Mishandled Baggage

Part 234 – ASQP
Mishandled Baggage, Wheelchairs, Scooters Data
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.
Required Sample Data File Record Format (Form 1):
ZZ,2010,03,2023,35000,918,2485
Required 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.
Required file name format 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.
Required file name format for Data File (Form 2): XX201003-234mbr-codeshare.csv

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OMB NO: 2138-0041
EXPIRATION DATE: 12/31/2021
Paperwork Reduction Act Burden Statement
A federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be
subject to a penalty for failure to comply with a collection of information subject to the requirements of the
Paperwork Reduction Act unless that collection of information displays a current valid OMB Control Number. The
OMB Control Number for this information collection is 2138-0041. Public reporting for on-time performance,
mishandled baggage, is estimated to be approximately 10 hours per response each, including the time for
reviewing instructions, completing and reviewing the collection of information. All responses to this
collection of information are mandatory, as authorized by 14 CFR, Part 234. Send comments regarding this burden
estimate or any other aspect of this collection of information, including suggestions for reducing this burden
to: Information Collection Clearance Officer, OAI/BTS/OST-R, RTS-42, 1200 New Jersey Avenue, SE, Washington,
D.C. 20590

Baggage Data File Form 1
Data Type

Length

Comments

Sample Data

Operating Carrier code
Year of Data

Character
Numeric

2
4

Two letter IATA code
Year (CCYY)

Month of Data
Number of Mishandled Bags
Number of Bags Enplaned
Number of Mishandled Wheelchairs
and Scooters
Number of Wheelchairs and Scooters
Enplaned

Numeric
Numeric
Numeric
Numeric

2
Varies
Varies
Varies

Month (MM)

ZZ
2010
03
2023
35000

Numeric

Varies

Field Description

918
2485

Baggage Data File Form 2 (Codeshare)
Data Type

Length

Comments

Sample Data

Marketing Carrier code
Year of Data

Character
Numeric

2
4

Two letter IATA code
Year (CCYY)

Month of Data
Number of Mishandled Bags
Number of Bags Enplaned
Number of Mishandled Wheelchairs
and Scooters
Number of Wheelchairs and Scooters
Enplaned

Numeric
Numeric
Numeric
Numeric

2
Varies
Varies
Varies

Month (MM)

XX
2010
03
2023
35000

Numeric

Varies

Field Description

918
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 gatechecked 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
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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 bags1, 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,2 if that carrier is a
reporting carrier, and that carrier accurately reports in this manner to the Department.3
(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 case4;
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.5
1 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.
2 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.
3 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).
4 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.
5 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.

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No later than December 1 of each year, reporting carriers must identify and submit in
writing to “[email protected]” 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.6 Additionally, if a reporting carrier enters into a new domestic interline
agreement during the calendar year, the carrier must notify OAI in writing of this event and of the
reporting methods the reporting carrier will use with its new domestic partner for the remainder
of that calendar year. 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).7 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 gatechecked 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.8
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.
6 Notwithstanding the effective date of this directive, reporting carriers must first provide this notification no later
than December 1, 2018.
7 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.
8 Reporting of Data for Mishandled Baggage and Wheelchairs and Scooters Transported in Aircraft Cargo
Compartments, 81 Fed. Reg. at 76302.

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(a)

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.
(2) 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.
(3) 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.
(4) 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
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a subsequent domestic flight segment on that itinerary, but the passenger failed to pick up the
bag.
(5) After a bag is reported pilfered, information is presented by the passenger, or his
or her representative, that the missing items were found.
(6) When the airline has conclusive evidence that a report was filed as a result of
fraud.
(7) When conclusive evidence shows that the mishandling reported did not occur in
the reporting carrier or its code-share partner’s custody. This exception will apply to carriers that
choose to report purely domestic itineraries with multiple operating carriers under reporting
method 1(B) only when conclusive evidence shows that none of the carriers involved in the
itinerary had custody of the bag.
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,
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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.
(b)

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:

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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.
Required file name format for Form 1 Report Certification: XX201003234mbrCert.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.
Required file name format for Form 2 Report Certification (Codeshare): XX201003234mbrCert-Codeshare.pdf

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