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Number 30 – Technical Directive: Mishandled Baggage, effective Jan 1, 2019

DEPARTMENT OF TRANSPORTATION

BUREAU OF TRANSPORTATION STATISTICS

OFFICE OF AIRLINE INFORMATION

TITLE 14 CODE OF FEDERAL REGULATIONS PART 234

TECHNICAL REPORTING DIRECTIVE #30 - MISHANDLED BAGGAGE AND WHEELCHAIRS AND SCOOTERS

ISSUE DATE:   October 31, 2018

EFFECTIVE DATE:   January 1, 2019

The Bureau of Transportation Statistics (BTS), Office of Airline Information (OAI), is issuing this Technical Reporting Directive to update the list of reporting air carriers and to provide instructions for carriers on how to report Mishandled Baggage and Wheelchairs and Scooters data for air transportation performed in 2019.

This Technical Reporting Directive addresses changes to the reporting procedures applicable to mishandled baggage that will take effect on January 1, 2019, pursuant to two final rules issued in November 2016. 

The first final rule, issued on November 2, 2016, titled “Reporting of Data for Mishandled Baggage and Wheelchairs and Scooters Transported in Aircraft Cargo Compartments,” 81 Fed. Reg. 76300, changed the reporting criteria for mishandled-baggage data from the number of mishandled baggage reports and the number of domestic passenger enplanements to the number of mishandled bags and the number of bags enplaned. This rule also requires separate statistics for mishandled wheelchairs and scooters. 

The second final rule, issued on November 3, 2016, titled “Enhancing Airline Passenger Protections III,” 81 Fed. Reg. 76826, lowered the reporting carrier threshold for mishandled baggage from at least 1.0 percent of domestic scheduled passenger revenues to at least 0.5 percent.  This final rule further required reporting carriers that market domestic scheduled codeshare flights to file separate mishandled baggage information for codeshare flights marketed under only one U.S. carrier’s code. 

Changes to mishandled baggage reporting consequent to these two final rules apply to domestic nonstop scheduled flights occurring on or after January 1, 2019.[1]  

Table of Contents

Section I. Introduction

Section II. Applicability

Section III. Reporting of Mishandled Baggage and Wheelchairs and Scooters Data

(a) Definitions

(b) Report Data Files

(c) Additional Reporting Information

(d) Report Certification

Section IV. Submission of Reports

Section V. Record Retention

Section I.  Introduction

Part 234 of the U.S. Department of Transportation's (Department's) Regulations, Airline Service Quality Performance Reports (ASQP), requires certain U.S. air carriers to submit information on mishandled baggage, and wheelchairs and scooters to the Department. These data are used to monitor each carrier's baggage, and wheelchairs and scooters handling, and to provide information to consumers. This information is filed monthly by electronic means with the required certification and transmittal letter.

Section II. Applicability

(a)  Each certificated air carrier providing scheduled domestic passenger operations must file “Mishandled Baggage and Wheelchairs and Scooters” data beginning in 2019 if its share of the industry’s total domestic scheduled-service passenger revenues is at least one half percent (0.005), based on Form 41 data for the 12 months ending June 30, 2018.

(b) There are 17 air carriers that reached the reporting threshold of $481,192,625 in domestic scheduled passenger revenues (one half percent of total domestic scheduled service passenger revenues) for the 12 months ending June 30, 2018. These carriers must submit mishandled baggage and wheelchairs and scooters data to the Department for calendar year 2019.

REPORTING AIR CARRIERS

  • Alaska
  • Allegiant
  • American
  • Delta
  • Endeavor
  • Envoy
  • ExpressJet
  • Frontier
  • Hawaiian
  • JetBlue
  • Mesa
  •  PSA
  • Republic
  • SkyWest
  • Southwest
  • Spirit
  • United

Changes in reporting air carriers will be made, as necessary, by the Director of OAI under authority delegated in 14 CFR 385.19.

(c) The reportable flight operations for which data must be submitted to the Department are (1) domestic nonstop scheduled passenger flights, including mechanically delayed flights, operated by a reporting air carrier to or from any reportable airport; and (2) domestic nonstop scheduled passenger flights, including mechanically delayed flights, to or from any reportable airport, marketed under only one U.S. carrier’s (the reporting carrier’s) designator code and operated by a code-share partner that is a certificated air carrier or commuter air carrier.

