Shipping Flight Hardware Safely and Legally
Flight hardware ships with controlled transport, documented chain of custody, correct hazmat classification and the right export filing. Carrier default liability rarely covers its value, so insurance and handling requirements need to be arranged before pickup, not after a claim.
Choose the transport mode for the hardware, not the price
Hardware that is sensitive to shock, contamination or loss should not move as standard less-than-truckload freight, where it may be cross-docked and handled several times. Pick the service level from the hardware's risk.
| Service | What it means | Use for |
|---|---|---|
| Parcel | Sorted by conveyors, multiple handlings | Robust, low value parts in well designed boxes |
| LTL freight | Shared trailer, terminal transfers | Crated, robust items |
| Dedicated truck | Exclusive use of the trailer, no transfers | Large crates, high value items |
| Air ride trailer | Air suspension reduces road shock and vibration | Instruments, assemblies, flight hardware |
| White glove | Specialized handlers, often inside delivery and placement | Delicate items that must be placed at a specific location |
| Hand carry or courier | A person travels with the item | Small, critical, schedule driven items |
Specify no terminal transfers and no team driver substitution if that matters, and confirm the trailer has air ride rather than assuming. See the logistics hub for how transport fits with packaging and receipt.
Chain of custody and tamper evidence
Chain of custody is a written record of every hand the hardware passed through, with times, signatures and seal numbers. For flight hardware it answers the question every investigator asks after a failure: could anything have happened to this part between acceptance and installation?
- Record serial numbers, seal numbers and photographs at packing.
- Use numbered tamper evident seals or tape on bags, crate lids and trailer doors.
- Have the driver sign for the seal numbers at pickup, and receiving verify them at delivery before opening.
- Keep indicator and data logger records with the custody record.
- If a seal is broken, stop, photograph, document and notify before opening further.
Hazmat basics: when a part becomes a dangerous good
Machined hardware is usually not hazardous, but some items are regulated under the Hazardous Materials Regulations in 49 CFR. The common cases in aerospace are pressurized components, batteries, residual propellants or cleaning solvents, and some chemicals shipped with kits.
Pressure. Under 49 CFR 173.115, a Division 2.2 non-flammable, non-poisonous gas is one that exerts a gauge pressure of 200 kPa (29.0 psig) or more at 20 °C in its packaging, or is a liquefied or cryogenic gas, and does not meet the flammable or poisonous definitions. A tank, accumulator or valve assembly shipped with a gas charge above that threshold may be regulated. 49 CFR 173.306 contains specific provisions for accumulators, with conditions that depend on charge pressure, gas space volume and testing; one example is the provision for accumulators charged to not more than 200 psig at 70 °F. Read the section itself before relying on any exception.
Simplest control. Where the design allows, ship pressure vessels and accumulators depressurized, or with only the minimal inert pad gas the regulations allow, and document the pressure at packing.
People. Anyone who classifies, packages, marks or signs for a hazmat shipment is a hazmat employee. Under 49 CFR 172.704 they need general awareness, function specific, safety and security awareness training, completed within 90 days of employment or a change in job function and repeated at least once every three years. Air shipments add carrier and international air rules on top.
Insurance and carrier liability
Carrier liability is limited by contract and is far below the value of most flight hardware. FedEx, for example, includes a standard $100 limit of liability per shipment in its rates and charges for declared value above that; declared value raises the carrier's limit but is not insurance. Freight carriers have their own published limits, often by weight.
For high value hardware, buy cargo insurance on the actual replacement value, confirm it covers the transport mode and any storage in transit, and read the exclusions for inadequate packaging. Agree in the purchase order who holds the risk of loss in transit, because the shipping terms decide who files the claim.
Export shipments and EEI
Exporting flight hardware involves two separate questions: is an export authorization needed, and must Electronic Export Information be filed in AES?
| Situation | EEI filing | Reference |
|---|---|---|
| Value over $2,500 per Schedule B or HTS number | Required unless another exemption applies | 15 CFR 30.2 and 30.37(a) |
| Value $2,500 or less per Schedule B number, no license needed | Generally exempt for those lines | 15 CFR 30.37(a) |
| BIS license required under the EAR | Required regardless of value | 15 CFR 30.2(a)(1)(iv) |
| Subject to the ITAR, licensed or license exempt (except as the ITAR notes) | Required regardless of value | 15 CFR 30.2(a)(1)(iv) |
Export classification and licensing are the shipper's responsibility and are not something to work out at the dock. Hand carrying hardware or technical data on a laptop to a foreign site is also an export. See controlled programs for how we keep controlled data and hardware with authorized U.S. persons and authorized suppliers.
