DANGEROUS GOODS
INTEGRATED MODULE
Compiled by :
Global Maritime Legal Solutions
World Class Knowledge Centre
This Module is suitable for training towards the FIATA Diploma, TETA, & QCTO
Qualifications and similar such courses.
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Learner Guide compiled by:
Mark Goodger
Review date – 2022 – Rhoda Kellner RISK MA
Copyright © 2022 edition.
Global Maritime Legal Solutions (Pty) Ltd.
No part of this book may be reproduced in any form or by any means without written
permission from the publisher.
WARNING AGAINST PLAGIARISM
ASSIGNMENTS ARE INDIVIDUAL TASKS AND NOT GROUP ACTIVITIES. (UNLESS
EXPLICITLY INDICATED AS GROUP ACTIVITIES)
Copying of text from other learners or from other sources (for instance the study guide,
prescribed material or directly from the internet) is not allowed – only brief quotations
are allowed and then only if indicated as such.
You should reformulate existing text and use your own words to explain what you have
read. It is not acceptable to retype existing text and just acknowledge the source in a
footnote – you should be able to relate the idea or concept, without repeating the original
author to the letter.
The aim of the assignments is not the reproduction of existing material, but to ascertain
whether you have the ability to integrate existing texts, add your own interpretation
and/or critique of the texts and offer a creative solution to existing problems.
Be warned: students who submit copied text will obtain a mark of zero for the assignment
and disciplinary steps may be taken by the faculty or University. It is also unacceptable to
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Table of Contents still to be inserted
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LEARNER GUIDE
DANGEROUS GOODS INTEGRATED MODULE
This Module incorporates all the NQF 4 Qualification Unit Standards relevant to Dangerous Goods
to ensure that the purpose of the full subject is achieved.
A range of formative and summative integrated assessments appropriate to the criteria being
assessed are utilised, to gather evidence towards competence. This will ensure the verification of
whether the learner “is able” to perform the required outcomes.
Unit Standards covered in this module
SAQA US ID Unit standard title Credits
242986 Accept and process dangerous goods for transportation by air 6
242991 Facilitate the forwarding and clearing of dangerous goods for 4
transportation
242997 Identify and classify dangerous goods for transportation 4
242996 Handle dangerous goods during warehousing and storage 4
242987 Identify, pack, mark, and label dangerous goods for transportation by air 2
242990 Load/unload dangerous goods for transportation by road 10
242985 Package dangerous goods for transportation 4
TOTAL CREDITS 34
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OVERALL OBJECTIVES OF THIS MODULE
The learners will be able to:
US 242986
• Interpret and apply the philosophy underpinning the carriage of dangerous goods by air.
• Identify and apply the limitations associated with the carriage of dangerous goods by air.
• Verify the classification of dangerous goods when accepting and processing dangerous goods
for transportation by air.
• Compile and verify documentation
US 242991
• Arranging and evaluating relevant documentation relating to the movement of dangerous
goods for transportation.
• Identifying and classifying dangerous goods.
• Facilitating the transportation of dangerous goods.
• Organising storage for dangerous goods.
US 242997
• Receiving a sample of potential substance.
• Facilitating the analysis and assessment of a sample based on United Nations criteria for
classification and identification.
• Facilitating the development of the Material Safety Data Sheet and transport documentation
relevant to the substance.
• Identifying and allocating packaging requirements according to substance if classified.
US 242996
• Identifying and classifying dangerous goods in accordance with documentation, packaging, and
labelling.
• Handling and storing classified goods and substances.
• Preparing the dangerous goods for transportation.
• Taking appropriate actions in the event of accidents in the handling of dangerous goods.
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US 242987
• Identifying dangerous goods for transportation by air.
• Identifying and applying packaging requirements for the transportation of dangerous goods by
air.
• Identifying and applying the marking and labelling of dangerous goods for transportation by air.