(d) The reportable airports are large, medium, small, and non-hub airports as defined in 49 U.S.C. 47102 which are included in the 2019-2023 National Plan of Integrated Airport Systems (NPIAS) transmitted to Congress on September 26, 2018.  The list of NPIAS airports, including large, medium, small, non-hub, and other airports, can be accessed through the FAA at the link: https://www.faa.gov/airports/planning_capacity/passenger_allcargo_stats/categories/

(e) Any carrier not included in paragraph (b) of this section, may voluntarily become a reporting carrier and submit Mishandled Baggage and Wheelchairs and Scooters data for its domestic nonstop scheduled passenger operations, including flights that it markets and are operated by its code-share partners, to or from each reportable airport, as described in this Technical Directive, provided that the Director of OAI is advised beforehand. Further, such voluntary data must then be submitted for a minimum of 12 consecutive months. The voluntary submission must meet the exact reporting specifications set forth in this directive. Volunteering carriers that wish to discontinue reporting after one year must advise the Director of OAI a minimum of 30 days before discontinuance, so that the necessary changes can be made to the Department's data processing procedures.

Section III.  Reporting of Mishandled Baggage and Wheelchairs and Scooters Data

  1. Definitions

For the purposes of this document:

  1.  ‘Codeshare’ or ‘Code-share’- means a flight marketed under only one U.S. carrier’s (the reporting carrier’s) designator code and operated by another carrier that is a certificated or commuter air carrier.
  1. ‘Domestic’- means a flight between or within any of the 50 States of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the U.S. Virgin Islands, American Samoa, the Northern Mariana Islands, the Trust Territory of the Pacific Islands, and Guam.[2]     
  1. ‘Flight’- means any nonstop passenger flight segment with a specific flight number scheduled to be operated pursuant to a published schedule within a specific origin-destination city pair, other than trans-border or foreign air transportation.[3]
  1. ‘Gate Checked Baggage’- means baggage that a passenger brought to the gate that is taken by the carrier at that location, checked into the baggage compartment of the aircraft, and are expected to be returned to the passenger at a baggage claim area of the airport.[4]
  1. ‘Interlined Baggage’- means baggage of passengers traveling on itineraries including multiple flights on multiple airlines that, because of a commercial agreement, is accepted by the participating airlines, allowing passengers to change from one flight on one airline to another flight on another airline without having to pick up and recheck their bags.
  1. ‘Mishandled’- means lost, delayed, damaged or pilfered.[5]
  1. ‘Valet Bag’- means a bag that a passenger is instructed by the carrier to drop off at the end of the loading bridge or on the tarmac near the aircraft and which carrier personnel load into the baggage compartment of the aircraft and return to the passenger on the loading bridge or tarmac following the flight.[6]
  1. ‘Wheelchair and Scooter’- means a manually-operated or power-driven device with wheels designed primarily for use by an individual with a mobility disability for the main purpose of indoor, or both indoor and outdoor, locomotion.
  1. ASQP – Mishandled Baggage Data Files

Each reporting carrier must submit a Baggage Data File Form 1, as described below, to OAI for the domestic flights operated by that carrier to or from a reportable airport in a reportable month.  Additionally, each reporting carrier that markets domestic scheduled codeshare flights must submit a Baggage Data File Form 2 (codeshare), as described below, to OAI for the domestic flights marketed under only one U.S. carrier’s (the reporting carrier’s) designator code and operated by a codeshare partner to or from a reportable airport in a reportable month.

The ASQP – Mishandled Baggage Data Files must be created as an electronic “comma separated value” file, using ASCII text character encoding, for uploading via the “eSubmit” application.

Sample Data File Record Format (Form 1): ZZ,2010,03,2023,35000,918,2485

Sample Data File Record Format (Form 2): XX,2010,03,2023,35000,918,2485

            The comma separated value file MUST BE indicated when naming the file, by using the letters [CSV] or [csv] following the file name, as the file name extension.

Suggested file name for Data File (Form 1): ZZ201003-234mbr.csv

The file name for reports of codeshare flights filed by a marketing carrier must contain the word “codeshare” to indicate the nature of the file.

