Transport of Dangerous Goods as cargo

1. Approval to transport Dangerous Goods

1.1 An Operator must hold a permanent approval from the Governor before dangerous goods can be carried by air. This permanent approval (other than when granted to a non-Territory Operator) will normally be part of the grant of the AOC but it may be granted separately. An application form for a permanent approval can be obtained from the OT aviation authority (OTAA). In addition to the information on the application, the OTAA will need to be satisfied that adequate training has been given, that all relevant manuals (e.g. ground handling manuals, Operations Manual, etc.) contain instructions and guidance material and that there are procedures in place to ensure the safe handling of dangerous goods at all stages of their transport by air.

1.2 In addition to the permanent approval, a further specific approval is required when:

(a) The Technical Instructions indicate that an exemption is required from all the States concerned (which may be those of the origin, transit, overflight and destination of the consignment and that of the Operator); or

(b) The Technical Instructions indicate that an approval is required from the State of Origin of the goods (which is where they are to be first loaded onto an aircraft) - see paragraph 1.4 below regarding A1, A2 or A109 approvals.

1.3 Dangerous goods carried in accordance with an exemption or specific approval must comply with the conditions on that exemption or approval as well as those on the permanent approval, unless these have been varied.

1.4 The Technical Instructions indicate that some dangerous goods which are forbidden in normal circumstances can be carried subject to an approval having been granted by the State of Origin; these goods are identified in the Technical Instructions by special provision A1, A2 or A109. When they are to be carried on a passenger aircraft in a Territory under A1 or A2, specific approval is required from the OTAA irrespective of whether or not the Territory is the State of Origin for the goods. They may be carried into the Territory on a cargo aircraft under an A2 or A109 approval granted by the State of Origin, providing the OTAA has been notified in writing prior to the proposed flight date. Moreover, where the dangerous goods are explosives, advice should be sought from the OTAA in good time before the flight as to the suitability of the intended airport of landing for the handling of the explosives. This is because controls exist for the quantities of explosives that can be handled at certain airports at any one time. Failure to seek this advice may result in the aircraft being refused permission to land at the planned airport.

2. Transport of radioactive materials - Quality Assurance programme

2.1 Operators who need to carry radioactive materials will need to have a quality assurance programme which includes procedures for the transport and in-transit storage of such materials, with the aim of ensuring compliance with all relevant provisions. This requirement stems from the Regulations for the Safe Transport of Radioactive Material produced by the International Atomic Energy Agency. The quality assurance programme should cover the following elements:

(a) Quality assurance procedures;

(b) Organization;

(c) Document control;

(d) Inspection and test control;

(e) Controls of use and care of packages;

(f) Non-conformity control;

(g) Corrective actions;

(h) Records;

(i) Staffing and training;

(j) Audits.

2.2 Operators otherwise required to have a quality system to monitor compliance with, and the adequacy of, procedures to ensure safe operational practices, could incorporate the elements necessary to provide for the transport and storage of radioactive materials, or a separate programme can be devised.

3. Explosives

Operators wishing to carry explosives should ensure they are able to comply with the national regulations that may apply in relation to explosives in the country they are operating to or from. Operators who are uncertain of the regulations that apply should seek guidance from the OTAA. See also Chapter 4 paragraph 8 on the storage of explosives.

4. Acceptance for transport

4.1 An acceptance check is carried out to establish that a package of dangerous goods appears to be in a fit condition for transport and that the associated documents are complete and accurate. This initial inspection is a vital aid to ensuring the integrity of packages before they are accepted for transport and loaded on an aircraft. It should be carried out conscientiously and methodically, with attention paid to anything which appears to be unusual, such as a package being heavy for its size or having an uneven weight distribution as these could indicate it is not packed properly. However, minor tears or dents in an outer or single packaging should not result necessarily in rejection of the package; what matters is whether or not these have reduced the ability of the packaging to continue to perform its prime containment function.

