Date: 202103
Local time of day: 1201-1800
Location: ZZZ.Airport, US
Aircraft: Commercial Fixed Wing
Operator: Air Carrier
Operating under: Part 121
Flight plan: IFR
Mission: Passenger
Flight phase: Parked
Reporter organization: Air Carrier
Reporter function: Captain; Pilot Flying
Reporter qualification: Flight Crew Air Transport Pilot (ATP); Flight Crew Instrument; Flight Crew Multiengine
Human factors: Communication Breakdown
Anomaly: Deviation / Discrepancy - Procedural Hazardous Material Violation; Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Flight Crew
When detected: Pre-flight
Result: Flight Crew Overcame Equipment Problem
Contributing factors: Company Policy; Procedure; Environment - Non Weather Related
Primary problem: Company Policy

Narrative: While boarding the ramp manager arrived to the flight deck with a NOTOC regarding 20 KG of dry ice being loaded onto the aircraft. The Ramp Manager informed the Captain that it was freight containing pharmaceuticals; not a UN3373. She also told the Captain that [this] was not an expedite item. Moments later the Dispatcher sent an ACARS to tell the Captain to verify that the package was an expedite item. The Ramp Manager again confirmed that it was NOT an expedite item. The Captain called the Dispatcher and they discussed that the package was not a expedite medical supply item or an expedite UN3373 and was therefore limited to 2.5KG per package. Because the package was 20 KG the Captain asked that it not be loaded. After swapping aircraft due to an unrelated Maintenance issue; the Captain went to look at the package and noted that it had a handwritten label saying it was the X Company Vaccine. The Captain noted that because it was not an expedite item it was not labeled normally; i.e.; it did not state 'Contains dangerous goods...' and did not have the dry ice placard. It also had a marking indicating that it contained no dangerous goods. When speaking with the Dispatcher again the Dispatcher told the Captain that we were indeed authorized to carry it citing the national state of emergency due to the pandemic. Captain read the FOM chapter pointing out that it was not an expedite medical supply item and not an expedite UN3373 and should therefore be limited to 2.5 kg of dry ice; but the Dispatcher assured the Captain that we could take it. The Captain confirmed that the package would not be able to fly on any other flight that day. After conferring with Dispatch; and the manager who brought up the NOTOC who confirmed the contents the package was loaded on to the aircraft. There were no further issues.Flight crew and Dispatch worked together to determine if the item was safe for transport.Speaking with Dispatch and the Ramp Manager; it became clear that each party agreed that the 20 kg of dry ice would normally exceed the limit for an individual package that is not an expedite medical supply item or expedite UN3373; it was; however; also agreed that this vaccine shipment was somehow excepted from that normal requirement. The cause would seem to be some confusion as to whether or not freight which is not an expedite item that contained medical supplies; specifically the Vaccine; were allowed. Perhaps a lack of guidelines specific to the transport of the vaccine was a possible cause (if such an exemption from policy exists). The Captain determined after speaking with the individual parties that it would be safe to transport.Better guidance; including up to date flow charts; to help navigate this issue. It is not entirely clear whether a medical supply needs to be an expedite item in order to be exempt from the individual limitations of 2.5 kg. Although both the Captain and the Dispatcher initially thought that it does need to be an expedite item to contain more than 2.5 KG; the chapter in the FOM does not expressly say either way. The exception to the limit of 2.5KG appears to be listed under the expedite item section on the maximum limits page of the FOM; but it then states; 'Dry Ice weight may exceed the 2.5 kg (5.5 lbs) limitation; if contained within the UN3373 expedite item or medical shipment.' The use of the word 'or' may indicate that a medical supply need not be an expedite item even though it is located under the expedite item section. This could use clarification. If a medical shipment can exceed 2.5 KG without being an expedite item; then it should be listed as a separate exception. Similarly; if the medical shipment MUST be an expedite item that should also be clearly stated. If there is some exception due to the pandemic for the COVID vaccine that should be conveyed. The current flow chart contained on our system could stand to be updated. Specially; it lists all limits in pounds; but the NOTOC is in KG; which in itself renders the tool useless. Also; the flow chart ask the question 'is dry ice in an expedite item?' This is a yes or no question; but the flow chart only has an option for 'YES.'




Synopsis: Air carrier Captain reported a hazardous material documentation issue while attempting to transport a vaccine.