Suggested file name for Data File (Form 2): XX201003-234mbr-codeshare.csv

Baggage Data File Form 1

Field Description

Data Type

Length

Comments

Sample Data

Operating Carrier code

Character

2

Two letter IATA code

ZZ

Year of Data

Numeric

4

Year (CCYY)

2010

Month of Data

Numeric

2

Month (MM)

03

Number of Mishandled Bags

Numeric

Varies

2023

Number of Bags Enplaned

Numeric

Varies

35000

Number of Mishandled Wheelchairs and Scooters

Numeric

Varies

918

Number of Wheelchairs and Scooters Enplaned

Numeric

Varies

2485

Baggage Data File Form 2 (Codeshare)

Field Description

Data Type

Length

Comments

Sample Data

Marketing Carrier code

Character

2

Two letter IATA code

XX

Year of Data

Numeric

4

Year (CCYY)

2010

Month of Data

Numeric

2

Month (MM)

03

Number of Mishandled Bags

Numeric

Varies

2023

Number of Bags Enplaned

Numeric

Varies

35000

Number of Mishandled Wheelchairs and Scooters

Numeric

Varies

918

Number of Wheelchairs and Scooters Enplaned

Numeric

Varies

2485

Number of Mishandled Bags: Reporting carriers must report the number of mishandled bags, as reported by or on behalf of passengers, that were mishandled while in its custody, including gate-checked baggage, “valet bags,” interlined bags, and wheelchairs and scooters.

(1) For bags traveling on purely domestic itineraries with multiple operating carriers on a single ticket, the Department considers carriers involved in the itinerary to be in compliance with DOT reporting rules if:

(A) the carriers accurately determine the actual number of bags mishandled in each carrier’s custody, and the carrier responsible for the mishandling reports it to the Department; OR

(B) the carriers, for bags other than valet bags[7], do not determine where or by whom a bag was mishandled, but all carriers agree to have the carrier that operated the last flight segment report the mishandling to the Department,[8] if that carrier is a reporting carrier, and that carrier accurately reports in this manner to the Department.[9]   

(2)  For bags of passengers traveling on itineraries with reportable domestic segments and nonreportable international segments, the Department considers the carrier in compliance with DOT reporting rules if:

(A) the carrier accurately determines whether a bag was mishandled while traveling on a domestic segment, and reports to the Department if that is the case[10]; OR

(B) the carrier accurately excludes, from the data submitted to the Department, mishandled bags as reported by passengers traveling on international itineraries with domestic segments, other than mishandled valet bags on domestic segments, and the carrier also accurately excludes the number of bags enplaned into the aircraft cargo compartment on international itineraries with domestic segments, other than valet bags transported on domestic segments.[11]

No later than December 1 of each year, reporting carriers must identify and submit in writing to “Ontime.support@dot.gov” their reporting methods for the upcoming calendar year for bags traveling on purely domestic itineraries with multiple operating carriers on a single ticket and for bags traveling on itineraries with reportable domestic segments and nonreportable international segments.[12]  Each reporting carrier intending to submit data to the Department in the manner described in (1)(B) of this subsection for any of its flights involved in  a purely domestic itinerary should identify to the Department all carriers with which it has an agreement to handle domestic interlined baggage and, separately, which of these carriers have agreed to report using option (1)(B) (participating carriers).[13]  The carriers that choose to report data to the Department in the manner described in (1)(B) must report consistently in that manner for the entire calendar year for bags traveling on participating carriers.  Additionally, a carrier that chooses to exclude domestic segments of international itineraries as described in (2)(B) of this subsection must report for the entire calendar year only in this manner. 

Number of Bags Enplaned: Reporting carriers must report the number of bags, including gate-checked baggage, “valet bags,” interlined bags, and wheelchairs and scooters that were placed into the aircraft cargo compartment for each domestic nonstop scheduled passenger flight.  For example, if a passenger was traveling one-way from Denver to Boston with a connection requiring a change in aircraft in Chicago, the bag will be counted twice as it was placed into the cargo compartment of two aircraft.  Consistent with this approach, if that passenger were instead traveling on a direct flight from Denver to Boston with an intermediate stop in Chicago with no change of planes, the bag would be counted only once – when it was enplaned in Denver.[14] 

For carriers excluding mishandled bags of passengers traveling on domestic segments of international itineraries as described in (2)(B) of this subsection, the carrier would also exclude the bags enplaned on domestic segments of international itineraries.  An acceptable way of doing this is by taking the carrier’s monthly total number of bags enplaned and then removing from it the monthly total number of bags associated with a passenger name record that includes a segment departing from or landing in a location outside the United States.  Additionally, for carriers using this reporting method, mishandled valet bags on domestic segments of international itineraries would be reported in the number of mishandled bags, and valet bags on domestic segments of international itineraries would be included in the number of bags enplaned.

  1. Additional Reporting Information.

What should be reported as a Mishandled Bag?

