Emergency response guidance
An emergency situation can arise at any time on an aircraft. There may be some circumstances when the emergency has been caused by dangerous goods being carried or they may become involved in it e.g. a fire in a cargo compartment may not have been caused by dangerous goods but they may be damaged by it, which could exacerbate the problem. The guidance in this Chapter is aimed at dealing with emergency situations on an aircraft in flight involving dangerous goods. It explains the purpose and use of the ICAO Emergency Response Guidance document; in addition it suggests what actions might be considered in response to an incident on an aircraft, what should be taken into account in making a decision on what to do, and what might be appropriate to make available to flight crew to aid them in any decisions to be taken concerning an incident on an aircraft.
2. Emergency response guidance for aircraft incidents involving dangerous goods
2.1 ICAO has produced a document entitled Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (reference Doc 9481-AN/928); it is referred to throughout this Chapter and in Appendix 2 as the Emergency Response Guidance document. It gives guidance for developing procedures for dealing with incidents on aircraft in flight. It is not suitable material for developing procedures for dealing with ground incidents.
2.2 The Emergency Response Guidance document contains:
(a) general information e.g. cargo compartment locations and classifications, what fire extinguishers can be found on aircraft and what might be included in an emergency response kit;
(b) general considerations e.g. where dangerous goods may be found and the peculiarities pertaining to each location which might be relevant in an incident;
(c) examples of checklists for incidents in the cabin or cargo compartments;
(d) lists of emergency response drills with drill reference numbers, identifying the dangerous goods both alphabetically and numerically.
2.3 Many operators who carry dangerous goods have decided to implement the requirement to provide emergency information to the PIC by placing a copy of the Emergency Response Guidance document in the aircraft library. Even if an operator does not knowingly carry dangerous goods, an incident may well arise through dangerous goods carried by passengers. There is guidance material in the Emergency Response Guidance document which should form the basis of actions in emergencies no matter whether they arise in cargo compartments or the passenger cabin. This material should always be considered when formulating actions for emergencies since it gives information for use at the time of an incident. It should also form the basis of training.
2.4 The limitations of the Emergency Response Guidance document should be realised; it was produced to aid decisions in flight and recognises that little equipment may be available other than standard fire extinguishers and items carried for the safety or comfort of passengers or to assist in providing cabin services. Also, it is not mandatory to use the document to try to deal with an incident e.g. the PIC may decide that it would be preferable to make the main focus of attention the need to land rather than dealing with a spillage etc.
3. Unpressurised aircraft
The wording of the Emergency Response Guidance document makes it apparent it was produced with pressurised aircraft in mind. Whilst some of the detailed material may not be appropriate for unpressurised aircraft, including helicopters, the basic principles and general considerations are relevant to all aircraft.
4. General considerations
Section 2 of the Emergency Response Guidance document contains general considerations to be taken into account when assessing the appropriate action to be taken to deal with an incident involving dangerous goods. The following paragraphs amplify some of these general considerations and suggest others.
4.1 Safety of the Aircraft and Persons on Board
4.1.1 The primary consideration in any incident should be to preserve the ability of the crew to fly the aircraft. The other considerations are:
(a) to safeguard all other persons on board from the effects of any fumes or liquid from leaking packages of dangerous goods;
(b) to protect the aircraft structure as far as possible from damage; and
(c) to control the potential for the dangerous goods to cause any further harmful effect.
4.1.2 On a passenger aircraft, if it is suspected there is a problem in the cargo compartment, the normal drills for dealing with fires in cargo compartments should be carried out. If the problem is in the cabin it is essential to ensure leaking or fuming items are removed from the cabin area and placed where they cannot affect anyone. A possible place is a toilet, where the positive pressure should ensure fumes are vented overboard, but if the item is suspected of being flammable, consideration should be given as to which toilet is used so that any smoking sections are not crossed in order to reach it. On aircraft where the air is normally recirculated it may be necessary to ensure the air is vented overboard.
