI limit catches people because it is a number, not a package type, and it is easy to assume the ground limit carries over. I have seen shippers with a YELLOW-III package at TI 3.5 try to put it on a passenger flight because “it is under 10.0.” That 0.5 above the 3.0 threshold is the difference between flying today and waiting for a cargo service.
Separation Distances from Passengers and Crew
CATEGORY II-YELLOW and CATEGORY III-YELLOW packages must be separated from passengers by minimum distances based on the total TI. These distances are measured from the package surface to the nearest inside surface of the cabin partition or floor (IATA DGR §10.9.3.7).
CATEGORY I-WHITE packages have a TI of zero and have no separation distance requirement.
Passenger and Cargo Aircraft Separation (Table 10.9.C)
This table applies to all aircraft. The distances increase with the total sum of TI:
| Total Sum of TI | Minimum Distance |
|---|---|
| 0.1 to 1.0 | 0.30 m (10″) |
| 1.1 to 2.0 | 0.45 m (18″) |
| 2.1 to 3.0 | 0.61 m (24″) |
| 5.1 to 6.0 | 0.97 m (3'10″) |
| 9.1 to 10.0 | 1.37 m (5'5″) |
| 20.1 to 25.0 | 2.41 m (9'6″) |
| 45.1 to 50.0 | 3.63 m (14'4″) |
These are minimums. The DGR states that greater distances should be used where feasible, in keeping with the ALARA principle.
Other Separation Requirements
- Undeveloped photographic film: Must limit exposure to 0.1 mSv per consignment (IATA DGR Table 10.9.E). While digital photography has reduced this concern, film-based imaging equipment still exists in some industries.
- Live animals: 0.5 m minimum for journeys of 24 hours or less; 1.0 m for longer journeys (IATA DGR §10.9.3.9)
In practice, the airline's load planning team handles the actual placement of radioactive packages in the cargo hold based on the TI information on the labels and the DGD. As a shipper, your job is to make sure the TI on the label is accurate and that the DGD is correct — the airline uses that information to calculate separation distances and plan where packages go. That being said, I always recommend communicating directly with the carrier's dangerous goods department if you are shipping multiple radioactive packages on the same flight. The combined TI affects the separation distance, and the airline needs to know the total picture, not just each individual package. Most carriers have systems to manage this, but giving them a heads-up makes the process smoother.
LSA and SCO Aircraft Limits
LSA material and SCO in industrial packages have additional per-aircraft activity limits (IATA DGR Table 10.9.A, §10.9.3.3.3):
| Material Type | Activity Limit per Aircraft |
|---|---|
| LSA-I | No limit |
| LSA-II and LSA-III — non-combustible solids | No limit |
| LSA-II and LSA-III — combustible solids, all liquids and gases | 100 × A2 |
| SCO | 100 × A2 |
These limits apply to the total activity on a single aircraft, not per package. If you are shipping multiple LSA or SCO packages on the same flight, their combined activity must not exceed these limits.
I have seen the LSA aircraft limits become relevant when a decommissioning project needed to ship multiple drums of LSA-II waste by air to meet a project timeline. Each drum individually was fine, but when you added up the total activity across all packages on a single flight, they were approaching the 100 × A2 limit for combustible solids. They ended up splitting the shipment across two flights to stay within the per-aircraft limit. It is one of those rules that rarely comes up for routine shipments — if you are shipping one or two packages, you are almost never near the limit. But bulk LSA or SCO shipments on a tight schedule can run into it.
Fissile Material: Additional Aircraft Considerations
For fissile material, the CSI limits in Table 10.9.B govern how much can go on a single aircraft. The key constraint is that the total CSI must not exceed 50 under non-exclusive use (both passenger and cargo). Under exclusive use on cargo aircraft, there is no CSI limit — but groups must be spaced at least 6 meters apart if the CSI sum exceeds 50 (IATA DGR §10.9.3.5.2).