Generally, carriers must report to the Department all bags (including wheelchairs and scooters) reported by or on behalf of passengers as lost, damaged, delayed, or pilfered, that occurred in the custody of the carrier or the custody of its code-share partner (as defined in subsection (a)(1) of this section) for domestic flights to or from any U.S. large, medium, small or non-hub airport.  For multi-carrier itineraries, the carriers involved must determine under which carrier’s custody the bag was mishandled and report accordingly or report the mishandling to the Department based on the carrier that operated the last flight segment.  For itineraries with reportable domestic segments and nonreportable international segments, the carriers must determine whether a bag was mishandled on a domestic segment and, if so, report the mishandling to the Department or exclude the mishandled bag and enplaned bag on international itineraries with domestic segments (other than the valet bags on the domestic segment(s)).

A bag is considered delayed when the bag is reported as delayed or lost, and the bag is not yet proven lost.  For example, a bag that is located and returned within 30 minutes, or with the arrival of the next flight is still reportable to the Department if the passenger reports it to the carrier as delayed or lost, and should not be filtered out by carriers.  The mishandled baggage number sent to the Department should include, for example, reports by or on behalf of a passenger of a mishandled bag even if the passenger had agreed to a voluntary separation from his or her baggage, courtesy tracer reports, baggage improperly checked by skycaps, baggage claimed by the wrong passenger, and baggage delayed because of security.

What should not be reported as a Mishandled Bag, Wheelchair, or Scooter to DOT?

The following are the limited instances when a carrier may exclude a bag reported as mishandled by or on behalf of the passenger from its report to the Department:

  1. When a particular type of mishandling (i.e., loss, delay, damage, or pilferage) for the same bag on the same trip itinerary is reported more than once, the carrier need only include one mishandling in its statistics.
  1. When a bag is reported by or on behalf of a passenger who did not have a reservation for an itinerary marketed or operated by the carrier.
  1. When a bag is reported lost or delayed, undisputable evidence (e.g., video footage or the passenger’s own statement) shows that the bag was picked up without delay, such as by the consumer’s traveling companion.
  1. When a carrier is reporting for domestic segments of international itineraries pursuant to (b)(2)(A) of this section, and a bag is reported lost or delayed at the passenger’s final destination, undisputable evidence shows that the bag was available in the appropriate location at the first point of entry into the United States, to be picked up by the passenger for rechecking for a subsequent domestic flight segment on that itinerary, but the passenger failed to pick up the bag.
  1. After a bag is reported pilfered, information is presented by the passenger, or his or her representative, that the missing items were found.
  1. When the airline has conclusive evidence that a report was filed as a result of fraud.
  1. When conclusive evidence shows that the mishandling reported did not occur in the reporting carrier or its code-share partner’s custody (as described below).

In the event a carrier discovers an instance described above after reporting data to the Department for the month in which the mishandling occurred, the carrier may not revise that month’s data by subtracting this mishandled bag or omit a mishandled bag in any subsequent month’s report.

           

When is a bag (including a wheelchair or scooter) in a carrier’s custody?

For the purposes of reporting mishandled baggage data to the Department, a bag, wheelchair, or scooter is in the custody of a carrier beginning at the point in time which the passenger hands the bag to the carrier’s representative or agent, or leaves the bag at a location as instructed by the carrier.  A carrier’s custody ends when the passenger, a party acting on the passenger’s behalf, or another carrier takes physical possession of the bag.  A bag loaded on a conveyor belt and unclaimed by a passenger is considered to remain in the carrier’s custody.

For a bag that is being handed off between carriers or its agents such as for purposes of transferring the bag to a connecting flight, the arriving carrier is considered to be in custody of the bag until the receiving carrier or its agent takes physical possession of the bag or the bag is left at a location as instructed by the receiving carrier. 

For the purposes of reporting mishandled baggage data to the Department, the Department considers security screening, such as that performed by the TSA or contracted security screeners, to be part of the carrier’s process in handling baggage.  Therefore, possession of a bag by these entities is not an event that breaks a carrier’s custody.

Do carriers need to report mishandlings by third parties?

Carriers are responsible for reporting mishandled bags occurring in the custody of their third-party contractors, such as a vendor delivering the bag to the passenger on the airline’s behalf.  However, carriers do not need to report a mishandled bag if the mishandling occurs in the custody of a third-party that is not performing services on behalf of the carrier, such as when the passenger authorizes the agent of a cruise line to pick up a bag on his or her behalf.  Again, for the purposes of reporting under this directive, the Department considers security screening, such as that performed by the TSA or contracted security screeners, to be a service that is not independent of the carrier’s normal process in handling baggage and, therefore, not an excludable third-party. 