4.2 An Operator carries out an acceptance check on all packages of dangerous goods, and the associated documents, before they are accepted for transport, to ensure that at the end of the check it can be established that:

(a) the documents (e.g. the Dangerous Goods Transport Document and any Air Waybill) are in order, and

(b) that the package is marked and labelled correctly, and

(c) that from its external appearance it appears to be in a fit condition for transport.

Note: The IATA Dangerous Goods Regulations show model checklists which are suitable for meeting this requirement. The checklist needs to be capable of completion by the checker, whether this is by manual, mechanical or computerised means; if the checklist is computerised it needs to be capable of being printed out so that a copy of it can be obtained if required.

4.3 There may be occasions when packages of dangerous goods and/or their documents are found during the acceptance check not to be in total compliance with all applicable requirements. In these circumstances they should not be accepted for air transport but returned to the shipper or his agent with an explanation for the rejection. Whilst there is no legal requirement to do so, annotating the acceptance checklist with the reasons for the rejection can aid any future acceptance check on the corrected package/documents. It will also provide a record of the actions taken in relation to the original consignment which was offered for transport. Depending on the reasons for not accepting a consignment, there may be a need to retain the package(s) and document(s) since there is the possibility that the level of non-compliance is such that it is a potential dangerous goods incident. In this case, the OTAA needs to be informed (see Chapter 7).

4.4 Where an Operator uses the services of a handling agent to accept dangerous goods for transport, he should ensure that acceptance checks of the required standard are carried out. There must also be an agreement between them as to who will keep the completed acceptance checklist, where it will be stored and what action each will take in relation to consignments which are to be rejected.

5. Inspections for leakage or damage

It is important to ensure that leaking or damaged packages of dangerous goods are not loaded on an aircraft since this could lead to an incident in flight hazarding its safety. Any leaking or damaged packages which are found on board need to be removed without delay and the operator informed. An initial inspection of packages is carried out during the acceptance check; further checks must be made before the packages are loaded into an aircraft or a unit load device (ULD) and when they have been unloaded. This final check should be carried out as soon as possible after unloading to ensure that if leakage has occurred during either a flight or the loading/unloading process, the aircraft can be inspected for damage or contamination before undertaking another flight.

6. Loading and Stowage

6.1 There are loading and stowage requirements in the Technical Instructions which are intended to ensure that:

(a) dangerous goods are separated from passengers and crew members (except for those which have to be accessible on cargo aircraft);

(b) incompatible goods are kept apart;

(c) there is securement to prevent movement in flight, and

(d) there are restrictions on the stowage of "cargo aircraft only" dangerous goods on such aircraft.

6.2 These requirements ensure that there cannot be interaction between incompatible goods in the event of leakage and that any leakage cannot affect the passengers or crew. They also ensure that packages cannot suffer damage through movement (such as falling over). Finally, on cargo aircraft, the requirements are designed to ensure that most of the dangerous goods are accessible so that, if a problem arises, the crew can consider actions such as moving packages or containing/absorbing any leakage.

6.3 Some packages of radioactive materials emit a low level of radiation during transport; the permitted limit is set down in the Technical Instructions. To protect passengers and crew from this radiation, separation distances are laid down which detail how far a package of such radioactive material needs to be stowed from the nearest occupied area. Not all packages of radioactive materials require separation since not all of them emit radiation during transport. Those which do emit measurable radiation have labels which are half yellow and half white; whilst those which do not emit such radiation are all white in colour. Both types of labels have on them the trefoil (radioactive) symbol.

7. Damaged packages of Dangerous Goods and contamination

7.1 Not dealing with damaged packages at the time they are found may cause problems later, which may then be more difficult to deal with. Packages may be damaged in flight because of bad loading or the movement of cargo; they may be damaged on the ground due to bad stacking or handling or from being left in a place where a heavy item can fall on them or they can be run over by a fork-lift truck. See also Chapter 4 paragraph 6.

