Accidents, incidents and emergencies involving Dangerous Goods
1. Notification of Dangerous Goods following an aircraft accident or incident
1.1 If a catastrophic accident or serious incident happens to an aircraft it will be essential for information about any dangerous goods on board to be passed quickly to the State where the accident or serious incident occurred. This will be needed to ensure the safety of persons involved in dealing with the accident or serious incident and to minimize the hazard to persons, property and the environment. The responsibility is on the Operator or handling agent to give the information without waiting to be asked. The notification may come from the Operator or handling agent, from a Territory base or from an operating base outside the Territory, providing the information is supplied immediately and is accurate. A point of contact should also be given when notifying so that, if further information is required, it can be obtained without delay.
1.2 In the first instance the information is to be given directly to the emergency services or to whoever is collating information for their use. As soon as possible the information is also to be given to the aviation authority of the State where the accident or serious incident occurred, or as directed by that State, as well as to the State of the Operator and to the OTAA if it is neither. The information required is that which is on the NOTOC for the relevant flight (see Chapter 3 paragraph 9). However, it should be realised this may mean that some dangerous goods in cargo would not be notified since they do not appear on a NOTOC (e.g. excepted radioactive materials). Sending the NOTOC details is not to be delayed whilst checks are made for the presence of excepted radioactive material; details of these should be sent as soon as possible. If there are copies available of the Dangerous Goods Transport Documents, these may be useful at a second stage, when it may be necessary to identify more precisely what is in a particular package. Since it is important to ensure that any dangerous goods on an aircraft involved in an accident or serious incident are notified without delay, there should be procedures in place and reference made to them in the contingency plan for responding to accidents and serious incidents.
1.3 If there is an aircraft incident, information only needs to be provided if it is requested; but depending on the seriousness of the incident and what is being carried, giving the information without waiting to be asked may assist in the early stages of dealing with it. Any information needs to be given as soon as possible; initially, it is given to the emergency services or to whoever is seeking it on their behalf and, subsequently, to the aviation authority of the State where the incident occurred, or as directed by that State.
2. Dangerous Goods emergencies
2.1 An emergency situation concerning dangerous goods could arise at any time whilst they are in air transport. Such emergencies can range from the discovery of leaking or damaged packages during their preparation for transport, to a major incident (e.g. a fire) on an aircraft. Also, passengers may deliberately or inadvertently take into the cabin dangerous goods which they are not entitled to have. The ability to respond correctly and efficiently to an incident involving dangerous goods should not rely on an instinctive reaction to a situation, but on having established procedures and training.
2.2 An emergency involving dangerous goods can occur not only to declared dangerous goods; it might also arise on the ground with undeclared dangerous goods and on an aircraft through the actions of a passenger. Therefore, some of the information in both this Chapter and Chapter 8 is appropriate irrespective of whether or not the Operator holds an approval to carry dangerous goods.
3. Information requirements
3.1 An Operator must provide information in manuals on the actions to be taken in emergencies; this information is applicable to all staff, whether they are crew members or ground staff. Instructions need to be given on the actions to be taken in dealing with an incident occurring in an aircraft in flight and on the ground.
3.2 Information must be immediately available to the Pilot in Command (PIC) for use in the response to an emergency occurring in flight when dangerous goods are being carried as cargo. As a minimum, this information should give guidance on the hazards associated with the dangerous goods on the aircraft. In practice the requirement is often met by having on board a copy of the Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (Doc 9481-AN/928), published by ICAO. However, it can be met by providing any other document which gives similar information concerning the dangerous goods on board. Detailed guidance may be found in Chapter 8 of this OTAC.
3.3 If an in-flight emergency occurs and the situation permits, the PIC is required to inform the appropriate air traffic services unit of any dangerous goods on board an aircraft. Whenever possible this information should include:
(a) the proper shipping name and/or UN/ID number;
(b) the class/division, any identified subsidiary risk(s) and, for explosives, the Compatibility Group;
(c) the quantity and location.
3.4 This information is for the use of the airport authorities, primarily to warn the emergency services what to expect when they approach the aircraft after it has landed; in this respect the PIC has a duty of care not only to the passengers and other crew on board but also to those on the ground. The emergency information should, wherever practicable, include sufficient details to identify fully the dangerous goods and where they are located. If the situation does not allow for full details to be given, the PIC should decide what it would be appropriate to give in the circumstances; for instance, if a telephone number has been provided as a point of contact from where the information on the NOTOC can be obtained, this may be given in lieu of any details or, if a summary of all the dangerous goods on the aircraft has been provided, the nature of the hazard(s) on board might be conveyed adequately by giving the class, quantity and location, rather than individual UN/ID numbers.
4.1 It is not only the crew on an aircraft who may become involved in dealing with an incident, ground staff might also do so in the course of handling dangerous goods during their preparation for transport or through coming into contact with them inadvertently. Training for all these persons should include guidance on what to do if there is an incident involving dangerous goods.
4.2 The persons who should receive training are:
(a) those engaged in the acceptance of dangerous goods;
(b) those engaged in the acceptance of general cargo and the ground handling, storage and loading of cargo and baggage;
(c) flight crew and other crew members;
(d) passenger handling staff and security staff employed by the Operator.
The operator may also decide that there are additional members of staff who may benefit from dangerous goods training.
4.3 The benefits of providing training for persons employed on cargo related and flight crew duties is clear. However, experience has shown that, as passengers cause many incidents, training is also required for persons handling passengers and their baggage (including cabin crew). The aim of training for flight and cabin crew is to ensure a correct and adequate response to any incidents occurring in the cabin during flight. Emergency procedures training for the persons identified above is appropriate even if dangerous goods are not carried as cargo.