4.2 Dangerous Goods in Inaccessible Cargo Compartments
If the normal fire or smoke warnings are activated for an inaccessible cargo compartment, it should be ascertained if there are dangerous goods stowed in it, by using the NOTOC. They may not have caused the fire/smoke but they may become involved. The normal drills for fire/smoke in cargo compartments should be carried out, but it should be realised that if oxidisers or organic peroxides are in the compartment, they may contribute oxygen to a fire and cause it to continue burning even after the cargo compartment fire extinguishers have been activated.
Passengers may deliberately or inadvertently bring dangerous goods which they should not have into the cabin; they are often unaware that the environment on the aircraft is likely to be different to that at ground level. The first indication of a potential incident could be a passenger becoming concerned about an item in their cabin baggage which is leaking or giving off fumes (this can happen because of the reduced pressure); or a passenger seen using an item which is not permitted in the cabin.
Also, there have been incidents caused by items which passengers can legitimately take on aircraft but which developed faults during flight. If it appears that the item is not likely to cause a problem, it might be better for the passenger to be allowed to keep it; although a watch should be kept for any sign of leakage or fuming. If it seems likely that the item might cause a problem or is leaking or fuming, it should be dealt with as suggested in paragraphs 4.1 and 8.
4.4 Identifying Dangerous Goods
4.4.1 It is difficult to deal effectively with spillages or leakages of dangerous goods until their identity has been established but it is not always easy to do this. If the item is being carried by a passenger, they should be asked if they can identify it or give any information on the hazard from it. Given modern requirements for consumer protection, often items or their packagings carry warnings; if it is not in a language understood, ask if the passenger can translate.
4.4.2 On a cargo aircraft, identifying the dangerous goods can only be done if they are on the main deck and accessible, which does not apply to all "cargo aircraft only" items.
4.4.3 Packages of declared dangerous goods have on them their proper shipping name and UN/ID number; and the lists of dangerous goods and associated drills in the Emergency Response Guidance document are both alphabetical and numerical. Experience has shown that it is often undeclared dangerous goods which could cause an incident. If there is a chemical name on the outside of a package, it may appear in the alphabetical list in the Emergency Response Guidance document. Similarly, if a four-figure number is shown on the package without UN or ID prefixing it, it may still be such a number and appear in the numerical list.
4.4.4 Consignments of dangerous goods in air transport are accompanied increasingly by documents, such as the Material Safety Data Sheet (MSDS/SDS), giving first aid and other emergency information; an MSDS may be attached to the copy of the Dangerous Goods Transport Document which is on the aircraft. Similar information may also appear on labels on the outside of packages.
4.4.5 In the absence of evidence to the contrary or a suspicion that the truth is being withheld, it should be assumed information shown on packages, documents etc. is accurate. There may be a greater risk in regarding the goods as unidentified than in accepting a described nature and level of hazard.
4.5 Landing as soon as possible
Unless it is obvious that an incident has been dealt with successfully, the decision should be taken to land as soon as possible. It should not be hoped the problem can be contained or will go away, it may suddenly develop into a situation which becomes difficult to deal with whilst in flight.
4.6 Notifying the Pilot in Command of a Problem
If the cabin crew are involved in an incident the Pilot in Command should be told as soon as possible about what has occurred, and be given as many details as are known. If the incident develops, the greater the warning and the more details the PIC has, the better may be the preparation to deal with the consequences.
4.7 Information by the Pilot in Command
If the PIC decides to land, air traffic control must be advised of the reason for doing so and given sufficient information, including details of the dangerous goods as shown on any NOTOC, to enable them to alert the airport authority. This is so the emergency services can be warned of any unexpected hazard and be prepared to deal with the aircraft when it lands. These details should be passed on even if the incident did not involve the dangerous goods, since the emergency services may need to be aware of what is on the aircraft in order to make decisions as to the appropriate action to take.