7.2 Packages which are damaged on the ground must never be loaded on an aircraft. If a damaged package is found on an aircraft it should be removed, or arrangements made for its removal by a specialist organisation, and a check made to ensure no other piece of cargo on board is damaged and there is no contamination. Where, upon unloading from an aircraft or ULD, it is suspected that packages of dangerous goods have been damaged or are leaking, the aircraft should be checked without delay for damage or contamination and any found dealt with immediately. The cause of the damage or contamination should be identified quickly, since permanent damage to the airframe may need to be prevented and some types of spillages may need to be neutralised. Operators and handling agencies should have procedures for notifying the maintenance organisation of any spillage or leakage of dangerous goods on an aircraft. This is especially important when the event occurs away from the main base, since further remedial action may need to be taken.

7.3 In flight the crew, even if they realise there is leakage from a package and can reach it, can only respond with first-aid measures intended to contain the immediate problem or land without delay. Specific action to deal with damaged and leaking packages can only be taken when they can be handled without obstruction, so that an assessment can be made of the extent of damage and leakage and the potential hazard to persons. Guidance for actions in emergencies may be shown on a package or on accompanying documents but in the absence of this it may need to be obtained from the shipper, consignee or a specialist organisation. Sufficient information must be given to them to enable accurate identification of the goods. However, if nothing can be ascertained, a "worst case" may have to be assumed, but any information on packages and documents should be believed unless there are positive indications that it is inaccurate.

7.4 Leaking packages of infectious substances and radioactive materials have the potential for spreading airborne contamination unless they are correctly dealt with. If a package of an infectious substance is found to be damaged or leaking it must be isolated, the public health authority notified and the shipper and/or consignee informed. If a package of radioactive material is found damaged or leaking, it must be isolated and a qualified person called to establish the extent of the leakage and whether there is any contamination. If there is contamination of an aircraft from radioactive material it must be taken out of service until such contamination is removed or reduced to levels specified in the Technical Instructions.

7.5 Damaged or leaking packages of dangerous goods must be disposed of safely, to ensure they cannot cause injury or property damage. Depending on the hazard of the goods, it may be possible to dispose of them locally or, if they are in transit, to have them re-packed and returned to the shipper or sent on to their final destination. The shipper or consignee should be able to advise on disposal. If they are to be re-packed for onward carriage the shipper will need to give instructions for this to be done and authorise an appropriate person to sign a new Dangerous Goods Transport Document on their behalf.

8. Contaminated Baggage or General Cargo

It is possible that baggage or general cargo on board an aircraft or which is to be loaded on an aircraft may become contaminated by leaking dangerous goods. Where it is suspected this has happened it should never be ignored, particularly if the baggage or cargo is in transit, since there may be a delayed reaction leading to a serious incident in flight. If it is thought that contamination of baggage or cargo has been caused by dangerous goods, the goods need to be identified in order to establish the hazard and the correct method of dealing with it. Baggage and cargo which has been contaminated should never be placed on an aircraft until the Operator is satisfied that all trace of the contaminant has been removed or neutralised.

9. Provision of information to the pilot-in-command (the NOTOC)

9.1 In the event that an aircraft carrying dangerous goods wishes to make an emergency landing, details of these will need to be conveyed to ATC for the benefit of the emergency services. It is also important that the pilot in command PIC is aware of where dangerous goods have been placed on the aircraft. To this end, he must be given written information about what has been loaded on board, and its location. This information is usually referred to as the "NOTOC" - Notification to Pilot in Command (formerly Notification to Commander); it may be produced manually or by computerised means and as a minimum it needs to show, for each package of dangerous goods:

(a) The proper shipping name and UN/ID Number;

(b) The class/division, any identified subsidiary risk(s) and, for explosives, the compatibility group;

(c) The packing group, number of packages and net or gross quantity;

(d) The category and transport index (for radioactive materials);

(e) The loading location;

(f) When for cargo aircraft only;

(g) The airport of unloading;

(h) Where State exemptions apply

9.2 It is not uncommon for some consignments to consist of packages of different net quantities of the same dangerous goods. When there is a consignment of multiple packages of the same dangerous goods, the NOTOC may show for each loading location only the total quantity and the net quantity in the largest and smallest package. The NOTOC is to include details of any dangerous goods which remain on board from a previous flight or which are temporarily offloaded and are to be reloaded for onward carriage. A telephone number may be included from where the information on the NOTOC can be obtained and which the pilot in command, in an emergency, can give to the air traffic services as an alternative to giving detailed information.

