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IAEA Technical Meeting on Denials of Shipment

March 23-26, 2021

Characterising the denial of shipment of radioactive material, and

identifying potential remedial policies

Author: Serge Gorlin – Head of Industry Cooperation, WNA

Abstract

The international transport of radioactive material is built on firm foundations, composed of two key

elements: a strong and harmonized global regulatory framework covering all modes; a mature industry

that is competent in the application of transport regulations. Yet there are often difficulties in shipping

these products from producer to end-user in an efficient way. In the maritime sector, denial of

shipment of radioactive material is a chronic issue among carriers and port terminals. The non-

acceptance by hub ports of transhipment of radioactive material is another obstacle to finding efficient

maritime routes. Acceptance of radioactive material by airlines is better than by sea carriers, however

as the products shipped by air are usually time and health critical, any delays need to be avoided.

Unnecessary delays to the delivery of radioactive material can be caused by offloading of cargo from

the hold of aircraft by pilots and by lengthy custom checks.

After reviewing the international efforts of the last 20 years to combat denials of shipments, this paper

characterises the current situation by analysing data from two modes key to the international

transport of radioactive material: air and maritime. It further evaluates the results of the 2020

Transport Facilitation Working Group survey, conducted before the pandemic, as well as the global

disruption to the supply of medical radioisotopes by the COVID-19 pandemic. The second part of the

paper is devoted to examining policies that could moderate the effects of denial of shipment without

affecting the firm foundations of the radioactive material transport system. It is suggested that these

policies would as a corollary help address the problems relating to the distribution of medical

radioisotopes caused by the pandemic. A central role to be played by the International Atomic Agency

Agency in addressing the issue of denials is proposed.

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Contents

1. Introduction – Road to IAEA TM DOS 2021

2. Characterising denial of shipments

1. Defining denial of shipments

2. Maritime mode

3. Air mode

4. Results of 2020 TFWG survey

3. Identifying remedial policies

4. Conclusion

Appendices

1. Policies of ports used for the global distribution of sealed sources

2. Airline operator variations

3. Report from Salvadoran Institute of Social Security on disruption to medical radioisotope

supply during the pandemic

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1. Introduction

Background

The phenomenon of difficulties encountered during the shipment of radioactive materials due to their

non-acceptance by ports and transport companies dates back many years. The proceedings of the US

Atomic Energy Commission Transport Symposium in 1962, for example, record a comment from a UK

competent authority representative: “The people that we have had trouble with are those that we call

minor competent authority, people like ports [sic] and airfields [sic], station-masters and people who

are somewhere in the chain, and they have enough power to refuse to accept your material, but not

enough time to understand what the regulations are about”1.

However, it was not until the International Atomic Energy Agency’s (IAEA) Conference on the Safety of

Transport of Radioactive Material, held in July 2003, that the issue of denial of shipments (DoS) was

officially and formally recognised, and a concerted effort to address it was initiated. The Conference

noted that the nuclear industry and other industries using radioactive material were facing a reduced

availability of transport routes, modes and carriers as a result of decisions by commercial carriers,

ports and handling facilities not to accept radioactive material. The Conference suggested that the

IAEA should work more closely with the Modal Organizations of the United Nations (UN) and with

Nongovernmental Organizations in determining why shipments of radioactive material were being

denied, and to develop a strategy for addressing this issue.

There were subsequently a number of meetings discussing the issue. These included the IAEA Fact

Finding Discussion Forum convened at the International Maritime Organization (IMO) headquarters in

London 16 July 2004, the IMO Facilitation Committee (FAL) meeting 19-23 July 2004, also held in

London, and the ICAO Dangerous Goods Panel Working Group of the Whole, which discussed the issue

at its meeting in Abu Dhabi, 4-8 Oct. 2004.

The 2004 IAEA General Conference welcomed “the progress made on the problems related to refusals

of shipments of radioactive materials (in particular for medical applications)”. It added that it “looks

forward to a satisfactory resolution of this issue.” Then in September 2005, the General Conference

encouraged the Agency to continue addressing this matter by establishing a steering committee.

Formation of the International Steering Committee on Denials of Shipment

In 2006, the International Steering Committee on Denials of Shipment of Radioactive Material (ISC)

was constituted to satisfy the IAEA resolutions. The ISC’s objective was to serve as a mechanism to

facilitate the establishment of a comprehensive international work plan of activities related to denials

and delays of shipments of radioactive material. Membership of the ISC was drawn from United

1 Summary Report of AEC Symposium on Packaging and Regulatory Standards for Shipping Radioactive Material, held in Germantown, MD on 3-5 December 1962, TID-7651, United States Atomic Energy Commission

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Nations and other international, governmental, and nongovernmental organizations, transport trade

organizations, and manufacturers of sources of radioactive material.

The ISC’s Action Plan aimed to address cases of denial of shipment by reaching out and working with

the concerned organizations in an attempt to increase awareness, harmonize national and

international regulations, ensure coordination among regulators within a State to minimise

duplicative, overlapping and sometimes contradictory requirements, provide training and other

educative programmes for cargo handlers and public officials on the safety of transport of radioactive

material, and to promote a fuller understanding of the implications of denial.

National Focal Points and Regional Co-ordinators

To help implement this plan, the ISC established National Focal Points (NFPs) and Regional Co-

ordinators (RCs), and incorporated these individuals into networks. NFPs were effective in resolving

DoS domestically where their experience could facilitate discussions and resolutions. RCs were

instrumental in helping the IAEA organize, between 2007 and 2011, a number of regional workshops

globally, including in Africa and Latin America. The ISC development of a brochure, fact sheets, and a

video provided key tools in communicating the benefits of transporting radioactive material and the

consequences of denials. The brochure was translated into Spanish by the IAEA. Further

communication tools included an IAEA denial website.

Another important success of the ISC was in gaining cooperation from the airline industry for the

timely delivery of radioactive material. Airline pilots were made aware that radioactive materials can

be carried safely alongside pets and biological samples in the hold of an airplane and do not need to

be off-loaded. Air Canada even made it its policy to prioritize certain radioactive material for

transportation over other cargoes and passengers. It maintains this policy today.

Despite the progress made by the ISC, the President of the IAEA Conference on the Safe and Secure

Transport of Radioactive Materials held 17 – 21 October 2011 in Vienna, still found that: “Denial of

shipments continues to be a problem that must be addressed”. This conference further noted for the

first time the connection with safety and security: “Efforts to reduce denials have both safety and

security benefits.”

Dissolution of the ISC

By 2013, the year it had set as a target to make denial and delay “insignificant”, the IAEA ended the

ISC. It dissolved the committee and ceased supporting the RC and NFP networks that had been built

up. Director General Amano attended the closing ceremony of the ISC, and in his remarks said that a

high proportion of the 30 Member States he visited each year complained about transport issues that

hinder the receipt of radioactive material.