5. Using the Emergency Response Guidance Document
5.1 Flight crew should not be expected to use the Emergency Response Guidance document for dealing with an incident until training has been given. It contains information that is not only of use in an emergency but also intended for training and the development of procedures and incident checklists.
5.2 A dangerous goods incident can only be dealt with as such when the goods are accessible i.e. it occurs in the passenger cabin or an accessible cargo compartment on a passenger aircraft or the main deck of a cargo aircraft. The method of dealing with the incident may be different depending on the location and the Emergency Response Guidance document gives specific guidance on dealing with incidents in all these situations, plus dealing with an incident in an inaccessible cargo compartment.
5.3 The lists in the Emergency Response Guidance document have been designed for incidents occurring with dangerous goods that are accessible, since the correct identification of the goods causing the problem is essential to the correct use of the drills.
5.4 Whilst it may appear so, the number in the Drill Code is not always related to the Class/Division of the dangerous goods. Moreover, it may not give actual actions which can be taken but rather present a number of possible consequences and considerations.
5.5 In deciding what action to take in relation to a suggested Drill Code, the following may also be relevant:
(a) a fire should be dealt with using any available equipment, but water should only be used when it can be positively established that it will not exacerbate the fire (see paragraph 6);
(b) if there are fumes, an attempt should be made to prevent further spillage or leakage and to reduce the spread of fumes by covering with polyethylene plastic based material;
(c) if the hazard may result in an explosion, the aircraft should descend to an altitude where the pressure can be reduced to a minimum value commensurate with safe operation;
(d) if the hazard is associated with radioactive materials, toxic or infectious substances, no attempt should be made to approach them and any passengers thought to be in danger should be moved;
(e) spillages of both powders and liquids should be contained to prevent spreading by surrounding with non-reactive material, such as polyethylene waste bin bags, duty-free sales bags;
(f) powders may be better left in situ if they do not appear to be causing progressive damage or discomfort to crew or passengers (to check for damage there should be the minimum disturbance of the spillage but the edge should be moved to see what is happening underneath);
(g) extreme caution should be used with liquids; they may be better left in situ, if they do not appear to be causing progressive damage or discomfort to passengers, and covered with polyethylene based material;
(h) for a limited period polyethylene (plastic) should not react with any dangerous goods.
5.6 Operators may provide information to the PIC by extracting the relevant parts from the Emergency Response Guidance document; this could be done by adding the Drill Code to the entry in the NOTOC and providing lists which identify the information appropriate to each number and letter.
6. Use of water as a fire-fighting agent
6.1 The drills assigned to dangerous goods in the Emergency Response Guidance document are not always comprehensive in describing all possible hazards. In particular, not all those dangerous goods are identified where the use of water as a fire-fighting agent would exacerbate the situation. In some instances it is possible to identify when water should not be used e.g. those in Division 4.3 or where "W" appears as part of the Drill Code. However, there are other dangerous goods where no such guidance is given but it is known that water should not be used. In the absence of any other guidance (e.g. on the Dangerous Goods Transport Document or other information provided about the dangerous goods on the aircraft) the use of water should be subject to the following considerations:
(a) it should not be used unless the class or division of the dangerous goods is known and there is no specific prohibition on its use in the Drill Code;
(b) it should not be used on any Corrosive material (Class 8, "RCM").
6.2 It is known that a number of dangerous goods react with water to a degree; sometimes the reaction can be severe. Usually, where there is a severe reaction, the classification assigned to the goods is that of having either a primary hazard or subsidiary risk of being water reactive.
6.3 However, there are other dangerous goods which react with water but this is not immediately apparent from the classification. The following groups of dangerous goods are known to react with water and in such circumstances can produce flammable, toxic or corrosive fumes:
(a) Substances which are in Division 4.3 (water reactive substances);
(b) Substances which have a Division 4.3 subsidiary risk;
(c) All entries in the Alphabetical and Numerical Lists of the Emergency Response Guidance document where "W" appears as a letter in the Drill Code.