Environmental control in transit
Some hardware has temperature or humidity limits: bonded assemblies, optics, batteries, lubricated mechanisms and some composites. State the allowable range on the purchase order and use temperature controlled transport or a data logger. Remember that a closed trailer or a container on a sunny ramp can far exceed ambient temperature.
Desiccant and humidity indicator cards inside a sealed barrier give a simple record of moisture exposure, covered in crating and packaging.
Pre-shipment checklist
- Hardware inspected and accepted; cert pack complete and packed with or ahead of the hardware.
- Packaging per the purchase order, photographed before closing.
- Seals applied and numbers recorded; indicators armed.
- Hazmat classification confirmed, with shipping papers signed by a trained person if regulated.
- Export classification, authorization and EEI filing confirmed if leaving the country.
- Insurance and declared value set to replacement value.
- Carrier service level confirmed in writing: air ride, dedicated, no transfers.
- Receiving notified with tracking, seal numbers and arrival window.
Receiving's side of the handoff is in receiving inspection.
Loading, securing and unloading
Much transit damage happens at the ends of the trip, during loading and unloading, not on the highway. Brief the driver and the receiving dock in advance.
- Mark the center of gravity, lift points and fork entry on heavy crates, and state which side must stay up.
- Require load bars or straps so crates cannot shift, and forbid stacking anything on top of sensitive crates.
- Specify liftgate or forklift needs at both ends, and the maximum tilt allowed if the item is tip sensitive.
- Ask the carrier to note crate condition and indicator status on the bill of lading at pickup.
- At delivery, inspect before signing; write any visible damage or activated indicators on the delivery receipt, because a clean signature weakens a later claim.
For flight hardware, consider having a company representative present at loading and at delivery. It costs a day of someone's time and removes most arguments about what happened.
Get help shipping hardware
Request a crating and shipping quote with the item's weight, value, sensitivities, pressure state and destination. We source qualified packaging and transport suppliers, flow down your requirements and keep the paperwork with the hardware. A person replies within 1 business day.
Questions
Is declared value the same as insurance?
No. Declared value raises the carrier's contractual limit of liability, for a fee, and claims still depend on the carrier's terms, including packaging and exclusions. FedEx, for example, includes a $100 standard limit and charges for declared value above it. For flight hardware, buy cargo insurance covering replacement value and confirm it applies to the transport mode and any storage in transit.
Do I have to ship a pressure vessel as hazmat?
It depends on the gas and pressure. A non-flammable, non-toxic gas becomes Division 2.2 at a gauge pressure of 200 kPa (29.0 psig) or more at 20 degrees C under 49 CFR 173.115, and 49 CFR 173.306 has specific conditions for accumulators. Shipping depressurized is often simplest. Have a trained person classify the shipment, because the shipper is responsible for getting it right.
When is EEI required for a low value export?
Low value shipments are generally exempt when each Schedule B number is $2,500 or less, under 15 CFR 30.37(a). The exemption does not cover shipments that need a BIS license or that are subject to the ITAR; 15 CFR 30.2 requires EEI for those regardless of value. Classify the item first, then decide on filing.
What does chain of custody add if I already have tracking?
Tracking shows where a package was scanned. Chain of custody records who had control of the hardware, the seal numbers at each handoff and its condition. For flight hardware that record supports acceptance, failure investigation and insurance claims. It also deters tampering, because any break in seals or signatures is visible and must be explained before the hardware is used.
Who can sign hazmat shipping papers?
A person trained under 49 CFR 172.704 for that function. Training covers general awareness, function specific requirements, safety and security awareness, must be completed within 90 days of starting the job function, and repeated at least every three years. A new employee may work under direct supervision of a trained employee before completing training. Air shipments add carrier requirements.
Related
Sources
- 49 CFR 173.115, Class 2 gas definitions (Division 2.2 pressure threshold)
- 49 CFR 173.306, Limited quantities of compressed gases, including accumulators
- 49 CFR 172.704, Hazmat employee training requirements
- FedEx, declared value and the standard $100 limit of liability
- 15 CFR 30.2, General requirements for filing Electronic Export Information
- 15 CFR 30.37, Miscellaneous exemptions from EEI filing ($2,500 per Schedule B number)
- SpotSee, ShockWatch impact and TiltWatch tilt indicators for packaging (PDF)
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