In the light of the comments of DG Amano, and the awareness of members of the ISC that problems

with DoS still existed, it is pertinent to ask the question why the ISC was closed. The author can only

offer his view (as the person who chaired the final ISC meeting). Firstly, the reporting system for

denials was not working effectively. This led to underreporting of issues, and to questioning whether a

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problem with denials existed at all (the reporting question is discussed in Section 2.1). Secondly, the

ISC, which was managed by the Department for Nuclear Safety and Security, was set up in a way that

gave governments and industry representatives equal status. In the aftermath of the Fukushima

Daiichi accident in 2011, where the lack of a division between regulator and regulated was seen as a

contributory factor in inadequate safety measures, the ISC model may not have seemed appropriate.

Formation of Transport Facilitation Working Group

In 2014, the Transport Facilitation Working Group2 (TFWG) – made up of former Chairs of ISC,

interested Member States and representatives of relevant trade associations – was set up to highlight

problems and develop strategies to facilitate Cl. 7 transport. One of its first activities in 2015, partly

driven by the difficulties ISC had experienced with its reporting system, was to conduct a survey of 61

organizations depending on the shipment of radioactive materials. The cohort represented a good

cross-section of organizations from diverse regions and sectors of nuclear technology, and was

collectively responsible for over 300,000 package movements / year. The survey results showed that

problems with denial of shipments were persisting. The consequences were fragile supply chains and

transport by indirect routes.

Besides assessing trends, TFWG members have focused on the development of communication

materials that explain the role of radioactive materials in modern society, and that of a model course

on the safe and efficient transportation of Class 7 radioactive material aimed at port operatives and

shipping company employees.

In June 2018, the International Maritime Organization’s Facilitation Committee accepted a report

submitted by the World Nuclear Transport Institute: "Difficulties in Shipments of IMDG Code Class 7

Radioactive Materials". The report outlined how – notwithstanding previous efforts by the IMO –

problems were still being encountered in shipping radioactive cargoes efficiently and directly. It

encouraged Member Governments to reinforce the messages in previous IMO circulars and

resolutions to facilitate the shipments of IMDG Code Class 7 radioactive materials.

At the 2018 General Conference, Brazil hosted a meeting on the topic of difficulties in the shipment of

radioactive material, co-organized with TFWG. The meeting’s objectives were to raise awareness of

the ongoing issue of denial of shipments and to discuss ways in which the recommendations of the

annual IAEA resolution (which continued to call for NFPs to be appointed) and IMO FAL paper could be

implemented. During the discussion at this meeting, ideas were advanced for minimizing the effects of

DoS, which included: revival of the networks created during the time of ISC; and the development of

an IAEA Code of Conduct on facilitation of transport.

2 See www.tfwg.info

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A new IAEA resolution on DoS

At the April 2019 IAEA Board of Governors meeting, Ambassador Rafael Grossi of Argentina

highlighted the previous year’s General Conference side meeting on denial of shipments hosted by

Brazil and the idea of a Code of Conduct to facilitate the safe transport of radioactive material. The

2019 IAEA General Conference Nuclear Safety Resolution subsequently called for a Technical Meeting

(TM) to be convened to examine ways – including a Code of Conduct – in which the denial of shipment

could be addressed. This TM was supposed to take place physically in Vienna in April 2020, but was

postponed to April 2021.

It should be noted that there were several calls for the virtual IAEA TM to be held earlier, including by

the G-77 and China, which in its statement3 to the IAEA Board of Governors 14 – 18 September 2020

said: “The Group notes that the restrictions imposed by the COVID-19 pandemic have exacerbated

the challenges related to delays and denials of shipment of radioactive sources including medical

isotopes, the Group calls on all Member States to facilitate to the highest extent possible, the

shipment of these materials through their sea ports and airports and to minimize delays and denials

even during this difficult period. Finally, the Group calls on the Agency to convene a technical meeting

before the end of the year virtually to further discuss measures which may be taken to overcome

delays and denials of shipment.”

3 See: https://www.g77.org/vienna/wp-content/uploads/2020/09/BOGG77final.pdf

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2. Characterising denial of shipments

2.1 Defining denial of shipments

Denial of Shipment (DoS) has been recognised as a persistent problem, but what is the nature, the

scale, the character of the predicament today? Clearly these are questions that need to be answered,

but characterising the issue depends at least partly on how DoS is defined.

A Provisional Definition

At the 5th meeting of the ISC (25-26 February 2010) a definition for denial was agreed upon. It was: “a

(explicit or implicit) refusal to carry a shipment of radioactive material though it conforms to all the

applicable Regulations”. However, this decision was not without controversy and the topic was still

being debated by the ISC during the 8th and final meeting in 2013. The criticism of this definition was

that it implied that denials take place during the course of transport between consignor and

consignee. Such events do occur, for example, when a pilot rejects the loading of a Cl. 7 package in the

hold because of live cargo also being transported, or when regulations are suddenly changed4.

However such instances are very rare. The producers and freight forwarders do meticulous planning,

and do not initiate a shipment if they consider there is a likelihood of it being held up during the

journey.

This view that denial takes place in the course of transport was also reflected in the reporting form

developed by the ISC to help characterise the situation. Among other questions, this form asked the

shipper for: the name of aircraft/ship/vehicle; type of aircraft/ship/vehicle; aircraft tail/IMO

ship/vehicle identification number; flight number/voyage reference/route reference. The

questionnaire also requested “the name of entity with whom the alleged difficulty”. A fear of breach

of confidentiality was another deterrent to submission of report forms.

Evolving the Definition

The Transport Facilitation Working Group (TFWG) has interpreted DOS differently to ISC, but in a way

which is consistent with the 2003 IAEA Transport conference. It sees it as the cumulative effect of

ports / airports / terminals, commercial carriers and handling facilities not to accept radioactive

material as a policy. It is not measured in instances of denial but in the:

• level of difficulty a consignor experiences when preparing and executing a Cl. 7

shipment

• the number of potential routes and carriers,

• the degree to which the shipment goes indirectly to consignee.

4 For example, the Suez Canal (SC) Rules of Navigation were suddenly changed in 2015 preventing entry to the canal for vessels carrying Cl. 7 that were already en route.

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A further definition of DoS can be considered in the context of the COVID-19 pandemic. This has

caused a drastic curtailment of air transport resulting in disruption to the global distribution of

medical radioisotopes. While it is not DoS in the traditional sense, it may be argued that it is DoS

nonetheless: health centres have been denied shipment of the products they need to treat patients;

producers have been denied the opportunity to ship Cl. 7 to their customers.

Spending time on definitions may appear somewhat academic, but the issue matters – especially

when one considers the fate of the ISC. We do need greater clarity and consensus on what we are

trying to address.

This paper will consider all above-mentioned interpretations of DoS:

• the blocking of a Cl. 7 shipment in the course of transport

• the cumulative effect of the policies of transport companies, handling facilities and ports /

airports

• the degradation in the security of supply of radioactive materials, notably of medical

isotopes, caused by the pandemic.

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2.2 Maritime shipment

Background

Maritime mode is important for the global distribution of long-lived radioisotopes, as well as nuclear fuel.

Besides INF cargo5, which tends to be shipped in specially adapted vessels that can travel for long distances

without refuelling, most radioactive material transported by sea goes by regular container vessels, shipped

alongside other cargoes. These vessels need to stop off in ports to refuel, pick up, and drop off other cargo.

