Transport of Dangerous Goods by air as cargo - Additional requirements in the Territories
1. Additional requirements
The Technical Instructions contain all the requirements applicable to the transport of dangerous goods by air. In the Territories there are some circumstances when it is considered that either additional requirements or variations to the normal requirements are needed; these are identified below. When these require the grant of an exemption or specific approval it is the responsibility of the operator to apply for that exemption or specific approval. Similar exemption or approval may also be required from other States if part of the flight is in their territory.
2. Rescue and Fire-Fighting cover at airports
2.1 Operators should take careful note of any operating conditions placed on their Approval document that may require them to operate to and from certificated aerodromes only, or aerodromes with a certain level of rescue and fire-fighting provision.
2.2 Irrespective of the conditions on approvals, there may be occasions when it is safer to land at an aerodrome when the minimum RFF category is below that required rather than divert to another airport. An example of this is an emergency landing, or if in the pilot's opinion, a diversion or hold may introduce a more significant hazard.
2.3 Whilst it is the Operator's responsibility to ensure the condition is met, in practice the decision is likely to be placed on the PIC, since he will be in possession of all the required information, including what dangerous goods are on board. If an aircraft might use an airport where it is possible the RFF cover at the time of landing may not be at the minimum level specified in any approval, the Operator should discuss the problem with the OTAA and have contingency procedures in the Operations Manual to assist the PIC in his decision for landing or diverting.
3. Passenger aircraft without Class B main deck cargo compartments
3.1 On aircraft carrying passengers, dangerous goods can only be carried in any main deck cargo compartment when this meets the certification requirements for a Class B cargo compartment. There are many aircraft in operation which do not have such a main deck cargo compartment e.g. HS748, F27.
3.2 There are some dangerous goods which present a relatively low hazard and which, therefore, could be suitable for transport in aircraft where the only available cargo compartment is on the main deck but it does not meet the requirements for a Class B cargo compartment.
3.3 The Technical Instructions recognise that dangerous goods of the types shown below could be carried safely and have provided that the State of Origin may exempt to allow them to be carried under certain conditions. The dangerous goods are primarily:
(a) Division 1.4S explosives;
(b) Division 2.2 gases;
(c) a number of liquids and powders which are in Packing Group III and some articles of Classes 3, 8 and 9, Divisions 4.1, 5.1 and 6.1;
(d) Division 6.2 infectious substances; and
(e) Class 7 radioactive materials in excepted packages or those requiring White-I labels on the package.
3.4 In the event of leakage, none of these dangerous goods will produce fumes or any other reaction which could cause discomfort to passengers.
3.5 The OTAA may be prepared to grant an exemption to an Operator who wishes to carry dangerous goods but whose passenger aircraft only have main deck cargo compartments and these do not meet the Class B cargo compartment certification requirements. Advice can be sought from the OTAA.
4. Transport of Dangerous Goods on helicopters
4.1 The Technical Instructions use the term "aircraft" throughout the document. Often the wording suggests the provisions are relevant only to fixed-wing aircraft but unless it is apparent otherwise all the provisions are intended to apply to helicopters, no matter whether the dangerous goods are carried inside or outside. This does mean there may be some circumstances when it is impracticable or impossible for dangerous goods to meet the full requirements e.g. when they are underslung beneath a helicopter. The requirements are likely to be those concerned with packing, the marking of packages and loading.
4.2 There is a set standard of packing, including specifications and testing requirements for packagings, but other ways of achieving an equivalent level of safety are possible.
4.3 Whilst many of the markings on packages are necessary to ensure accurate identification of them and their contents, some of them do not make a direct contribution to safety and can be omitted in some circumstances. The loading requirements for passenger aircraft, as indicated in paragraph 3.2 above, restrict carriage on the main deck to being in cargo compartments meeting Class B certification requirements; this certification is inappropriate for helicopters and if there is an essential reason for doing so it may be possible to permit dangerous goods and passengers on the same helicopter, depending on circumstances and what needs to be carried.
4.4 The OTAA may be prepared to grant an exemption to an Operator to permit helicopters to carry dangerous goods other than in accordance with the normal requirements for packing, marking of packages and loading, providing it can be satisfied that the level of safety will be not less than that achieved by the normal requirements and providing there are overriding reasons for allowing the variation. Advice can be sought from the OTAA.