US 242990
• Adhering to standard operating procedures and applicable requirements of South African
National Standards 10231 for the loading/unloading of packaged goods and bulk.
• Identifying required placards, tremcards, and dangerous goods declaration.
• Complying with standard operating procedures and South African National Standards 10231
after loading/unloading of dangerous goods.
• Complying with contents of operational agreement RISK MA.
US 242985
• Identifying and classifying dangerous goods to be packed.
• Assessing packaging group of dangerous goods to be packed.
• Assessing and identifying packaging requirements.
• Obtaining approval of packaging by competent/testing authority.
At the end of this Module there are practical workplace exercises (i.e., formative assessment)
covering all Unit Standards in this Module which must be completed and uploaded to the GMLS
LMS, together with your summative assessment. This forms part of your PoE (Portfolio of
Evidence).
Upload/attach/insert this evidence with or on the SUMMATIVE assessment document on the
GMLS platform.
Please ensure that you correctly number and label all your practical workplace exercises
(formative assessments) when you upload/attach/insert them as evidence together with your
summative assessment.
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US 242986 - Accept and process dangerous goods for transportation by air
• Interpret and apply the philosophy underpinning the carriage of dangerous goods by air
• Identify and apply the limitations associated with the carriage of dangerous goods by air.
• Verify the classification of dangerous goods when accepting and processing dangerous goods
for transportation by air.
• Compile and verify documentation.
SO1 INTERPRET AND APPLY THE PHILOSOPHY UNDERPINNING THE CARRIAGE OF DANGEROUS
GOODS BY AIR
Introduction
AC 1 - The term Dangerous Goods is defined as it relates to the transportation of dangerous goods
by air:
Dangerous goods are substances or articles which pose a risk to health, safety or property when
transported, handled, and stored and which are classified according to the criteria in the ICAO
Technical Instructions (ICAO TI) or the IATA Dangerous Goods Regulations (IATA DGR).
Dangerous goods could be substances in solid form, liquid form or gas or they could be articles.
They
are often subject to chemical regulations.
Dangerous goods include materials (substances and articles) that are toxic, poisonous, radioactive,
explosive, flammable, corrosive, oxidising, asphyxiating, bio hazardous (a biological agent or
condition that is a hazard to humans or the environment), pathogenic (means capable of causing
disease), or allergenic (induces allergies, such as pollen). Also included are physical conditions such
as compressed gases and liquids or hot materials, including all goods containing such materials or
chemicals, or may have other characteristics that render them hazardous in specific circumstances.
Dangerous Good may only be shipped with prior approval from an international or national sea
carrier, rail carrier, road carrier or air carrier and only prior to pre-booking a shipment. Such
shipments are also subject to possible surcharges on the freight. It is the shipper's responsibilities
to identify, declare, and provide the necessary and correct shipping documents for shipping
dangerous goods.
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Delays and freight costs due to improper identification, classification and/or incorrect or missing
documentation of dangerous goods will be the responsibility of the shipper. Shipments of
dangerous goods may require more transit time than regular shipments.
Dangerous goods are usually classified with reference to the immediate hazard they pose rather
than the long-term health effects.
Dangerous goods are grouped into nine classes, which may be subdivided into divisions and/or
packing groups.
In the United States of America “dangerous goods" are also known as "hazardous materials" or
"HAZMAT."
The most common dangerous goods are assigned a UN number, a four-digit code which identifies it
internationally: less common substances are transported under generic codes such as "UN1993:
flammable liquid, not otherwise specified", or “UN1954: flammable compressed gas, N.O.S.” The
abbreviation N.O.S. is used to indicate “not otherwise specified.”
As in all potentially hazardous activities, awareness is the key to maintaining safety.
The regulations to be adhered to are the International Civil Aviation Organisation’s Technical
Instructions (ICAO TI) and the International Air Transport Association’s Dangerous Goods
Regulations (IATA DGR).