How do the requirements addressed in this directive relate to electronic passenger notifications such as through mobile devices applications?

The Department is aware that some airlines are implementing baggage tracking systems that alert passengers when their bags will arrive late.  These new systems benefit passengers by providing them prompt and up-to-date information about the status of their bags and by connecting them with their bags without needing to visit the baggage claim areas or the baggage service offices.  When using these technologies, passengers are often advised to click on a link provided in the late bag notification to either wait for the bag or set up free delivery.  By filling in the required information for baggage delivery, passengers are acknowledging the receipt of the notification that their bags are delayed and, in the Department’s view, that acknowledgement constitutes reporting a mishandled bag with the airline.  Similarly, by choosing to wait for a bag and completing a delayed bag report, passengers are reporting a mishandled bag with the airline.  The use of new baggage tracking technologies to alert travelers when checked baggage arrives late does not relieve a carrier of its obligation to report those bags as mishandled.

  1. ASQP – Mishandled Baggage and Wheelchairs and Scooters Report Certification

A certification statement identifying an appropriate official of the reporting carrier is required for each Mishandled Baggage and Wheelchairs and Scooters Report.  In addition to filing Baggage Data File Form 1, reporting carriers that market reportable codeshare flights must file a separate Mishandled Baggage and Wheelchairs and Scooters Report using Baggage Data File Form 2 for domestic flights marketed under only one U.S. carrier’s (the reporting carrier’s) designator code and operated by its codeshare partners to or from a reportable airport.  The certification statement will read:

I, (Name) and (Title), of the above-named carrier, certify that the Mishandled Baggage and Wheelchairs and Scooters Report file is to the best of my knowledge and belief, true, correct and a complete report for the period stated.

Month and Year of Data:

Number of Mishandled Bags:

Number of Bags Enplaned:

Number of Mishandled Wheelchair and Scooters:

Number of Wheelchair and Scooters Enplaned:

Date:

Name (Please Print or Type):

Signature:

Once signed, the Mishandled Baggage and Wheelchairs and Scooters Report Certification must be published as an electronic “portable document format” (PDF) document, and uploaded to the eSubmit application.

The PDF file format MUST BE indicated when naming the file, by using the letters [PDF] or [pdf] following the file name, as the file name extension. You must have Adobe Reader software downloaded on your computer in order to “save as/print” your document as a ‘pdf’ file.

While the file name is flexible and may be determined by the individual air carrier, the pdf file format is required.

Suggested file name for Form 1 Report Certification: XX201003-234mbrCert.pdf

The file name for reports of codeshare flights filed by a marketing carrier must contain the word “codeshare” to indicate the nature of the file.

Suggested file name for Form 2 Report Certification (Codeshare): XX201003-234mbrCert-Codeshare.pdf

Section IV. Submission of Reports

(a) Due Dates. The due date for the Mishandled Baggage and Wheelchair and Scooter Report is 15 days after the applicable reporting month; i.e., data for the month of March is due by April 15. If the 15th day falls on a weekend or federal holiday, the due date will be the next business day.

(b)  Enforcement. Penalties for late filing or noncompliance with these reporting requirements will be assessed in accordance with 49 U.S.C. 46301.

(c)  Missing or Incomplete Records. Any carrier subject to this directive, which does not file the required data for any period, or files incomplete data, will submit a sworn statement of a company officer that the carrier was unable to provide the data because it did not have and could not obtain the necessary records. That statement, as well as the veracity of the information and the data submitted, will be subject to 18 U.S.C. 1001, regarding criminal penalties for false statements made to a government agency. The statement shall be filed with the Director of OAI at the address below, three days prior to the due date.

William Chadwick, Jr.

Director, Office of Airline Information

Bureau of Transportation Statistics RTS-42, E36-304

U.S. Department of Transportation

1200 New Jersey Avenue SE

Washington, DC  20590

202 366-4405

Ontime.support@dot.gov

(d)   Special Circumstances. Requests for waivers, exceptions, extensions, or other considerations shall be submitted in writing to the Bureau of Transportation Statistics at the address in subsection (c) above.

Section V. Records Retention

The Mishandled Baggage and Wheelchair and Scooter Report is a statistical report.  The record retention requirements for statistical reports are governed by 14 CFR Part 249, "Preservation of Air Carrier Records" of the Department’s Regulations. Specifically, 14 CFR 249.20-6 requires the information supporting a statistical report to be maintained by the carrier for three years.

