TRANSPORTATION OF DANGEROUS GOODS BY AIR LEARNING FROM THE MISFORTUNES OF OTHERS OBJECTIVES • To give a brief overview of the requirements for the transport of dangerous goods by air • To identify deficiencies in the supply chain that could lead to serious accidents/incidents • To demonstrate the challenges facing industry in ensuring compliance with the regulations DEFINITION OF DANGEROUS GOODS Dangerous Goods are articles or substances which are capable of posing a risk to health, safety, property or the environment, and which are shown in the list of Dangerous Goods in the Dangerous Goods Regulations or which are classified according to these Regulations. ENABLING LEGISLATION FOR THE SAFE TRANSPORT BY AIR OF DANGEROUS GOODS • Annex 18 to the Convention • Aviation Act No. 74 of 1962 • ICAO Technical Instructions • ICAO Technical Instruction Supplement • Civil Aviation Regulations of 1997; Part 92 • SA-CATS-DG • ICAO Emergency Response Guidance for aircraft incidents involving dangerous goods • Part 141 Dangerous Goods Training • IATA Dangerous Goods Regulations – used by industry (mostly IATA Members) – contains all the requirements in the ICAO Technical Standards USE OF THE ICAO TECHNICAL INSTRUCTIONS and IATA DGR Manual • Classify & identify proper shipping name • Check if permitted on passenger/cargo aircraft or if forbidden • If forbidden, check if subject to exemption • Check quantity and packaging • Prepare consignment – mark/label/document • Sign Transport Document and offer for transport • State Variation Requirements • Operator Variations LIMITATIONS OF DANGEROUS GOODS ON AIRCRAFT • Forbidden for air transport under any circumstances - certain explosives - substances liable to produce dangerous evolution of heat • Forbidden for transport unless exempted by various States • Acceptable for transport on both Passenger and Cargo Aircraft • Forbidden for transport on a Passenger Aircraft, but acceptable on Cargo Aircraft only LEARNING FROM THE MISFORTUNES OF OTHERS PROBABLE CAUSE • Valujet 592; Chemical Oxygen Generators • Pan American B-707; Onboard nitric acid fire • American Airlines DC-10; Chemical Oxygen Generators • Fed-Ex DC-10; Flammable Liquids in Lab Machine • Continental Airlines B-727; Safety Matches • DC-8 Freighter in Dallas; Carbon Dioxide fumes • American Airlines DC-9; Hydrogen Peroxide CONTRIBUTING FACTORS • Lack of training • Negligence • Reluctance to declare correct contents - Shippers • Undeclared dangerous goods • Mis-declared dangerous goods • Lack of communication • Incorrect packaging UNDECLARED/HIDDEN DANGEROUS GOODS A MAJOR RISK TO THE SAFETY OF CIVIL AVIATION • Risk to the safety of passengers & crew • Risk of explosion • Risk of smoke or fire • Risk of incapacitation of crew – toxic inhalation • Exposure to Ionizing Radiation • Exposure to contaminated substances/liquids • Risk to aircraft radiation contamination • Incompatible dangerous goods - a ticking time bomb UNDECLARED DANGEROUS GOODS ORIGINAL CONSIGNMENT OF ACIDS UNDECLARED SULPHURIC AND HYDROCHLORIC ACID CORROSION CAUSED BY ACID TO PALLET BASE UNDECLARED FLAMMABLE PAINT UNDECLARED FLAMMABLE PAINT UNDECLARED COMPRESSED GAS UNDECLARED SPILLABLE BATTERY UNDECLARED FLAMMABLES/AEROSOLS How Could They Have Been Prevented • Correct content declaration • Correct classification • Adequately trained personnel • Educated clients • Documented and packed as dangerous goods • UN Specification packaging • Concerted effort by all to ensure an overall level of safety (Don’t buck the system) SUPPLY CHAIN (AS STRONG AS ITS WEAKEST LINK) Road Consolidator Rail Sea Freight Forwarder/ Agent Shipper/ Courier Org. PACKER C A R G O T E R M I N A L CARRIER SUPPLY CHAIN - GENERAL CONSIDERATION • Communication - Instructions from shipper clear • Compliance with relevant regulations • Supply chain commercially driven – No shortcuts • Packing - 99% of undeclared dangerous goods not packed in accordance with the regulations • Honesty/trust - Reluctance of Shippers to declare contents • Safety/security consciousness – do not compromise safety • Know what you are shipping • Liability issues in Supply Chain • Dangerous goods packing organisations can assist SHIPPER’S RESPONSIBILITY GENERAL REQUIREMENTS • Dangerous Goods not to be transported under any circumstances • Identified/classified • Packed – essential component/Valid Package Performance Test Certificate – expiry date of packaging • UN Specified Packaging • Marked • Labelled • Accompanied by a properly executed transport document (Shippers Declaration) • Transport document to be signed by trained personnel OPERATOR’S RESPONSIBILITY • Acceptance Procedures • Storage and loading • Inspection • Retention of records • Training • Provision of information, Including emergency response information DANGEROUS GOODS TRAINING • Requirement of regulations – ICAO/CARS and IATA DGR • Job Specific • Different categories of training oShippers personnel involved in the preparation of a dangerous goods shipment and contractors oAir Operators personnel/aircrew/cabin crew/acceptance personnel/warehouse/drivers oRamp personnel/security screening personnel oFreight Forwarders/processing dangerous goods • Training by a CAA accredited organisation ENFORCEMENT BY THE APPROPRIATE AUTHORITY (SACAA) • CAR 185 & Section 19 of the Aviation Act of 1962 • Criminal charges - on conviction; fine or imprisonment or to both fine & imprisonment • First Time Offender – if not serious - warning • Injury to persons or damage to property; SAPS will consider findings before moving for possible prosecution • Safety/security is a co-operative venture ROLE OF SHIPPERS IN TRANSPORTING DANGEROUS GOODS BY AIR • Transported in accordance with Regulations • Overall level of safety maintained at all times • Security of dangerous goods • Personnel current in dangerous goods training • Ongoing training • Educate clients &personnel about dangerous goods • If a chemical is forbidden for transportation by Air check with CAA if Exemption is applicable TODAY’S CHALLENGES • Multi-modal transport – stake holders acting in silos? • Vision for the future – key role players • Fragmented regulations • Proper management • Identification of critical issues • International requirements • Complexities in compliance • Harmonisation – A distant dream?