We have already seen that dangerous goods are defined as articles or substances which are capable
of posing a significant risk to health, safety or to property when transported by air, and when we
discuss dangerous goods in this context, we generally mean cargo. Most dangerous goods are
prohibited in passenger baggage, with a few exceptions.
Hazardous substances in passenger baggage can, however, pose a greater threat to air safety than
cargo as they may easily find their way onto an aircraft unnoticed. The passengers cannot be
expected to have the knowledge of the characteristics of air transport that professionals in the
industry have, or even have an understanding of the potential dangers of articles they carry in their
baggage. Therefore, it is the responsibility of all staff involved to be vigilant to signs of potential
hazards. The operators have the final responsibility to make sure the passengers and/or client are
informed and aware of regulations and technical instructions regarding dangerous goods.
Articles and substances classified as dangerous goods have various limitations imposed on them
depending on how dangerous they are. Some goods are considered too hazardous to transport by
air while others may be limited to transport on cargo aircraft only and some may be acceptable on
both cargo and passenger aircraft. Certain dangerous goods normally not acceptable for transport
by air may be transported under exemption by the state of origin, the state of destination and all
states to be over-flown.
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Any person or company involved in the movement of dangerous goods is responsible for complying
with the dangerous goods regulations.
AC 2 - The history and origin of Dangerous Goods Regulations is described as it relates to the
transportation of dangerous goods by air.
In the early 1950’s, a growing demand was found for transporting hazardous materials and
substances by air. Experience gained by observing other forms of transportation had shown that,
when handled correctly, this could be done with minimal risk provided that the goods were suitably
packaged in limited quantities.
These experiences, in conjunction with the aviation communities’ knowledge of the characteristics
of air transport, resulted in the first industrial regulations on the safe transportation of dangerous
goods. Today we know these regulations as IATA Dangerous Goods Regulations (IATA DGR). These
regulations are however, based on the requirements of Annex 18 of the Chicago Convention and
the subsequent editions of ICAO Technical Instructions (ICAO TI), which are the legal documents
relating to the air transport of dangerous goods.
IATA DGR applies to IATA member airlines, associate members and interline partners so, unless
operating as such, ICAO TI is the document to comply with.
The International Civil Aviation Organisation (ICAO) has the responsibility for regulating the many
technical aspects of international civil aviation, with the main purpose of promoting aviation safety
and security.
Some of the most important multilateral instruments addressing aviation security, hijacking and
terrorism were adopted under the ICAO’s auspices.
The most important legislative function performed by ICAO is the formulation and adoption of
Standards and Recommended Practices (SARPs) for international civil aviation. These are
incorporated into the 18 technical annexes to the Convention on International Civil Aviation (also
known as the Chicago Convention).
Of critical importance to the future of civil aviation and to the international community at large are
the measures taken by ICAO to prevent and suppress all acts of unlawful interference against civil
aviation throughout the world. SARPs for international aviation security were first adopted by the
ICAO Council in March 1974, and designated as Annex 17 to the Chicago Convention.
Annex 17 to the Chicago Convention contains several Standards and Recommended Practices with
the aim of preventing explosives and incendiary devices from being placed onboard aircraft, either
through concealment in otherwise legitimate shipments or through gaining access to aircraft via
cargo handling areas.
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Cargo intended for carriage on passenger flights must be subjected to appropriate security control.
Operators must not accept consignments of cargo on passenger flights unless security has been
accounted for by a “regulated agent” (defined as an agent, freight forwarder or any other entity
who conducts business with an operator and provides security controls that are accepted or
required by the appropriate authority in respect of cargo) or that they are subjected to other
security controls.
The Following is an extract from the IATA website:
“Who is responsible for aviation security?
Overall, it is recognised that airline operators have a primary responsibility for protecting their
passengers, assets, and revenues. States need to ensure that airlines develop and implement
complementary programs compatible with those of the States out of which they operate.