In June 2018, the International Maritime Organization’s Facilitation Committee (FAL) accepted a report

submitted by World Nuclear Transport Institute (WNTI) FAL 42/16/1 "Difficulties in Shipments of IMDG Code

Class 7 Radioactive Materials". The report outlined how – notwithstanding previous efforts by the IMO –

problems were still being encountered in shipping radioactive cargoes efficiently and directly.

Challenges and difficulties

In characterizing the challenges, FAL 42/16/1 identified that there was “a continued consolidation of shipping

lines, with some companies which have historically accepted IMDG Code class 7 radioactive materials being

merged or bought out by companies that have policies not to accept IMDG Code class 7 radioactive materials.”

Moreover, remaining shipping companies often operate in alliance groups in response to the strong

competition in the industry. “In a shipping alliance, companies share cargo space, and if one carrier is not

willing to accept IMDG Code class 7 radioactive materials it affects all the alliance.” The total number of

shipping alliances decreased from ten in 2005, to only three in 2017. Finally, the document identified the trend

towards increases in vessel size as an issue. This raises the risk of a severe economic impact if a vessel is denied

entry to a particular port during its voyage.

An analysis of the policies of the 30 leading container / liner operators6 with regard to Cl. 7 acceptance shows

that only three companies - CMA-CGM, Hapag-Lloyd and Zim - offer services to the whole of market for the

shipment of Cl. 7. While these companies account for 21% of global capacity, it should be underlined that it is

normally only the ships owned by these shipping lines that can accept Cl. 7. Where the vessels are operated

under charter agreements, it will generally not be possible for the ship to accept Cl. 7.

For the purposes of this paper, an analysis of 84 international ports required for the global distribution of sealed

sources was carried out (see Appendix 1). The list includes 30 of the world’s top container ports according to

the World Shipping Council7. Each port was examined as to whether it accepts:

5 INF Code means the International Code for the Safe Carriage of Packaged Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes on Board Ships adopted on 27 May 1999 by the Maritime Safety Committee of the International Maritime Organization 6 See: https://alphaliner.axsmarine.com/PublicTop100/ 7 https://www.worldshipping.org/about-the-industry/global-trade/top-50-world-container-ports

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• loading / unloading of Cl. 7 cargo

• transit of Cl. 7 cargo8

• transhipment of Cl. 7 cargo9

The acceptance rates, shown in Table 1, are very low compared to other categories of cargo, including other

categories of dangerous goods.

Operation Acceptance rate

Loading / unloading 74%

Transit 74%

Transhipment 15%

Table 1: Acceptance of Cl. 7 operations at 84 international ports used for the global distribution of sealed

sources

It should be emphasized that among the ports that ‘accept ’Cl. 7 for loading / unloading and transit, often only

one terminal will allow this cargo. To create a viable route from consignor to consignee, it is necessary to find a

shipping line that both accepts Cl. 7 and uses the appropriate terminals at ports.

Major issue

The very low level of short-term or long-term storage at port and terminals for Cl. 7 cargo – normally a

precondition of transhipment – is another major obstacle to the efficient movement of Cl. 7. Should the 1st leg

vessel arrive earlier than the 2nd leg vessel, the 1st leg vessel must not berth to commence unloading. Naturally,

ocean carriers do not favour having a Cl. 7 shipment on board delay their operations.

This characterisation of the situation in the maritime area is confirmed by a report Analysis of Nuclear Fuel

Availability at EU Level from a Security of Supply Perspective10 published by the Euratom Supply Agency

Advisory Committee Working Group on Prices and Security of Supply in March 2020. It identifies a lack of

transport hubs as the biggest threat to the availability of nuclear fuel in the EU. A lack of harmonisation and

multiple regulation in transport authorisation was the 4th biggest of 10 risks in the report.

8 cargo in transit remains on the vessel, while other cargo is being loaded or discharged at a port in the vessel's voyage rotation 9 transhipment is the act of off-loading a container from one ship (generally at a hub port) and loading it onto another ship, to be further carried to the final port of discharge 10 See: https://ec.europa.eu/euratom/docs/2020_Security_report_2.pdf

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The impacts of fragile supply chains under maritime mode are shown in Table 2. It should be noted that the

shipment of nuclear and radioactive material by circuitous routes runs contrary to the IAEA’s security guidance

with respect to transport11.

Impact type Examples

Safety - Increased likelihood of damage to packages resulting from longer

and more complex routes

- Increased risk of material getting out of regulatory control

- Decreased reliability of infrastructure (e.g. bridges and pipelines)

and modes of transport such as airplanes if sources for non-

destructive testing not delivered.

Security - Added physical protection risk to the material when sent via

indirect routes

- Difficulty in shipping sources back from countries where they

cannot be adequately managed perhaps due to political unrest

- More countries decide to develop proliferation-sensitive fuel cycle

facilities because of insufficient security of supply

Healthcare - Shortage of sterile medical disposable products

- Lack of access to radiotherapy

Environment - Leakage from pipelines

- Using longer routes burns more fuel and increases discharges to

the environment

Economy - Use of expensive charter services

- Increase in healthcare costs

- Ineffective use of research funding

- Adverse effects on African economies that export half of the

world’s tantalum ore

Table 2: Adverse consequences due to the difficulties encountered in maritime shipments of Class 7 radioactive

materials.

11 See IAEA Nuclear Security Series No. 9 and INFCIRC/225/Rev5 (NSS 13)

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2.3 Air shipment

Background

Short-lived radioisotopes used in medicine need to be transported rapidly to point of use. As perishable

products any delays in their delivery can lead to loss of value for producers and of potentially life-saving

treatment and diagnosis for patients. The most used radioisotope in nuclear medicine – Tc99m – is used in tens

of millions of procedures around the world each year.

When point of use is far from the production centre medical radioisotopes are often shipped by air. Scheduled

flights are preferred, and passenger aircraft are frequently used. Other Cl. 7 cargo shipped by air include –

where permitted – samples from fuel cycle facilities and from safeguards inspections. Cargo flights can be used

for larger objects, such as the surface-contaminated equipment used in the maintenance of nuclear power

plants. These are transported in industrial packages.

The International Air Transport Association (IATA), representing some 290 of the world’s main airlines, is a good

source of information for understanding carrier restrictions to the carriage of Cl. 7. IATA asks its members to

declare their additional rules and variations to its Dangerous Goods Regulations (DGR) and publishes them.

Challenges and Difficulties

Appendix 2 provides a list of operator variations relating to Cl. 7 in the IATA DGR, combined with other data

based on the experience of TFWG members. In explaining discrepancies between the IATA’s data and the

experience of the industry, it should also be noted that some airlines that accept Cl. 7 use handling agents in

certain parts of the world who do not accept radioactive materials. This is a common problem.

The data shows that while there is a better level of acceptance of radioactive material among major airlines

compared to major shipping lines, there are some problematic gaps. It is important to stress that any gap is a

potential degradation in the security of supply of medical radioisotopes. As perishable goods, the risks to their

supply cannot be mitigated by having a strategic stockpile.