Additional consignment-level restrictions apply for fissile material shipped under the exemptions of IATA DGR §10.3.7.2.3 through 10.3.7.2.5:
- Packages under §10.3.7.2.3: no more than 45 g of fissile nuclides per consignment
- Packages under §10.3.7.2.4: no more than 15 g of fissile nuclides per consignment
- Material under §10.3.7.2.5: exclusive use on aircraft, no more than 45 g of fissile nuclides
How to Determine Your Aircraft Eligibility
Use this step-by-step process to determine which aircraft type your shipment can use:
- Check for absolute prohibitions: Is your package vented Type B(M), pyrophoric, requiring external cooling, or subject to operational controls? If yes → forbidden on all aircraft.
- Check for passenger aircraft prohibitions: Is the package Type B(M)? Is the shipment under exclusive use? If yes to either → cargo aircraft only.
- Check the TI: Is the TI per package > 3.0? If yes → cargo aircraft only. If TI is ≤ 3.0 → eligible for passenger aircraft.
- Check surface dose rate: Is the surface dose rate > 2 mSv/h? If yes → special arrangement required (rare).
- Check LSA/SCO limits: If shipping LSA or SCO in industrial packages, verify the total activity per aircraft does not exceed Table 10.9.A limits.
- Check CSI: If shipping fissile material, verify the total CSI does not exceed 50 (non-exclusive) or that proper spacing is maintained (exclusive).
- Check operator variations: Contact your carrier to confirm they accept Class 7 and verify any airline-specific restrictions.
Tip: Most routine radioactive shipments — excepted packages, low-activity Type A packages with TI under 3.0 — are eligible for passenger aircraft. The cargo-only restriction typically applies to higher-activity sealed sources, Type B(M) packages, and exclusive use consignments.
In my experience, the overwhelming majority of radioactive air shipments are passenger-eligible. I would estimate 80% or more of the Class 7 air shipments I have been involved with had a TI under 3.0 and no other passenger-aircraft prohibitions. Most excepted packages, medical isotopes, and low-activity instruments fall well within passenger limits. The cargo-only restriction is more common with industrial sealed sources, Type B packages, and exclusive use consignments — which are a smaller slice of the total volume. That being said, if your facility routinely ships higher-activity sources, your experience will skew more toward cargo-only.
Marking the Aircraft Limitation on the DGD
Step 7 of the DGD (IATA DGR §10.8.3.5) requires you to mark the aircraft limitation. There are two options:
- “Passenger and Cargo Aircraft” — the shipment meets all passenger aircraft requirements and can go on either type
- “Cargo Aircraft Only” — the shipment is restricted to cargo aircraft due to TI, package type, or exclusive use
Marking “Passenger and Cargo Aircraft” does not mean the shipment must go on a passenger flight — it simply means it is eligible for one. The carrier can still load it on a cargo-only flight.
Critical: Marking a shipment as “Passenger and Cargo Aircraft” when it should be “Cargo Aircraft Only” is a serious violation. If a cargo-only shipment gets loaded on a passenger aircraft because the DGD was marked incorrectly, the shipper bears responsibility.
I have seen this error more times than I would like. The most common cause is using a pre-filled DGD template that defaults to “Passenger and Cargo Aircraft” and the shipper does not update it when the TI exceeds 3.0. They fill out the rest of the form correctly, but they forget Step 7. The consequence is serious — if a cargo-only shipment gets loaded on a passenger aircraft because the DGD was marked wrong, that is a regulatory violation on the shipper. The airline relies on the DGD to make loading decisions. If you are unsure, mark it “Cargo Aircraft Only” — a cargo-only marked shipment can always go on a cargo flight, but a wrongly marked passenger-eligible shipment on the wrong aircraft is a problem you do not want.
How RadShip.com Helps
RadShip.com helps you determine aircraft eligibility as part of the classification process:
- RAMcalc — Classifies your material and determines the correct UN number and package type, so you know immediately whether you are in Type B(M) territory (cargo-only) or Type B(U) (passenger-eligible)
- LabelCalc — Calculates TI and assigns the correct label category, which feeds directly into the aircraft eligibility decision
- Regulatory Guides — Plain-language guidance on IATA DGR requirements for both aircraft types
Here's the reality: if you discover an aircraft eligibility issue at the cargo counter, you are already too late. The package is prepared, the DGD is completed, the pickup is scheduled, and now you find out it cannot fly on the flight you booked. That means rebooking on a cargo service (if one is available), potential delay charges, and a missed delivery window. For medical isotopes with short half-lives, that delay can mean the material decays below usable activity before it arrives. Knowing the aircraft limitation at classification time — before you book, before you prepare the DGD — means you book the right service the first time and avoid the entire chain of problems.