4.4 Training should be relevant to the responsibilities of the person concerned. The essential element for everyone is what action should be taken in an emergency. Such training should include:
(a) for ground staff:
i) dealing with damaged or leaking packages;
ii) other actions in the event of ground emergencies.
(b) for flight crew:
i) action in the event of emergencies in flight, both in the cabin and in cargo compartments;
ii) notification to air traffic control.
(c) for other crew members, such as loadmasters, dealing with damaged or leaking packages in flight.
(d) for cabin crew, dealing with incidents caused by dangerous goods in the possession of passengers.
4.5 Training for emergencies should be to a depth sufficient to ensure that the hazards associated with dangerous goods are appreciated and that the Operator's procedures for dealing with emergencies can be applied.
5. Procedures for dealing with emergencies
5.1 It is a requirement that manuals contain information on actions in the event of emergencies. This should cover emergencies occurring on the ground as well as in flight. To ensure there is an accurate and efficient response to an incident, it is necessary for an Operator to have established procedures for dealing with emergencies and these should be incorporated into manuals, written instructions etc.
5.2 Most incidents which involve damaged or leaking packages of dangerous goods are discovered on the ground. The established procedures should ensure that all ground staff are aware of what is expected of them in the event of an incident; these procedures should aim to implement a system which will:
(a) identify the dangerous goods involved;
(b) identify, from labels or documents, the hazards (e.g. toxicity, flammability) associated with the dangerous goods;
(c) assess the potential level of hazard to persons;
(d) seek to contain the situation e.g. prevent spread of contamination;
(e) seek assistance, if ncessary;
(f) ensure the safe removal or disposal of the dangerous goods, if necessary.
5.3 In the absence of evidence to the contrary (or a suspicion that the truth is being withheld) it should be assumed that information on documents, packages etc., is accurate. There may be a greater risk in regarding the goods as unidentified than in accepting the described nature and level of hazard.
5.4 Procedures should be tested periodically and updated if found inadequate or inaccurate. In order for staff to be able to deal effectively with a ground incident, they should be trained in the procedures. Personal protective equipment should be available, such as gloves, goggles and face masks and, depending on the type and quantity of dangerous goods likely to be encountered, overalls and portable breathing equipment. Training should be given in the use and limitations of the equipment and it must be maintained in a fully functional state.
5.5 Incidents in flight may occur through dangerous goods either in cargo or carried by passengers. On a cargo aircraft, the dangerous goods may be either in inaccessible cargo compartments or on the main deck. There should be established procedures for dealing with incidents occurring in flight and these should cover all circumstances.
5.6 Guidance material for dealing with incidents involving dangerous goods which occur in flight has been produced by the International Civil Aviation Organization; it is contained in Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (Doc 9481-AN/928). See Chapter 8 of this OTAC.
6. Other considerations
6.1 There may be legal or other requirements, which are not the responsibility of the OTAA, which pertain to the action to be taken in emergencies when dangerous goods are in air transport. Some airport authorities have requirements for the action to be taken if dangerous goods are found leaking or damaged in transit sheds, warehouses or other premises.
6.2 For some types of radioactive materials carried under exclusive use, legislation requires the shipper to produce a contingency plan to cater for an unexpected situation. This is intended to ensure the continued safety of the consignment at all times. When such radioactive material is in air transport, the shipper will require the Operator to have instructions on what should be done if an in-flight emergency occurs or the aircraft diverts for some other reason.
7. Reporting of Dangerous Goods accidents and incidents
7.1 The Technical Instructions contain definitions of dangerous goods accident and dangerous goods incident. OTAR Part 13 makes no distinction between dangerous goods accident and incidents and any other type. Therefore, any such incidents or accidents should be reported in accordance with the requirements and timescales of OTAR Part 13.
7.2 Given the nature of dangerous goods, incidents may arise at any time, particularly if the applicable requirements have not been met. The major problem encountered by Operators is dangerous goods which are undeclared or misdeclared; these are sometimes found only when leakage, spillage or fire occurs. Therefore, there is the potential for a major incident or accident to happen. It is the experience of the regulatory authorities to date that incidents occur frequently (although many are not of any significance) and they usually result from non-compliance with all the applicable requirements.
7.3 Dangerous goods accidents and incidents must be reported to the OTAA; initial reports must be made within 72 hours of the accident or incident unless exceptional circumstances prevent this. Every type of dangerous goods accident or incident which meets the criteria or which involves undeclared or misdeclared dangerous goods should be reported, no matter whether such goods are contained in cargo, mail, passengers' baggage or crew baggage. An initial report may be made by any means but a written report should be made as soon as possible. The report should be comprehensive and contain all data known at the time it is compiled; if all relevant information is not available at first, the initial report should be sent stating what is known and a follow-up report sent when the full details are available. There is a legal requirement for an Operator to report dangerous goods accidents and incidents but, in practice, there is nothing to prevent a handling agent from reporting on behalf of the Operator, since it is important to ensure occurrences are reported as quickly as possible. An Operator is expected to have in place arrangements both internally and with handling agents to ensure reports of dangerous goods accidents and incidents are processed with the minimum of delay.
7.4 Reports made to the OTAA should include copies of relevant documents and any photographs taken should be attached. The report may be sent by any means, including e-mail; any hard copy documents, photographs, etc that cannot be e-mailed should be sent to the OTAA by fax or post.
7.5 If the dangerous goods accident or incident involves loss of or damage to packages of radioactive materials whilst in transport the Governor also needs to be informed.