A noteworthy gap is the policy of KLM Dutch Airlines not to accept Class 7 cargo, other than excepted packages.

Not only does this policy affect the KLM fleet; as KLM is the main handler of goods at Schiphol Airport in the

Netherlands, it prevents other airlines from carrying Cl. 7 using this airport. The impact of this is that the Petten

facility in northern Netherlands, which is responsible for production of over half of Europe ’s

radiopharmaceuticals and exports to the rest of the world, needs to ship its produce by road to other airports in

Belgium and Germany for further export. This causes unnecessary logistical complexity and risk, and the loss of

activity of life-saving products.

According to the Transport Facilitation Working Group (TFWG) 2020 survey, an issue that can affect the timely

delivery of Cl. 7 goods by air is the decision by pilots to reject the Cl. 7 cargo when live animals and / or

biological samples are being carried in the hold. Such an action is not required by the regulations.

Another finding from the TFWG 2020 survey is that customs authorities at airports can be too slow at clearing

short-lived radioactive material, such as fluorodeoxyglucose (FDG), leading to the loss of the product.

It should also be noted that while IATA’s members represent over 80% of airline traffic, there are over 4,000

other airlines whose policies with regard to Cl. 7 can influence the security of supply. These policies have not

been analysed for this paper.

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The Impact of COVID 19

The COVID-19 pandemic has highlighted the vulnerability of supply chains for medical radioisotopes. The

widespread grounding of passenger aircraft caused a deep decline in air cargo capacity. On 23rd April, IAEA

hosted a webinar12 on supply of medical radioisotopes and radiopharmaceuticals during the pandemic. As

preparation for the webinar, the Agency conducted a survey of institutions involved in the production of

medical radioisotopes. Out of the 65 replies from institutions in 45 Member States: 36 mentioned problems

with import of radioisotopes; 27 mentioned problems with transport.

During the webinar, Mouldi Saidi, head of radiopharmacy at Tunisia's National Centre for Nuclear Sciences and

Technologies (CNSTN), explained that, prior to COVID-19, it had typically taken two days for shipments of Mo-

99/Tc-99m generators from production sites in Germany and the Netherlands to Tunisia by scheduled flights via

Dubai. A generator would be expected to have an activity of 840 mCi after such a journey. He explained that the

shipments now involved road transport from the production site to Maastricht, followed by cargo transfer via

Istanbul - a more costly journey, taking 15 days and after which the activity of a generator was around 500

mCi13.

More developed economies were affected by the disruption too. The United States experienced critically low

availability of Mo-99 and other radioisotopes owing to limited transport options from Europe. The US

government considered using government aircraft, and discussions also took place with the Dutch government

over KLM’s acceptance of Cl. 7. KLM proceeded to perform a risk assessment of the technical issues around

transport of these cargoes, and later announced that it had agreed to accept carriage of radioactive materials

upon approval by its regulator beginning 27 April 2020. This would have been for an initial five-week period.

KLM withdrew from this action when a US airline resumed its Cl. 7 shipments from Europe.

Central America

One of the regions most seriously affected by the disruption of medical isotope deliveries during the pandemic

was Central America. According to experts at the Salvadoran Institute for Social Security, there were no

deliveries of medical isotopes from usual sources in Argentina and Cuba between March and October 2020,

leading to thousands of patients waiting for diagnostic procedures and treatment. The difficulties were mainly

due to the closure of borders in El Salvador and neighbouring countries to travellers. These changes led to a

drastic decrease in commercial flights of the airlines operating in the Central American region - Avianca and

Copa – with the eventual bankruptcy of Avianca. The few freight flights that operated to San Salvador had a

spaced frequency and did not coincide with the production cycle of the two producers. This situation was

similar for all Central American countries such as Panama, Honduras, Guatemala, Nicaragua, Costa Rica, which

also saw their supplies and nuclear medicine paralyzed, a situation that still persists in the case of Honduras and

Nicaragua in 2021. Appendix 3 provides a more in-depth description of the security of supply issues

experienced by Central American countries.

While the situation affecting the distribution of Cl. 7 by air has improved since spring 2020, the situation

remains fragile around the world. This is due to a number of factors, including worsening of the

epidemiological conditions of COVID-19, transport companies going bankrupt and changes to the transport

regulations due to the pandemic.

12 See: https://iaea.mediasite.com/Mediasite/Play/1060e8edf420445b98be89221db8b3251d 13 See: https://world-nuclear-news.org/Articles/Air-transport-bottleneck-easing-for-medical-radioi

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2.4 Results of the TFWG 2020 Survey

A survey on experience in shipping Class 7 was conducted by the Transport Facilitation Working Group in

February-March 2020 with a view to understanding trends, specific issues and policy preferences. The questions

in the survey mirrored those that were asked in a TFWG survey in 2015. The survey group comprised 57

shippers and other Cl. 7 transport stakeholders collectively responsible for tens of thousands of package

movements a year. The respondents (see Table 3) were drawn from across different technologies and were

geographically diverse.

Three sets of analyses took place according to the following criteria: all respondents; respondents who ship 30%

or more of their cargo internationally (‘international group’ - 29 respondents); respondents who had a strong

reliance on maritime transport ( ‘maritime group’- 30 respondents).

Key Findings

Some of the key findings from the survey are as follows:

- Shipments generally take place according to plan. Across all three groups, around 80% of

respondents said the shipments were executing predictably and efficiently. This suggests that

interruptions to shipments – either due to non-compliance, or denial of shipment – are rare.

- 50% of respondents said that planning times for shipments had increased; 13% said that planning

had decreased.

- There is a lack of available options for shippers:

o 48% of the international group had one or fewer routes to their main consignee; the equivalent

results were 40% for the maritime group and 36% for all respondents.

o 69% of the international group had two carrier services14 / one regular and reliable carrier

service to their primary consignee; the equivalent result for the maritime group was 67% and

for all respondents 58%

- 35% of respondents said that the situation for Cl. 7 shipment had deteriorated compared to three

years ago; 27% said that the situation had improved, with the remainder saying that the situation

had stayed the same

- Respondents across all groups regularly have to use circuitous routes to deliver to customers:

examples included nuclear fuel delivered to Asia from Europe being shipped via N. America adding

around 20 days, and hundreds of thousands of dollars of additional costs to the journey;

radiopharmaceuticals produced in a European country needing to be shipped by road to a

neighbouring country before being exported abroad.

- There is an increased burden of security regulation.

14 Respondents had the option to check a different box: three carrier services / two regular and reliable carrier services.