9.3 The NOTOC needs to be a dedicated form i.e. it should not consist of copies of Dangerous Goods Transport Documents. The information on it should be presented in a legible manner. It should include confirmation, either by a written signature or by some other indication, that there is no evidence that damaged or leaking packages have been loaded; and the PIC needs to acknowledge receipt of the information, by signature or in some other manner. The NOTOC is to be readily available to the PIC in flight.

9.4 As part of the requirements for dealing with emergency situations, there is a need to ensure that the information about what is on an aircraft is available from several different ground sources. A legible copy of the NOTOC needs to be retained on the ground at the departure airport and this copy should include the PIC's acknowledgement of the receipt of the information. This copy or the information on it is to be readily accessible at the departure and scheduled arrival airports until after the flight has been completed.

9.5 On some flights there may be a large quantity of dangerous goods to be carried; this means that in an emergency it is likely to be impractical or impossible for the PIC to consider giving to the air traffic services detailed information about the dangerous goods on board. In such circumstances it is recommended that, in addition to the NOTOC, an Operator provide a summary of the information on it, giving at least the quantities and classes or divisions of the dangerous goods in each cargo compartment; this would assist the PIC in knowing what is the essential information to give over in the event of an in-flight emergency.

9.5 The NOTOC, or a copy of it, must be retained for a minimum period of three months but after the flight has been completed, the place of retention does not need to be readily accessible.

10. Retention of records

Paragraphs 4 and 9 refer to the need to retain the acceptance checklist and the NOTOC. Apart from these documents, a copy of the Dangerous Goods Transport Document must also be retained. Among other things, this is to ensure that full information is available on the ground about the dangerous goods on board an aircraft in case it should suffer a catastrophic accident in flight and there is a need to know what was on board. Therefore, the location at which the copy is kept, at least for the expected duration of the relevant flight(s), should allow for access to it within a reasonable period of time. After that it may be retained at some other point. The copy of the Dangerous Goods Transport Document is required to be retained for a minimum period of three months.

11. Cargo-only aircraft and carriage of operator's staff

11.1 Some dangerous goods are restricted to transport on "cargo aircraft only". In this context such an aircraft can also carry persons who, for other reasons, may be regarded as passengers.

They are:

(a) an authorised representative of the OTAA, ASSI or other Authority;

(b) a person accompanying a shipment on board, which is not necessarily a consignment of dangerous goods;

(c) a member of the Operator's staff in an official capacity.

11.2 A member of the Operator's staff in an official capacity is intended to mean that they have duties concerned with the preparation or undertaking of the flight, or on the ground once the aircraft has landed although not necessarily in connection with any aircraft.

11.3 Dangerous goods are restricted to transport on cargo aircraft because of the quantity contained in a package or they are considered unsuitable for passenger aircraft in normal circumstances. Most "cargo aircraft only" dangerous goods are required to be stowed in an accessible position on the main deck of the aircraft. If an incident occurs on a cargo aircraft carrying dangerous goods, the flight crew can consider a greater range of options than is possible on a passenger aircraft e.g. inspecting the packages to assess the problem, attempting to deal with it, using oxygen masks, reducing pressurisation. Carrying persons other than the flight crew on cargo aircraft may reduce this range of options; therefore, it should not become routine to do so. A number of factors need to be considered on each occasion, such as what is being carried, what Classes are represented, what net and total quantities are involved and the stowage location.

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