7.1 There are requirements that the training for flight and cabin crew include emergency procedures for dealing with incidents arising from dangerous goods. This training can be developed from any available material but the Emergency Response Guidance document and this OTAC contain suggested procedures and give General Considerations which might be applied when trying to contain any incident or dealing with the consequences.
7.2 The Emergency Response Guidance document and this OTAC also have suggested checklists, and guidance in the use of these should form part of training if it is intended they be included in the procedures for dealing with a dangerous goods incident. Further information about checklists is given in paragraph 8 below.
8. Development of procedures and checklists
8.1 It is possible for an emergency to arise at any time on an aircraft involving dangerous goods. Obviously, it is only when the goods can be seen that it can be established they are the cause of the problem or are likely to become involved in it. Where a spillage or leakage has occurred or the package appears to be damaged badly, the decision needs to be taken as to whether or not to attempt to contain the effects. To do this successfully, there needs to be a plan of action to ensure no one suffers injury and no further damage is caused. Consideration needs to be given in advance as to what actions should be taken at this time and these should be developed into procedures to be incorporated into the Operations Manual. An appropriate way to summarise these procedures is as a checklist. Appendices 2 and 3 are two suggested checklists - one for use by the flight crew and one for use by cabin crew. These are very comprehensive and could be abbreviated for actual use. They are not a repeat of the checklists which are in the Emergency Response Guidance document but could be considered as alternatives. Explanations and additional guidance in regard to these checklists is given in paragraphs 8.2 and 8.3 below. Further guidance can be found in the Emergency Response Guidance document.
8.2 Guidance Related to the Flight Crew Checklist
8.2.1 The checklist in Appendix 2 is intended to suggest actions which can be taken progressively to deal with a suspected dangerous goods incident which occurs in flight. It is intended for use both on cargo and passenger aircraft and relates mainly to actions which could be taken when the dangerous goods are accessible - either by being on the main deck of a cargo aircraft or in the passenger cabin. It is not intended to be used where there is a warning of fire/smoke in an inaccessible cargo compartment; in these circumstances the standard drills should be used.
8.2.2 In using the checklist, the following should be borne in mind:
(a) reference to the NOTOC, in conjunction with the checklist, is essential; the NOTOC itemises what dangerous goods are on board in cargo and will aid correct identification of the item causing the problem, thus enabling the appropriate Drill Code in the Emergency Response Guidance document to be ascertained;
(b) the decision to send a crew member to investigate an incident should be considered carefully, since if they are overcome by smoke, fumes, etc., the crew complement will be a person short to deal with whatever then happens;
(c) if dangerous goods are not involved in the incident, moving them to a safe area could prevent the problem intensifying; even if they are involved it may be desirable to try to move them to prevent a sudden worsening of the problem.
8.2.3 To amplify some of the suggested actions on the checklist:
(a) if the incident arises in the cabin of a passenger aircraft, it should be left to the cabin crew to deal with initially;
(b) there should be good communications and co-ordination of actions between the flight crew and cabin crew, since it is essential that each is aware of what the other is planning and doing;
(c) vapours and fumes may not be easily detectable; there should be a smoking ban if there is the possibility these have penetrated the cabin or flight deck and it should remain in force for the remainder of the flight;
(d) water should not be used on any spillage or when fumes are present since it may spread the spillage or increase the rate of fuming; also consideration should be given to the presence of electrical components if a water extinguisher is to be used; in addition a number of dangerous goods react badly with water (see paragraph 6);
(e) spillages, fire and fire-fighting activities may cause damage to electrical systems; consideration should be given to turning off all non-essential electrical items and retaining power only to those instruments, systems and controls necessary for the continuing safety of the aircraft. Power should not be restored until it has been ascertained that it is positively safe to do so;
(f) after landing, if the incident was in a cargo compartment, the passengers and crew should disembark before cargo compartment doors are opened; if the incident was in the cabin, the passengers and non-essential crew should disembark before any further action is taken to remove the item or deal further with it or the effects of it;
(g) it should be ensured that ground staff and, if necessary, the emergency services are informed of where the incident occurred and where the dangerous goods now are; if appropriate it should be ensured that the NOTOC is given to the emergency services;
(h) it is essential that an entry be made in the maintenance log to ensure that checks are made for damage as a result of leakage, spillage etc., and that aircraft equipment (e.g. fire extinguishers etc.) are replenished or replaced, as necessary.