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Medical

International Isotopes Inc, Acerts Nuclear; China Isotope & Radiation Corporation; Chengdu Gaotong

Isotopes Co.,Ltd; China Isotope and Radiation Corp; Curium Netherlands B.V.; Cyclobras; Eckert &

Ziegler; FUSION Transportes; IPEN-CNEN/SP; In Medical Physics do Brasil; MMConex; Shenzhen

Zhonghe Headway Bio-Sci & Tech Co., Ltd

Research

CERN; Paul Scherrer Institut

Mining/Minerals

Mineração Taboca; Sievert Laboratório e Serviços Ambientais Ltda; AMG Mineração S.A.; CGNPC

Uranium Resources CO., Ltd.; Eco White Trading Ltda; CRONIMET Central Africa AG; Langer Heinrich

Uranium; Rossing Uranium Ltd

Industrial sources

TXNTC; Arctest

Nuclear industry

RSB Logistic; Westinghouse; EPZ; Cyclife UK Ltd; Orano; Sumitomo Corporation; Export Dept. China

Nuclear Energy Industry Corp; Industrias Nucleares do Brasil INB; Urenco; Cameco Corporation; Korea

Electric Power Company (KEPCO); KEPCO Nuclear Fuel

Table 3: Respondents to the 2020 TFWG survey (list excludes companies that asked for anonymity)

The results collected in the 2020 TFWG survey are comparable to those in 2015, which covered a similar

sample. That survey also showed that supply chains for international / maritime shipments were fragile.

Shippers were largely succeeding in transporting to customers, but were often forced to use indirect routings.

Unlike, the 2015 survey, it was noticeable that respondents felt the situation in 2020 was more difficult than

three years previously.

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3. Identifying remedial policies

The international transport of radioactive material is built on firm foundations, composed of two key elements:

a strong and harmonized global regulatory framework covering all modes; a mature industry that is competent

in the application of transport regulations and at finding innovative solutions. Every year, around 15 million

packages of radioactive material are shipped and delivered around the world in a safe manner. In developing

remedial policies to the issues of denial of shipments, it is essential that these foundations are not affected.

The TFWG has discussed policies that meet these objectives. While these are not costed, they are developed

with consideration of limited budgets and value for money in mind. Some were previously tried and tested

during the existence of the ISC, while some are based on new analysis that TFWG has performed. The seven

proposals are:

1) Appointment of an official within each country to oversee Cl. 7 transport facilitation with duties to

include:

a. knowing the main ports of entry / exit for Cl. 7 cargo

b. bringing together the main stakeholders for Cl. 7 transport (regulators, shippers, port

authorities, etc.) on a regular basis to share experience and challenges

c. helping to overcome obstacles that might be causing unnecessarily long shipment times

2) Each country to make publicly available the national competent authorities and regulations relevant to

Cl. 7 transport and to highlight differences to international norms

3) Each country to have at least two ports / airports within its national jurisdiction that are capable of

allowing import / export / transhipment / transit of Cl. 7.

4) Countries not to discriminate against Cl. 7 cargoes destined for other countries wishing to transit its

ports and airports.

5) Development of IAEA guidance and / or legal instrument on facilitation of Cl. 7 transport that IAEA

Member States can implement.

6) Development and delivery of Cl. 7 specific training courses for ports / airports and carriers.

7) Development and distribution of communication materials to increase understanding of Cl. 7 transport.

17

These policies are explored in more detail below. It is worth mentioning that in the 2020 TFWG survey

respondents were asked to provide their view of these proposals. The survey results can be found in Figure 1.

Figure 1: Attitude of TFWG survey respondents to policy proposals for improving Cl. 7 transport efficiency

1. Appointment of an official within each country to oversee Cl. 7 transport facilitation

This proposal fulfils the annual IAEA nuclear safety resolution, which calls upon Member States “to facilitate the

transport of radioactive materials and to identify, if they have not done so, a national focal point (NFP) on

denials of shipment of radioactive materials to achieve a satisfactory and timely resolution of this issue.” NFPs

were first created at the time of the ISC, and were an effective means of helping to improve the facilitation of

Cl. 7 shipment. At the time of the ISC’s closure in 2013, a network of over 70 NFPs had been created.

Brazil provides a good example of the positive impact an NFP can make. Since 2010 the NFP has maintained a

committee on denial of shipments. Meeting twice a year, this committee embraces representatives from air

and land modal transport agencies, qualified Class 7 cargo carriers, consignors and consignees – drawing on

average 50 people to meetings. The Brazilian Competent Authority (CNEN) provides expertise, the Scientific

Secretary and – at the meetings – is the facilitator.

The coordination has made an important difference. In Brazil, thanks to the support of a national committee on

denial of shipments, three new airlines have agreed to accept radioactive materials as cargo since 2015. This

meant that when the COVID-19 pandemic struck and passenger air transport was curtailed, the country was in a

better position to distribute radioisotopes to health centres around the country.

Because denial of shipment has safety and security implications (e.g. shipments delivered by circuitous routes;

abandoned material; lack of route diversity) it is reasonable for NFPs to be drawn from a national competent

authority (CA) for safe transport of radioactive materials. The CA works in liaison with other authorities such as

customs authorities, port/airport authorities, district police, federal police, modal regulatory agencies, health

and environmental authorities, understands the main industrial players and export /import routes bringing it a

broadly based understanding of the issues. However, where it is deemed by a Member State that the NFP

18

should sit outside the CA, the person can be drawn from a Ministry, e.g. for trade, transport, or health or from a

state-owned industrial enterprise. Fulfilling the role of NFP would require around 0.25 of a person / year’s

resource.

A NFP could potentially take on an additional responsibility: providing advice to carriers that inadvertently ship

undeclared Cl. 7 material.

2. Each country to make publicly available the national competent authorities and regulations relevant to

Cl. 7 transport to highlight differences to international norms

The increased transparency that would derive from this policy would help shippers to comply with regulations

when undertaking an international shipment of Cl. 7. ICAO already recommends that its members declare

differences to the regulations for the carriage of dangerous goods by air, which are published in the ICAO

Technical Instructions. The process of making such information publicly available might also expose examples

of overlapping or inconsistent regulation at a national level, and foster greater understanding between

different national authorities.

3. Each country to have at least two ports / airports within its national jurisdiction that are capable of

allowing import / export / transhipment / transit of Cl. 7

As was examined in 2.3, there is a lack of available port terminals for the loading / unloading, transit as well as

transhipment of Cl. 7 around the world. One of the responsibilities of the NFP would be to do an audit of

available options for the acceptance of Cl. 7 at a national level against these criteria. Where shortages are

identified, training and possible other measures would need to be undertaken to improve the situation.

4. Countries not to discriminate against Cl. 7 cargoes destined for other countries wishing to transit its

ports and airports.

Consignors regularly encounter the problem that their cargo cannot transit a particular port unless the final

destination of the cargo is within that country. Blocking the transit of Cl. 7 for this reason is an action of

potential self-harm, as it legitimizes the activity among other countries.

5. Development of IAEA guidance and / or legal instrument on facilitation of Cl. 7 transport that IAEA

Member States can implement

One of the potential solutions to DoS referred to in the 2020 Nuclear Safety Resolution is a Code of Conduct

(CoC). A C of C for the facilitation of safe transport would be a non-binding legal instrument, to which countries

make a political commitment. There have been two CofC developed under the IAEA to date: safety and security

of radioactive sources (2000 revised 2003); safety of research reactors (2004). They are there to provide

guidance to States on harmonising policies and regulations. To benchmark implementation, there are

processes for information exchange. Policy proposals 1 - 4 above could be part of a future C of C.