5. Transport of radioactive material over a Territory
The Technical Instructions provide an internationally accepted means of carrying dangerous goods and, in normal circumstances, there is no need to impose operating conditions over and above those which are contained in the Instructions. However, there are some circumstances when it is felt that additional conditions are required in order to provide information that would be needed immediately should an aircraft suffer a catastrophic event whilst overflying a Territory. These circumstances are primarily when an aircraft is carrying certain types of high activity radioactive material. An Operator intending to carry packages of radioactive material containing an activity greater than:
(a) for special form 3000 A1 or 100,000 A2, whichever is the lower; or
(b) for all other radioactive material 3000 A2
must notify the OTAA at least three working days before the flight.
6. Ground Handling and Storage
6.1 Ensuring the safe handling and storage of dangerous goods in warehouses, transit sheds etc., is not primarily within the responsibility of the OTAA. The appropriate competent authority may be the Government body responsible for Health & Safety, for the Environment or, in some circumstances, the Police.
6.2 Operators may require, either as part of their own safety management system, or in response to additional local legislation, to make an assessment of all the risks to the health and safety of their employees to which they are likely to be exposed whilst at work (and to non-employees who might be affected by the work activities); this requires a proactive approach to health and safety as well as a reactive one. The assessment should establish if there are any foreseeable ways in which packages of dangerous goods could become damaged through, for example, bad handling or storage and identify good working practices to reduce the possibility of this happening. For example:
(a) segregating packages from vehicle routes to prevent damage by fork-lift trucks;
(b) not storing packages in an insecure manner at a height where they are liable to fall;
(c) segregating significant quantities of incompatible dangerous goods from each other;
(d) ensuring there is adequate ventilation (e.g. natural ventilation) in the vicinity of packages of gases, flammable liquids, self-reactive substances and organic peroxides;
(e) ensuring packages are stored in the direction of any orientation arrows.
6.3 The risk assessment may show that, despite the precautions which have been taken, it will still be possible for damage and leakage to occur. In order to deal with spillages and leakages there should be contingency planning for what to do if such an event should occur; it would need to identify different levels of response depending on the type and quantity of material involved.
6.4 If dangerous goods handled at an airport are subsequently forwarded by road or rail there are various sets of regulations dealing with the different modes of transport which will apply.
7. Handling and Storage of Radioactive Materials
7.1 Operators undertaking work with ionising radiation will need to consider the storage and moving of the material as well as its carriage within the aircraft. An operator carrying radioactive material should establish a framework for ensuring that exposure to ionising radiation arising from work activities is kept as low as reasonably practicable and does not exceed the dose limits specified by the International Atomic Energy Agency. The Operator should provide key working instructions setting out the arrangements for restricting exposure in a particular area, and should consider appointing one or more radiation protection supervisors (RPS) to supervise work health and safety in such areas. Where necessary, Operators should seek appropriate specialist advice.
7.2 Records need to be maintained of all radioactive materials which are in transit. If it is believed a package of radioactive materials has been lost or stolen, it has to be reported as soon as possible to the OTAA and to the Police.
8. Storage of Explosives
National legislation may require that explosives are stored only in licensed or approved areas. In this instance it is likely that explosives would therefore need to be brought to the airport only a short time before the flight and the acceptance check will have to be carried out immediately prior to loading. Explosives need to be kept under secure conditions at all times when stored, to preclude unauthorised access to them and to prevent accidental damage which may affect the integrity of their packaging. It is suggested that, depending on the type and quantity, the loss of explosives whilst in the care of the Operator be reported to the Police.
9.1 There are specific requirements for training; these appear in both the Technical Instructions and OTARs.
9.2 They apply to all Operators, even when an approval to carry dangerous goods is not held. Where the Operator uses the services of a handling agent there is a responsibility on the Operator to ensure the staff of that agent are trained to the level necessary to perform their functions.
9.3 Training programmes are required to be established and maintained for all flight and cabin crew and appropriate ground staff (e.g. those involved in passenger check-in, acceptance of dangerous goods, cargo and baggage handling). Refresher training has to be given at intervals of not longer than two years. The level of training and the areas to be covered depend on the responsibilities of the individual; and the time taken to perform the training will depend on the level and the areas to be covered.