Questions regarding this technical directive should be addressed to ontime.support@dot.gov

W.A. Chadwick, Jr.

Director, Office of Airline Information

Bureau of Transportation Statistics

U.S. Department of Transportation

 

[1] On October 5, 2018, the President signed into law the FAA Reauthorization Act of 2018 (FAA Act), Pub. L. No. 115-254.  Section 441 of the FAA Act provides that the compliance date for the November 2, 2016, final rule shall be effective not later than 60 days after enactment of the Act, which is December 4, 2018.  Accordingly, airlines determined by OAI as accounting for at least 1 percent of domestic scheduled passenger revenues for calendar year 2018 should be submitting mishandled baggage data to the Department using the new mishandled baggage reporting methodology and separately reporting statistics for mishandled wheelchairs and scooters for domestic scheduled flights they operate between December 4 and December 31, 2018. The Office of Aviation Enforcement and Proceedings has published guidance on how airlines should report this data to the Department.  See 83 FR 53991 (October 26, 2018).  Additional guidance for reporting pursuant to the FAA Act is included on pages 4-5 of the Enforcement Policy Regarding Reporting of Mishandled Baggage Data issued by the Department’s Office of Aviation Enforcement and Proceedings concurrent with this directive.

[2]  See 234.6(b) (This definition is consistent with the carriers’ obligation to report domestic flights to or from any U.S. large, medium, small, or non-hub airport as defined in 49 U.S.C. 47102.).

[3] 14 CFR 234.2.

[4] Reporting of Data for Mishandled Baggage and Wheelchairs and Scooters Transported in Aircraft Cargo Compartments, 81 Fed. Reg. 76300, 76301 (November 2, 2016).

[5] See 14 CFR 234.2.

[6] Reporting of Data for Mishandled Baggage and Wheelchairs and Scooters Transported in Aircraft Cargo Compartments, 81 Fed. Reg. at 76301.

[7] Since valet bags are returned to the passenger by the carrier that accepted the bag, carriers following option (1)(B) must report the actual mishandling of a valet bag. 

[8] This methodology is consistent with principles of International Air Transport Association’s (IATA) Resolution 780, which is a mandatory practice for all IATA member airlines and is applicable to interline arrangements. See: http://www.iata.org/whatwedo/ops-infra/baggage/Pages/standards.aspx. Under IATA resolution 780, the carrier that operates the last flight segment generally accepts a mishandled baggage claim as reported by the passenger.  DOT defines a mishandled bag as a checked bag that is lost, delayed, damaged, or pilfered, as reported to a carrier by or on behalf of a passenger.  14 CFR 234.2. 

[9] If the last segment was operated by a non-reporting carrier, that carrier would not be required to submit a mishandled baggage report to the Department.  However, if the last flight segment is marketed under only one U.S. carrier’s code and that U.S. carrier is a reporting carrier, then that reporting carrier must include the mishandled bag data in Baggage Data Form 2 (codeshare).  See 14 CFR 234.6 (b).

[10] Reporting mishandled baggage data for domestic segments of international itineraries based on the carrier that operated the last flight segment is not an appropriate means of compliance with the rule.  Unlike for an itinerary of only domestic segments, if a carrier uses this approach for domestic segments of international flights, the carrier would, at times, be reporting mishandled bags that occurred on non-reportable segments that are outside the scope of the rule.

[11] Valet bags belonging to passengers who are traveling on domestic segments of international itinerates must be included in the total number of bags enplaned and, if mishandled, in the total number of mishandled bags.  Passengers drop off and pick up these bags at the end of the loading bridge or on the tarmac near the aircraft for a domestic flight, so it is clear if the bags were mishandled in the United States.

[12] Notwithstanding the effective date of this directive, reporting carriers must first provide this notification no later than December 1, 2018.

[13] For example, if a reporting carrier has an interline agreement with carriers 1 through 8 and only carriers 1 through 5 agree to use the method descried in (1)(B) of this subsection, the reporting carrier can use the method described in (1)(B) to report mishandled baggage data for itineraries involving only carriers 1 through 5 and (1)(A) for itineraries involving any of the carriers 6 through 8.    

[14] Reporting of Data for Mishandled Baggage and Wheelchairs and Scooters Transported in Aircraft Cargo Compartments, 81 Fed. Reg. at 76302.