How Do Dangerous Goods Regulations Apply to Uncrewed Aerial Vehicles Transporting Medical Cargos?

Abstract

Commercial operations of uncrewed aerial vehicles (UAVs or drones) are expanding, with medical logistics using UAVs as part of health service supply chains being targeted. The ability to transport cargos that include items classified as Dangerous Goods (DGs) is a significant factor in enabling UAV logistics to assist medical supply chains, but DG regulations for air transport have developed from the perspective of crewed aircraft and not UAVs. This paper provides an important audit of the current DG regulations, best practice in their application and the development of much-needed new governance that will be required to fully exploit UAVs for the safe transport of DGs in medical logistics. Findings from the audit provide a summary of the circumstances and potential challenges resulting from the application of DG regulations as they stand to UAV operations, particularly for medical logistics, and convenient guidance on the practical implications of DG regulations for UAV operators. The main conclusion is that this is an under-researched domain, not yet given full consideration in a holistic way by regulators, governments, industry bodies, practitioners or academia.

Enabling Safe and Sustainable Medical Deliveries by Connected Autonomous Freight Vehicles Operating within Dangerous Goods Regulations

“…As noted by Grote et al [24], existing ICAO DGs regulations do not explicitly cover movements using autonomous aerial vehicles, and this is also the case with ground based autonomous freight vehicles and the ADR, with technology outpacing regulation in a similar fashion to the "pacing problem" [28]. There has been some interest by the PHMSA, requesting information from stakeholders on areas of concern arising from autonomous DGs transport on land, but no further developments have been recorded to date [29].…”

“…Any exemptions from regulations were carefully studied so that suggested practices were not excessively cautious, and important factors were not excluded from the study. The methods used in this study align with those presented by Grote et al, [24], which gave stakeholders a thorough interpretation of the relevant areas of DGs regulation implementation for another emerging transport mode (i.e., UAVs).…”

“…The following section highlights the classification of CAV-Fs as a mode of transport; the types and characteristics of medical goods carried by CAV-Fs; and any exemptions which apply as a result of these arrangements. The methods used in this study align with those presented by Grote et al [24], which gave stakeholders a thorough interpretation of the relevant areas of DGs regulation implementation for another emerging transport mode (i.e., UAVs).…”

“…Many medical products can be classified as DGs, and it is important for logistics operators transporting such items to be able to meet the associated regulatory requirements and ensure relevant modes can be used to transport DGs legally and effectively [23]. Grote et al [24] investigated the implications of DGs regulations on the transport of medical cargoes via autonomous airfreight (i.e., via Uncrewed Aerial Vehicles; UAVs). Freighting of DGs is broadly addressed by the "UN Recommendations on the Transport of Dangerous Goods-Model Regulations" [23] and is subsequently adapted to suit the travel mode by the appropriate regulatory body.…”

“…1 Section 1.2 [14] A key issue in any supply chain involving multiple transport modes relates to how cargoes are safely transferred between them as part of the transhipment process. This places additional requirements on shippers and logistics providers when DGs are involved [24]. Under such circumstances, the appropriate regulatory rules for the specific mode will apply.…”