8.3 Guidance Related to the Cabin Crew Checklist
8.3.1 The checklist in Appendix 3 is intended to suggest actions which can be taken progressively to deal with a suspected dangerous goods incident which occurs to goods in the possession of a passenger.
8.3.2 In using the checklist the following should be borne in mind:
(a) it may not be possible to deal in total with the incident; the aim should be to ensure that the flight can continue safely, that so far as is possible no one is discomforted and there is no damage;
(b) if there is fire or spillage it may become worse suddenly through, e.g. contact with cabin furnishings or the air;
(c) there are a number of dangerous goods which can react with paper or cloth and these should not be used to mop up spillages because of the possibility of a reaction; however, if the item has already been in contact with these materials they could be considered for use as a last resort.
8.3.3 To amplify some of the suggested actions on the checklist:
(a) if dangerous goods can be identified by name or UN number, it may be possible to obtain information about them from the flight crew if a copy of the Emergency Response Guidance document is carried;
(b) cabin equipment made from polyethylene or a similar plastic material can be utilised to pick up and contain any spillage, if this is needed;
(c) oven gloves or fire-resistant gloves, if likely to be absorbent, should be covered with polyethylene bags;
(d) the assistance of a number of cabin crew members may be required in order to deal effectively with the problem;
(e) if there is only one cabin crew member available, the PIC should be consulted as to whether a passenger should be asked to assist in dealing with the incident;
(f) there should be good communications and co-ordination of actions between the cabin crew and flight crew, since it is essential that each is aware of what the other is planning and doing;
(g) gas-tight breathing equipment should always be worn to deal with smoke, fumes or fire;
(h) water should not be used on any spillage or when fumes are present since it may spread the spillage or increase the rate of fuming; also consideration should be given to the presence of electrical components if a water extinguisher is to be used. In addition, a number of dangerous goods react badly with water (see paragraph 6);
(i) the spillage of a flammable liquid onto fabric may increase the release of a flammable vapour, making the possibility of a fire more likely if an ignition source, e.g. a lighted cigarette, is present;
(j) removing a leaking container would preclude further leakage which might escalate the incident;
(k) the residue of the leakage, both for powders and liquids, should be contained to prevent spreading by surrounding with non-reactive material, such as polyethylene waste bin bags, duty-free sales bags;
(l) powders may be better left in situ if they do not appear to be causing progressive damage or discomfort to crew or passengers (to check for damage there should be the minimum disturbance of the spillage but the edge should be moved to see what is happening underneath);
(m) extreme caution should be used with liquids; they may be better left in situ, if they do not appear to be causing progressive damage or discomfort to passengers, and covered with polyethylene based material;
(n) polyethylene bags containing leaking items etc. should be placed in a toilet, if possible. On pressurised aircraft this should vent any fumes away from the passengers, but it might not be so on an unpressurised aircraft;
(o) for a limited period polyethylene should not react with any dangerous goods;
(p) badly contaminated cabin furnishings, carpet etc. might need to be removed. They should be stowed in a toilet or in an area well away from passengers and crew, in polyethylene bags if possible;
(q) the use of therapeutic masks with portable oxygen bottles or the passenger dropout oxygen system, to assist passengers if smoke or fumes are present, should considered since smoke or fumes could be inhaled through the valves or holes in the masks. Giving passengers a wet towel or other wet cloth to hold over the nose and mouth is more effective in filtering out smoke or fumes;
(r) regular inspections should be made of any item which has been removed to ensure it is not causing any further problem;
(s) it should be ensured that ground staff and, if necessary, the emergency services are informed of where the incident occurred and where the dangerous goods now are;
(t) it is essential that an entry be made in the aircraft technical log to ensure that checks are made for damage as a result of leakage, spillage etc., and that aircraft equipment (e.g. fire extinguishers etc.) are replenished or replaced, as necessary.