Common Questions
What is the maximum Transport Index per package on a passenger aircraft?
3.0. Packages with a TI greater than 3.0 (up to 10.0) can only ship on cargo aircraft. This is specified in IATA DGR Table 10.9.B.
Can Type B(M) packages go on a passenger aircraft?
No. Type B(M) packages are prohibited on passenger aircraft under IATA DGR §10.9.3.3.2. They can only be transported on cargo aircraft. Note that Type B(U) packages are allowed on passenger aircraft if they meet the TI and other requirements.
What does “Cargo Aircraft Only” mean?
The package cannot go on an aircraft carrying passengers. The DGD must be marked accordingly, and the shipment must be booked on a cargo-only service. This restriction triggers when TI > 3.0, when the package is Type B(M), or when the shipment is under exclusive use.
Is there a combined TI limit on cargo aircraft?
Under exclusive use, no. Under non-exclusive use, the limits depend on the freight container size per Table 10.9.B. For large freight containers, there is no TI limit even under non-exclusive use.
How close can radioactive packages be to passengers?
It depends on the total TI. Table 10.9.C specifies minimum separation distances. For example, a combined TI of 1.0 requires 0.30 m; a combined TI of 50 requires about 4.4 m. Category I-WHITE packages (TI = 0) have no separation requirement.
What I wish more shippers understood is that the passenger vs cargo distinction is not complicated once you know the three triggers: TI > 3.0, Type B(M), and exclusive use. If none of those apply, you are passenger-eligible. That is it. Most shippers overthink this and assume there is some complex decision matrix, but it really comes down to those three items. The thing that would make their lives easiest is surveying the package before booking. Know your TI, know your package type, and you will know your aircraft limitation in 30 seconds. That one step eliminates the most common source of rejected shipments.
Summary: Your Aircraft Eligibility Checklist
Before booking air transport for radioactive material:
- ☐ Confirmed no absolute prohibitions apply (no vented B(M), pyrophoric, external cooling, operational controls)
- ☐ Checked TI per package: ≤ 3.0 for passenger aircraft, ≤ 10.0 for cargo aircraft
- ☐ Checked for passenger-specific prohibitions: no Type B(M), no exclusive use
- ☐ Surface dose rate ≤ 2 mSv/h (otherwise special arrangement required)
- ☐ If LSA/SCO: verified total activity per aircraft within Table 10.9.A limits
- ☐ If fissile: verified CSI sum ≤ 50 (non-exclusive) or 6 m spacing maintained
- ☐ DGD marked with correct aircraft limitation (“Passenger and Cargo Aircraft” or “Cargo Aircraft Only”)
- ☐ Carrier contacted and acceptance confirmed (including operator variations)
Regulatory References
IATA DGR (Air Transport):
- IATA DGR §10.9.3.3 — Loading limitations (prohibitions by aircraft type)
- IATA DGR Table 10.9.A — Aircraft activity limits for LSA/SCO
- IATA DGR Table 10.9.B — TI and CSI limits by aircraft type
- IATA DGR Table 10.9.C — Separation distances (passenger and cargo aircraft)
- IATA DGR Table 10.9.D — Separation distances (cargo aircraft only)
- IATA DGR §10.9.3.5 — Fissile material storage and transport requirements
- IATA DGR §10.8.3.5 — Aircraft limitation marking on DGD
- Purchase the IATA DGR
DOT Requirements (Ground Comparison):
- 49 CFR 173.441 — Radiation level limitations (ground, max TI 10.0)
- 49 CFR 177.842 — Vehicle loading limits (ground, max combined TI 50)
About the Author
Scott Brown is the Subject Matter Expert and co-creator of RadShip.com. He has been a trained hazmat shipper for over 15 years and specializes in DOT Class 7 radioactive material shipping.
This guide is based on the requirements of 49 CFR (DOT) and the IATA Dangerous Goods Regulations as of the publication date. As regulations are amended, RadShip.com is committed to keeping its guides current with the latest requirements.
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