6. Development and delivery of Cl. 7 specific training courses for ports / airports and carriers

Technical training courses on Cl. 7 aimed at dangerous goods experts at ports, airports and carriers could help

to increase the capacity of such experts. General awareness training on Cl. 7 for management and handling staff

at relevant organizations would help to dispel some of the negative misperceptions about Cl. 7.

7. Development and distribution of communication materials to increase understanding of Cl. 7 transport.

19

This topic is covered under a separate World Nuclear Association paper to the IAEA TM DOS. A well-executed

communications strategy and plan could help change the prevailing attitude towards Cl. 7 among stakeholders

in the supply chain as an exceptional class of dangerous goods. Key messages to deliver would include the

beneficial uses of the cargo; the robust regulatory framework; the track record of transporting Cl. 7 safely. IAEA,

as a highly recognized entity and part of the UN family would be a good brand under which to develop

communication materials. Teaming up with other UN institutions would make sense in certain contexts. For

example, IAEA should work with WHO to develop materials on the transport of medical isotopes, and sources

used in the sterilization of medical instruments. An upshot could be more airlines, such as Air Canada, with a

positive policy to Cl. 7; air traffic control giving priority to aircraft taking off or landing with radioactive material.

20

4. Conclusion

This paper has focused on two modes key to the international shipment of radioactive material: maritime and

air. In the maritime area, issues with port terminal and carrier acceptance are chronic and are contributing to

fragile supply chains and to cargo being shipped by indirect routes. This runs counter to IAEA security guidance

on the transport of radioactive material. For air mode, acceptance levels are generally better, however – due to

the nature of the products being shipped - the effects of disruption can be catastrophic, as has been

demonstrated during the pandemic.

This points to the need for intervention to strengthen the security of supply. Because of the cross-border nature

of the supply chains for radioactive goods, approaches have to be international. Secondly, because industry

alone cannot overcome all the challenges, and because of the strategic importance of these materials in terms

of safety, security, healthcare, economy and environment, governments have a role to play.

To strengthen the system, industry must collaborate better across sectors to encourage carriers and ports to

accept radioactive material. The development and delivery of Cl. 7 specific training courses – both technical and

in terms of awareness-raising – would play an important role in this. Industry must also be better in collecting

data on Cl. 7 transport experience to help understand trends.

With its status as part of the UN system and international reach, IAEA is in an excellent position to

communicate and coordinate efforts on DoS. It has officially acknowledged the existence of an issue for almost

twenty years, and despite the dissolution of the Agency’s ISC in 2013, demonstrated with its resolutions to the

General Conference in 2019 and 2020 that it recognised fresh actions were required to address problems.

An immediate action that can be taken, that is called for by the GC nuclear safety resolution, is to reactivate

the National Focal Point network on denial of shipments. NFPs already exist in countries, such as Brazil,

Argentina, Sweden and Switzerland, and can have an instrumental role in addressing security of supply. Other

actions IAEA could take in the nearer term include working with WHO to develop communication material on

the transport of medical isotopes, and sources used in the sterilization of medical instruments. To support the

security of supply issues in the longer term, the Agency should also begin development of a voluntary Code of

Conduct on the facilitation of the safe transport of radioactive material. This could encompass some of the

ideas explored in Section 3.