9. Emergency Response Kit
9.1 There is no requirement for the carriage of an emergency response kit but some operators may choose to carry one. Whilst the aim of carrying the kit is to deal with incidents arising in the passenger cabin, it might also be of use on cargo aircraft if there is an incident with dangerous goods which are accessible. The aim of such a kit is to ensure there are items available that can be used to deal with the containment and absorption of dangerous goods should there be a spillage or leakage. Typically, a kit might consist of:
(a) supply of large, good quality polyethylene bags;
(b) bag ties;
(c) several pairs of long rubber gloves, which are flexible and of good quality;
(d) small quantity of sand;
(e) sodium bicarbonate.
9.2 It should be noted that polyethylene is reasonably resistant to all dangerous goods, at least for a short while. Sand is inert and can be used safely, except when there are products containing Hydrofluoric acid; these are identified by UN numbers UN 1786 and 1790. Sodium bicarbonate can be used safely with all acids but there may be some bubbling and carbon dioxide may be given off.
9.3 The emergency response kit suggested above is more comprehensive than that listed in the Emergency Response Guidance document, in that sand and sodium bicarbonate have been added to the list of items. It is felt that if a kit is to be carried the inclusion of these would greatly enhance its usefulness without adding significantly to either weight or cost and would then provide the means of suitably dealing with the containment or absorption of all dangerous goods, at least in the short term.
9.4 It will be noted that paper is not included in the kit; this is because it can react with a number of chemicals so that it disintegrates quickly or begins to smoulder. Its use is not recommended, unless there are positive indications that there will be no reaction e.g. the container for the item is paper or fibreboard/cardboard, or it is already in contact with these.
9.5 Although rubber gloves are included in the kit, other personal protective equipment may be needed, such as portable breathing equipment, goggles, overalls etc.
9.6 If an emergency response kit is carried, instructions in its use should be included in training.
9.7 Guidance Related to the Checklist When Using an Emergency Response Kit
At Appendix 6 is a suggested checklist for the actions which could be taken to deal with a spillage or leakage of dangerous goods using an emergency response kit. To amplify some of the suggested actions on the checklist:
(a) better decisions can be taken if the item can be accurately identified and the correct emergency response ascertained; there may be a label on the container which will give the information required and this will aid prompt and effective clean-up action;
(b) if there is no label on a container giving emergency information, there may still be a recognisable proper shipping name or UN/ID number (with or without the prefix letters) which can be checked against the alphabetical and numerical lists in the Emergency Response Guidance document;
(c) if it is suspected that there might be a reaction with sand, a sample can be tested first by placing a small quantity on the edge of the spillage and waiting for 2-3 minutes; any reaction would become apparent in that time but it would not be catastrophic;
(d) sodium bicarbonate should not be used on any dangerous goods except acids;
(e) the aim in removing an item from the cabin is to try to ensure that further fuming or leakage will not cause discomfort to passengers or crew and will not be detrimental to the continued good order of the flight. This is done by securing the item in at least two polyethylene bags, in a position so that further leakage cannot occur, and placing the bags in a location remote from the passengers and crew;
(f) the decision to try to remove the residue of a spillage, or leave it in situ and cover, may depend on the extent of that spillage and the effect it is having on passengers and crew. Despite passenger reaction, it might be preferable not to attempt to remove the residue but leave it covered by sand or sodium bicarbonate;
(g) it is unlikely that all traces of spillage will be removed unless the affected cabin furnishings, carpet etc. are also removed.
10. Raising of a Dangerous Goods incident report
When there has been a problem on an aircraft involving dangerous goods, it may be a dangerous goods incident which is reportable to the OTAA.