Risk reduction strategy
A risk reduction strategy has been developed for carriage of dangerous goods by air. When implemented it makes the carriage of these goods an acceptable practice.
Regulation of dangerous goods
Australia is a signatory to the Chicago Convention of the International Civil Aviation Organisation (ICAO) which governs international aviation. Annex 18 of the convention covers the broad principles relating to the carriage of dangerous goods by air. Australia has implemented the principles which are detailed in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods. Many airline operators use the International Air Transport Association (IATA) dangerous goods regulations which adopt the ICAO Technical Instructions and include provisions in some areas which achieve an even higher safety standard.
The Australian Civil Aviation Act 1988 and Civil Aviation Regulations set out the requirements for consigning and carrying dangerous goods as well as the training of employees of commercial aircraft operators, freight forwarders and regular shippers of dangerous goods. They also set out requirements for the shipper of any cargo to declare either:
- a description of the contents, or
- that the goods are not dangerous.
Classification of dangerous goods
The ICAO Technical Instructions include a comprehensive list of individually identified articles and substances which are deemed to be dangerous goods. Each listing has a specified United Nations classification number (UN number), a corresponding packing instruction number and maximum allowable quantities per package directions. Since the listing of substances cannot be exhaustive, there are many generic or "not otherwise specified" entries. The Technical Instructions also includes a section on how to test particular articles or substances to determine whether they are dangerous and thus enable the goods to be classified into the appropriate generic group. If in doubt, check with the manufacturer or distributor of the product.
Some dangerous goods have been identified as being too dangerous to be carried on any aircraft under any circumstances. Others are forbidden under normal circumstances but may be carried with specific approval from the aviation authority of the countries involved (usually the countries of the sender, the recipient and sometimes the country where the aircraft is registered). Some goods are restricted to carriage in cargo-only aircraft, however provided certain requirements are met, most can be safely carried on passenger aircraft as well.
Packing, packaging and preparation of dangerous goods
Packaging is an essential component in the safe transport of dangerous goods by air. Regulations provide Packing Instructions for all dangerous goods which are acceptable for transport by air with a wide range of options for combination (consisting of inner and outer packaging) and single packagings. The packing instructions normally require the use of United Nations (UN) performance-tested specification packagings. These are not required when dangerous goods are shipped in Limited Quantities (small amounts) under the provisions of the Limited Quantity "Y" Packing Instructions. The quantity of dangerous goods permitted within these packagings is strictly limited to minimise the inherent risk presented should an incident occur.
There are a number of packaging suppliers in Australia who can provide UN specification packaging. Selecting packaging to contain dangerous goods where a combination package is required (ie. a number of small packagings inside a larger packaging) is not as simple as just choosing a box off a shelf. The regulations generally require the packaging and the dangerous goods to be tested together to establish that it is a safe and appropriate package. There are exceptions to this general rule. It is suggested that the advice of CASA be sought where doubt exists about the packaging standards.
Packagings can be tested to UN standards by contacting:
National Association of Testing Authorities
Attn: Engineering Materials Officer
7 Leeds Street
Rhodes NSW 2138
Ph: 02 9736 8222
Fax: 02 9743 5311
Documentation of cargo
With all air cargo, there is a requirement that anyone who consigns cargo must either describe the contents or declare that the cargo does not contain dangerous goods. In describing the contents of the package, those people who accept and handle the cargo at the airline and freight forwarder's premises know what the nature of the cargo is. They are then in a position to identify and remove items which may be inherently dangerous when carried by air.
With declared dangerous goods, there is also a requirement to complete a Shippers Declaration PDF version or Shippers Declaration editable RTF version. The proper declaration of dangerous goods by the shipper ensures that all parties involved in the transportation chain know what type of dangerous goods they are transporting, how to properly load and handle them and to be prepared in the unlikely event an incident or accident occurs either in-flight or on the ground.
It is also common for shippers to include a copy of the Material Safety Data Sheet (MSDS) for the contents with the Shippers Declaration.
The airline is required to complete a Notification to Captain (NOTOC) form which ensures that the pilot is aware of the dangerous goods that he/she is carrying, where they are located on the aircraft and the emergency response actions to be taken in the event of an emergency.
Information to passengers & consignors of cargo
Passengers must be provided with information regarding "hidden dangerous goods" to assist them in recognising dangerous goods which they are not permitted to carry on the person or in their baggage and which may not be readily recognisable as being dangerous to the untrained eye. Information must also be given to persons who consign cargo.
This information is usually conveyed on the back of each passenger's ticket, through usage of display cabinets in airport foyers and with posters and signage at check-in counters, freight sheds and baggage halls. Travel agents also provide this information when tickets are sold and as do web-based agencies when using e-ticketing.
Marking and labelling
The Regulations require that consignments containing dangerous goods be properly marked and labelled. This includes hazard labels and written material giving the United Nations identifying number and the proper shipping name of the contents. People involved in handling the consignment can identify the nature of the risk and take appropriate precautions should there be a leak or breakage.
Training
An essential element to ensure the safe transport of dangerous goods lies in appropriate training. This ranges from the shipper being trained to ensure any dangerous products are appropriately classed and packaged, to the aircraft operator's staff being trained in the acceptance and examination of cargo, how to identify potentially undeclared dangerous goods, and to ensure that declared dangerous goods are packaged, prepared and handled in accordance with the proper instructions and that the accompanying documentation is correct.
The Civil Aviation Safety Regulations place employees into 6 groups, each appropriate to the functions and responsibilities of the employee. Training of these employees is required for aircraft operators, ground handling agents, freight forwarders, security screening agencies and shippers of dangerous goods.
Accident and incident investigation
Dangerous goods incidents or accidents must be reported by the aircraft operators to the relevant air safety authority. Investigations are carried out to establish the cause of the incident Corrective action can then be implemented to prevent a re-occurrence.
It is worth noting that less than 5% of incidents involving cargo originate from declared dangerous goods, and almost all of these are minor documentary deficiencies and not the result of spillages. It is the undeclared dangerous goods which cause most of the problems.
The role of the Civil Aviation Safety Authority (CASA)
CASA is responsible for implementing, regulating and enforcing Australia's international treaty obligations in respect to the carriage of dangerous goods by air. CASA develops standards, controls entry to the industry of aircraft operators, carries out industry compliance monitoring and the education of both the industry and the general public on dangerous goods issues.