21

Appendix 1

Policies of ports needed for global distribution of sealed sources

Country Port Loading /

unloading

Transit Transhipment

Asia

China Chiwan Not Permitted Permitted Not Permitted

Hong Kong Permitted Permitted Permitted

Ningbo Permitted Permitted Not Permitted

Qingdao Not Permitted Not Permitted Not Permitted

Shanghai Permitted Not Permitted Not Permitted

Shantou Not Permitted Not Permitted Not Permitted

Shekou Not Permitted Permitted Not Permitted

Shenzhen Not Permitted Not Permitted Not Permitted

Tianjin Low Activity

Permitted only

Permitted Not Permitted

Xiamen Not Permitted Permitted Not Permitted

Yantian Not Permitted Permitted Not Permitted

Bangladesh Chittagong Permitted Permitted Permitted

India Nhava Sheva Permitted Permitted Not Permitted

Mundra Not permitted Permitted Not permitted

Pipavav Not permitted Permitted Not Permitted

22

Korea Busan Permitted Permitted Not Permitted

Malaysia Port Kelang Permitted Permitted Not Permitted

Tanjung Pelepas TBD Permitted Not Permitted

Singapore Singapore Permitted Permitted Permitted

Sri Lanka Colombo Permitted Permitted Not Permitted

Taiwan Kaohsiung Permitted Permitted Permitted

Thailand Laem Chabang Permitted Not Permitted Not Permitted

Vietnam Vung Tau Terminal Permitted Not Permitted Not Permitted

Middle East, Persian Gulf, Eastern Med

Egypt Said, Damietta Permitted Permitted Not permitted

Iran Bandar Abbas Permitted Not Permitted Not Permitted

Israel Ashdod Permitted Not Permitted Not Permitted

Haifa Permitted Not Permitted Not Permitted

Lebanon Beirut Permitted Permitted Not Permitted

Pakistan Karachi Not permitted Permitted Not Permitted

Qasim Not permitted Permitted Not permitted

Turkey Izmir Permitted Permitted Not Permitted

Mersin Permitted Permitted Not Permitted

Istanbul Permitted Permitted Not Permitted

Africa

23

South Africa Durban Not Permitted Not Permitted Not Permitted

Cape Town Permitted Not Permitted Not Permitted

Tunisia Tunis Permitted Permitted Not Permitted

Europe

Belgium Antwerp Permitted Permitted Permitted

Germany Hamburg Permitted Permitted Permitted

Greece Piraeus Permitted Not Permitted Not Permitted

Italy Genoa Not Permitted Permitted Not Permitted

Malta Malta Not Permitted Not Permitted Not Permitted

Netherlands Amsterdam TBD TBD TBD

Rotterdam Permitted Not Permitted Not Permitted

Spain Algeciras Permitted Permitted Not Permitted

Barcelona Permitted Permitted Not Permitted

Tarragona Permitted Permitted Not Permitted

Valencia Permitted Permitted Not Permitted

Romania Constanta Not Permitted Not Permitted Not Permitted

Russia St. Petersburg Permitted Not permitted Not Permitted

Ukraine Odesa Not Permitted Not Permitted Not Permitted

United Kingdom Felixstowe Permitted Permitted Not Permitted

24

Liverpool Permitted Permitted Permitted

Southampton Permitted Permitted Permitted

South Pacific

Australia Sydney Permitted Permitted Not Permitted

Melbourne Permitted Permitted Not Permitted

New Zealand Auckland Permitted Permitted Not Permitted

Napier Permitted Permitted Not Permitted

Wellington Permitted Permitted Not Permitted

South America

Argentina Buenos Aires Permitted Permitted Not Permitted

Brazil Santos Permitted Permitted Not Permitted

Colombia Cartagena Permitted Permitted Not Permitted

Ecuador Guayaquil Permitted Permitted Not Permitted

Venezuela Port La Guaira Permitted Not Permitted Not Permitted

Central America

Dominican Republic Caucedo Not Permitted Not Permitted Not Permitted

Jamaica Kingston Not Permitted Permitted Not Permitted

Puerto Rico San Juan Permitted Not Permitted Not Permitted

North America

Canada Halifax Permitted Permitted Permitted

25

Montreal Permitted Permitted Permitted

USA Baltimore, MD Permitted Permitted Permitted

Charleston, SC Not Permitted Permitted Not Permitted

Everglades, FL Not Permitted Permitted Not permitted

Freeport, TX Not Permitted Not Permitted Not Permitted

Houston, TX Not Permitted Not Permitted Not Permitted

Jacksonville, FL Permitted Permitted TBD

Los Angeles / Long

Beach, CA

Permitted Permitted Permitted

Miami, FL Permitted Permitted Not permitted

New York / New

Jersey

Permitted Permitted Not Permitted

New Orleans Permitted Permitted Permitted

Norfolk Permitted Permitted Not Permitted

Oakland, CA Permitted Permitted Not Permitted

Pennsylvania Permitted Permitted TBD

Savannah, GA Permitted Permitted Not Permitted

Seattle, WA Permitted Permitted Not Permitted

Tacoma, WA Permitted Permitted Not Permitted

26

Appendix 2

Operator Variations Prohibiting Acceptance of Class 715

Adria Airways Class 7, Fissile materials will not be accepted for carriage.

Aer Lingus Class 7, Fissile radioactive material will not be accepted for carriage.

Aerolineas Argentinas Radioactive material will not be accepted for carriage

Air Astana Radioactive materials, including all categories of excepted packages, are not accepted for carriage.

Air Austral Radioactive material will not be accepted for carriage on board Air Austral aircraft.

Air Calédonie The transport of the following dangerous goods is forbidden by Air Calédonie - Radioactive

material class 7

Air Caraibes Only radioactive material Category I-White where the maximum radiation level at any point on any

external surface of a package or overpack does not exceed 0.005 mSv/h is accepted for transport.

Air Caraibes Atlantique Only radioactive material Category I-White where the maximum radiation level at any

point on any external surface of a package or overpack does not exceed 0.005 mSv/h is accepted for transport.

Air Europa Class 7, Radioactive materials, will not be accepted for carriage.

Air India Fissile radioactive material will not be accepted for carriage.

Air Seychelles The following dangerous goods are prohibited for carriage:

(a) Class 1 except 1.4S

(b) Class 7-Radioactive Material

Air Tahiti Only radioactive materials of Category I White (“RRW” code) are accepted for carriage.

The only exception is for UN 3332, Radioactive material, Type A package, special form, with a Transport Index

not exceeding 1, shipped exclusively by the Laboratoire des Travaux Publics.

Air Vanuatu Radioactive material, including all categories of excepted packages, will not be accepted for

transport.

All Nippon Airways Class 7 – Radioactive material Type (B(U) and Type A (various state regulations) accepted

for carriage with prior authorization. Type B(M), Type C, Fissile material (excluding fissile-excepted) packages,

SCO and LSA material in Industrial Packagings will not be accepted for carriage.

Atlasjet Airlines Class 7, Radioactive materials will not be accepted for carriage.

Atlasjet Ukraine Class 7, Radioactive materials will not be accepted for carriage.

Avianca Fissile radioactive material will not be accepted for carriage.

15 Source: IATA DGR, plus Transport Facilitation Working Group member experience

27

Avianca Ecuador Fissile radioactive material will not be accepted for carriage.

Aviateca Fissile radioactive material will not be accepted for carriage.

British Airways Class 7—radioactive material of any kind will not be accepted for carriage.

Brussels Airlines Class 7 – Radioactive material Type (B(U) and Type A accepted for carriage with prior

authorization. Fissile material will not be accepted

Cargolux Fissile radioactive material will not be accepted for carriage.

Cargolux Italia Fissile radioactive material will not be accepted for carriage.

China Southern Radioactive material of Categories III-Yellow will not be accepted for carriage.

Condor Flugdienst GmbH Fissile material will not be accepted for carriage. Class 7, Category II-Yellow will not

be accepted for carriage. Category I-Yellow and Radioactive Material excepted package are subject to prior

authorization.

Corsair Class 7—Radioactive material, including all categories of excepted packages, will not be accepted for

transport.

Delta Airlines UN2915 Radioactive Material, Type A package, and UN3332 , Type A packages will be accepted

for carriage, with prior authorization.

DHL Air Limited Radioactive and fissile wastes will not be accepted for carriage

DHL Aero Expreso S.A. Class 7, radioactive material, Category I-White, Category II-Yellow, III-Yellow, fissile

material and excepted packages will not be accepted for carriage.

EVA Airlines Class 7, Fissile radioactive material, Category II-Yellow, III-Yellow and excepted packages will not

be accepted for carriage.

Evelop Airways Class 7—Radioactive material will not be accepted for carriage.

Fiji Airways Radioactive material, including all categories of excepted packages, will not be accepted for

transport.

GOL Airlines Fissile radioactive material will not be accepted for carriage.

Gulf Air Fissile radioactive materials will not be accepted for carriage.

Hawaiian Airlines Class 7—radioactive material of any kind will not be accepted for carriage.

Hong Kong Air Cargo Class 7–radioactive materials, including all types of excepted packages will not be

accepted for carriage.

Iberworld Airlines Class 7—Radioactive material will not be accepted for carriage.

Japan Airlines Class 7 – Radioactive material Type (B(U) and Type A (various state regulations) accepted for

carriage with prior authorization. Type B(M) Packages and/or any SCO, or LSA Materials in Industrial Packagings

will not be accepted for carriage.

28

Korean Airlines Class 7 – Radioactive material Type (B(U) and Type A accepted for carriage with prior

authorization. Radioactive Type B(M), Type C packages and fissile materials packages will not be accepted for

carriage

Lufthansa Airlines Class 7 – Radioactive material Type (B(U) and Type A accepted for carriage with prior

authorization. Fissile material will not be accepted

MIAT—Mongolian Airlines Class 7—Radioactive material will not be accepted for carriage.

Neos SpA Class 7—Radioactive material will not be accepted for carriage.

Nippon Airlines Any Type B package, Type C package, SCO or LSA Materials in Industrial Packaging, Packages

containing Uranium Hexafluoride and Fissile Materials (including fissile-excepted) will not be accepted for

carriage.

Oman Air Class 7 Radioactive materials in any form will not be accepted for carriage. Special permissions in

exceptional circumstances may be granted subject to approval.

Orbest Airlines Class 7 shipments are prohibited.

Royal Brunei Airlines Class 7, Fissile radioactive material will not be accepted for carriage.

Royal Dutch Airlines/KLM Cityhopper B.V. Class 7–Radioactive material, with the exception of UN 2908, UN

2909, UN 2910, UN 2911 and UN 3507, will not be accepted for transport and handling.

