NOTOC (Notification to Captain): Entries, Timing, and Penalties

To fill out a NOTOC (Notification to Captain), enter each hazardous shipment on the form using the twelve data points required by 49 CFR 175.33, pull the details directly from the shipper’s declaration and the physical loading plan, and give the completed form to the pilot-in-command and flight dispatcher before the aircraft moves under its own power.¹ The pilot signs to acknowledge receipt, the form stays accessible on the flight deck for the whole trip, and the operator keeps it on file for 90 days after landing. Everything else on the form flows from those basics.

The Twelve Required Entries

Every hazardous shipment on the NOTOC needs the following information. Ground handling staff typically transfer these from the shipper’s declaration into the operator’s standardized system, but a handwritten or printed form is equally valid under federal rules.

Date of the flight, which ties the record to a specific operation for auditing.
Air Waybill number, when one has been issued, linking the packages to the freight record.
Proper shipping name.
Hazard class or division, plus any subsidiary risks.
Packing group.
UN or ID number. For Class 1 explosives, the compatibility group letter also goes here.
Total number of packages in the consignment.
Net quantity or gross mass. When multiple identical packages ship together, you can list the total quantity plus the largest and smallest package at each loading location rather than itemizing every package. Radioactive materials are the exception: they need the package category and transport index instead of mass.
Exact loading location, meaning the specific Unit Load Device position or cargo compartment. This is the entry that tells the crew where to direct firefighting if something goes wrong in flight, so precision matters.
Cargo Aircraft Only indicator, stated clearly when the shipment cannot fly on passenger aircraft.
Destination airport where the packages will be unloaded.
Special permit or state exemption notation, if the shipment moves under any regulatory exemption.

A contact telephone number that someone will answer for the full duration of the flight must also be available to the crew. It doesn’t have to appear on the form itself as long as it’s posted somewhere the cockpit knows to look.¹

Simplified and Special Entries

Dry ice (UN1845) gets a shortened treatment: UN number, proper shipping name, hazard class, and total quantity per compartment. That’s it.

Limited quantity shipments are handled differently depending on which rulebook governs the shipment. Under the ICAO Technical Instructions, the words “Limited Quantity” or “LTD QTY” don’t need to appear on the notification. Under the U.S. Hazardous Materials Regulations (49 CFR Parts 171–180), those words are required on the NOTOC because 49 CFR 172.202 and 172.203 add description requirements.² A carrier flying the same product internationally versus domestically will fill in the form differently. When the applicable framework is unclear, including the limited quantity notation is safer than leaving it out.

Emergency Response Drill Codes

Many operators add a drill code for each hazardous item on the NOTOC. These codes come from ICAO Doc 9481 and consist of a number followed by one or two letters.³ The number points to a line on a standardized chart describing the hazard and the recommended crew response — for example, which extinguishing agent to use, whether to ventilate, whether to avoid water. The letter flags secondary hazards like toxicity or corrosivity. If a drill code isn’t printed on the NOTOC, the crew can look it up in Doc 9481 using the proper shipping name or UN number from the form.

Getting It to the Pilot in Time

The regulation says the form must reach the pilot-in-command and the flight dispatcher “as early as practicable before departure,” with a hard deadline of the moment the aircraft begins to move under its own power. Some airline procedures set an internal cutoff of 15 to 45 minutes before pushback, but 49 CFR 175.33(a) draws the legal line at first movement.¹

The pilot-in-command must acknowledge receipt in writing. Handwritten, printed, or electronic all count; a signature on paper and a digital confirmation in the operator’s system both satisfy the rule. The form and its associated emergency response information stay with the pilot-in-command and flight dispatcher for the full flight, meaning accessible on the flight deck or in the electronic flight bag, not stowed away in the hold.

Intermediate Stops and Crew Changes

On multi-leg operations, the NOTOC travels with the flight. When crews change at a transit point, the outgoing pilot passes the form to the incoming one so no one operates the aircraft without knowing what’s below. If new dangerous goods are loaded en route, the ground handling station issues either an updated NOTOC covering the full hazardous cargo profile or a separate addendum listing only the additions. The pilot for the next leg signs off on the new information before the aircraft moves.

Shipping papers and pilot-in-command information also have to be readily accessible at both the airport of departure and the intended airport of arrival throughout the flight, so ground operations at both ends should be able to pull up the cargo details if controllers or responders need them while the aircraft is airborne.

After the Flight: Retention and Access

The operator has to keep the pilot-in-command notification for 90 days, either at the airport of departure or at the operator’s principal place of business. Shipping papers for the same shipments follow separate retention schedules: one year for standard hazmat, three years for hazardous waste.¹

Reporting Discrepancies After Departure

If someone discovers after acceptance that a hazardous shipment was improperly described, certified, labeled, marked, or packaged, or that a package accepted as non-hazardous actually contains regulated materials, 49 CFR 175.31 requires notifying the nearest FAA Regional Office “as soon as practicable.”⁴ Reports can be filed by phone or electronically. The FAA Washington Operations Center operates 24 hours at 202-267-3333. The report must include the reporter’s name and phone number, the aircraft operator’s name, the shipment’s location, the shipper’s name, and the nature of the discrepancy. Add the shipper’s address if you have it.

What a Mistake Costs

Failing to give the pilot-in-command accurate information violates federal hazardous materials transportation law under 49 U.S.C. 5123. As of the inflation adjustment effective in 2025, the FAA can impose a civil penalty of up to $102,348 per violation, rising to $238,809 if the violation results in death, serious illness, severe injury, or substantial destruction of property.⁵ These amounts adjust annually.

Penalties are assessed per violation, not per flight. One shipment with several NOTOC errors — a wrong loading location, a missing subsidiary risk, and an omitted cargo-aircraft-only designation, for instance — can be treated as three separate violations. That is the practical case for slowing down and checking each entry against the shipper’s declaration before the form goes to the flight deck.