RwandAir Class 7—radioactive material of any kind will not be accepted for carriage.

Saudi Airlines Class 7, Fissile Material, including fissile excepted, will not be accepted.

Singapore Airlines Class 7, Fissile Material, including fissile excepted, will not be accepted.

Solomon Airlines Class 7—radioactive material of any kind will not be accepted for carriage.

TACA Airlines Fissile Radioactive Material will not be accepted for carriage.

TAROM Romanian Air Transport Class 7 Radioactive material of any kind will not be accepted for carriage.

Thai Airways Intl Radioactive materials packed in Type B(U), Type B(M) packages; SCO or LSA packed in

industrial packages will not be accepted for carriage. Only radioactive materials with maximum TI not exceeding

3.0 which is intended for medical purpose will be accepted for carriage

Class 7, Fissile material, including fissile excepted will not be accepted for carriage.

Transavia Airlines C.V. Class 7, Radioactive materials are not accepted for carriage.

Ukraine International Airlines Radioactive materials are not accepted for carriage on passenger aircraft. This

requirement does not apply to Excepted Packages as defined in 10.5.8.

UPS – Accepts Cl. 7 between US, Canada and Mexico under contract only

Vietnam Airlines Class 7—Radioactive materials will not be accepted for carriage, except below radioactive

materials which met the following requirements

(a) intended for use in medical research or medical diagnosis and treatment; and

29

(b) approved by Vietnam’s Government for import, transit Vietnam by air transport.

(c) UN 2908 Radioactive material, excepted package–empty packaging;

(d) UN 2911 Radioactive material excepted package–instruments; and

(a) Radioactive materials in Type A package with Transport Index not exceeding 3.0 each package.

Virgin Atlantic Radioactive materials will not be accepted for carriage, apart from excepted packages: UN 2908,

UN 2909, UN 2910, UN 2911.

WestJet WestJet Cargo will not accept the following classes of dangerous goods for carriage: Class 7–

Radioactive materials, with exception of UN 2911, Radioactive materials, excepted package–instruments or

articles

30

Appendix 3

Interruption of the supply of isotopes to El Salvador and other Central American

countries due to the Covid-19 pandemic16

El Salvador has two companies17 with permits, infrastructure and experience in the distribution of

radiopharmaceuticals, which under normal conditions, guarantee stable supply of these products every week

for all nuclear medicine services in the country. These companies have a contract and act as distributors for

manufacturers in Argentina and Cuba. Under normal conditions, there are several air routes that, from both

origins, allow the importation of these products into the country.

El Salvador has a population of 6,745,400 inhabitants and has three health systems:

a) Public - serving 70% of the population.

b) Social security - serving 25% of the population and,

c) Private - serving 5% of the population

Five nuclear medicine centers are operating in the country: one public, one social security and three private.

Before the pandemic, the average entry into the country of isotopes was 8,000 mCi of iodine and 7,870 mCi of

technetium per month.

The shortage of radiopharmaceuticals ran from the end of March 2020 until October of the same year, caused

by the closure of the country’s borders to people with similar measures taken in neighbouring countries. These

changes led to a drastic decrease in commercial flights of the airlines operating in the Central American region

(AVIANCA and COPA). The few freight flights that operated in the aforementioned period to San Salvador, had a

spaced frequency and did not coincide with the production cycle of the manufacturers. They operated with a

stopover in Miami and the delivery of the product on average took between 7-15 days from origin to

destination, which is completely unworkable for the transportation of highly perishable medical isotopes. This

situation was similar for all Central American countries such as Panama, Honduras, Guatemala, Nicaragua,

Costa Rica, which also saw their supplies and nuclear medicine paralyzed, a situation that still persists in the

case of Honduras and Nicaragua due to the lack of availability of flights that can transport this type of product.

The supply of radiopharmaceuticals to El Salvador was restored in October from the moment the airport was

opened, and to date it is carried out weekly and uninterruptedly from Argentina and from Cuba.

The closure of borders to people as a mechanism to stop the advance of the COVID-19 pandemic has been used

by most countries in all regions of the world. The drastic decrease in commercial flights has been the common

denominator of all the world's airlines and is an element that still persists and will persist in the face of constant

outbreaks of the virus, state restrictions and the unwillingness of the world population to travel. The

bankruptcy of airlines and closure of air routes has become frequent and daily news. That the airlines establish

restrictive policies for the transportation of dangerous substances and specifically radioactive material is not

new and constitutes an important factor in the selection of the distribution channels of radiopharmaceuticals;

cargo flights are not regular and operate subject to routes and cargo availability, which (although used

16 This report has been compiled by medical experts at the Salvadoran Institute of Social Security 17 CORPORACION NOBLE S.A. DE C.V; Diversidades Tecnológica, S.A. de CV

31

occasionally) makes them very unsuitable to ensure the stable supply of medical isotopes. Using a charter

service for the exclusive transportation of these products is unaffordable and not very rational for a supplier or

State to use as a supply variant. These are the reasons why the supply of radiopharmaceuticals was paralyzed in

El Salvador and in other Central American countries. It was not due to the lack of supply, and indeed Argentine

companies continue to produce during this period on a weekly basis. This situation could unfortunately be

repeated, taking into account the epidemiological situation in the region and the world, and the measures that

countries are inevitably forced to take in their containment strategy.

The supply has been re-established uninterruptedly on a weekly basis since October, but the epidemiological

conditions of COVID-19 could return to the conditions that prevented the supply, which must be avoided if at all

possible. In current conditions, one of the problems is the policy of COPA (the only airline in the region that

currently guarantees transportation reliably) regarding the limit of packages (8) and Index of Transportation

(12) and the non-acceptance of cargo splitting of the same consignment on different flights. As for AVIANCA,

the policy of the company headquartered in Bogotá has caused the products to take between 3-5 days to reach

their destination. For both of these problems, the intervention of the IAEA would be desirable.

Both companies that distribute radiopharmaceuticals in El Salvador are committed to ensure security of supply.

CORPORACION NOBLE S.A. DE C.V. ratifies its will and commitment to collaborate in what is within its reach, to

guarantee the stable and safe supply of radiopharmaceuticals to the nuclear medicine services of El Salvador.

Diversidades Tecnológica, S.A. de CV maintains its efforts focused on the continuity of supply week by week,

complying with the local regulations of the competent authorities (Ministry of Health, Civil Protection, etc.), and

awaits possible favorable results obtained from meetings like IAEA Technical Meeting on Denials of Shipment

that can influence the timely shipment of radioactive material to El Salvador, coordinating with producer

countries such as Argentina and Cuba and countries and airports in transit such as Bogotá and Panama, and any

other entities that may favor the expedited shipment of these dangerous goods from and to their destination

country.

The Salvadoran Institute of Social Security consulted with Mexico over their provision of radioisotopes for

nuclear medicine, but met with the following difficulties:

1. The products are not licensed in El Salvador

2. Air transport is suspended during the pandemic

3. Higher costs.

Potential solutions.

1. Development of possible new route to El Salvador from Argentina via Miami

2. The urgent granting of new licenses to new providers, such as in the USA