It is important however to remember that security is not only the responsibility of top-level
management or the Head of Security. Security involves everyone and a positive security culture is
essential in promoting and maintaining a secure environment. Positive reinforcement of correct
security actions sends the message throughout an organisation that management believes security
to be a priority.
The ultimate goal is to enhance global security by implementing uniform security measures around
the world, a goal that cannot be achieved without a solid commitment by all concerned.”
Reference: https://www.iata.org/en/publications/newsletters/iata-knowledge-hub/what-you-
need-tohttps://www.iata.org/en/publications/newsletters/iata-knowledge-hub/what-you-need-to-
know-about-aviation-security/know-about-aviation-security/
The “core” of all regulations on transporting dangerous goods is the list of hazardous materials and
substances as recommended by the United Nations “Committee of Experts” and the “International
Atomic Energy Agency”. This list consists of more than 3000 entries describing the hazards and how
they are to be handled. Each entry has been assigned a number known as the “UN number” as a
form of universal index.
The United Nations Economic and Social Council (ECOSOC) has a Sub-Committee of Experts on the
Transport of Dangerous Goods and on the Globally Harmonised System of Classification and
Labelling, responsible for the UN Model Regulations (published as the “Orange Book). They cover
the transport of dangerous goods by all modes of transport except by bulk tanker. These are neither
obligatory nor legally binding on individual countries, however, they have gained a wide degree of
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international acceptance: they form the basis of several international agreements and many
national laws.
These address the classification of dangerous goods, their listing, packing requirements (including
standards for construction, testing, and approval of all kinds of packaging, containers, and tanks),
marking, labelling, loading, documentation, stowage, segregation, emergency response, training,
supervision, construction, and approval of means of transport.
The UN Recommendations do not cover the manufacture, the use, or the disposal of dangerous
goods.
Most countries regulate hazardous materials by law, and they are subject to several international
treaties as well. Even so, different countries may use different class diamonds for the same product.
For example, in Australia, Anhydrous Ammonia UN 1005 is classified as 2.3 (Toxic Gas) with sub risk
8 (Corrosive), where as in the U.S. it is only classified as 2.2 (Non-Flammable Gas).
Laws and regulations on the use and handling of hazardous materials may differ depending on the
activity and status of the material. For example, one set of requirements may apply to their use in
the workplace while a different set of requirements may apply to spill response, sale for consumer
use, or transportation.
The most widely applied regulatory scheme is that for the transportation of dangerous goods. The
United Nations Economic and Social Council (their Sub-Committee of Experts) issues the UN
Recommendations on the Transport of Dangerous Goods, which form the basis for most regional
and national regulatory schemes. For instance, the International Civil Aviation Organisation has
developed regulations for air transport of hazardous materials that are based upon the UN Model
but modified to accommodate unique aspects of air transport.
Individual airline and governmental requirements are incorporated with this by the International Air
Transport Association to produce the widely used IATA Dangerous Goods Regulations.
The Globally Harmonised System of Classification and Labelling of Chemicals or GHS is an
internationally agreed upon system set to replace the various different classification and labelling
standards used in different countries. The GHS will use consistent criteria for classification and
labelling on a global level.
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The basis of all national and international regulations for the safe transport of dangerous goods is
the Recommendations ("Specification") of the "UN Committee of Experts" as published in "The
Orange Book".
The IATA Dangerous Goods Centre of Expertise strives to lead industry efforts to ensure the safe
handling of dangerous goods in air transport, by providing a broad array of technical knowledge,
products, services, and training solutions tailored to meet industry needs. Ensuring that
undeclared dangerous goods do not get on board an aircraft is one of many key objectives of
IATA's dangerous goods program.
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By defining standards for documentation, handling, and training, and by actively promoting the
adoption and use of those standards by the air cargo industry, a very high degree of safety has
been achieved in dangerous goods transport. Working closely with governments in the
development of the regulations, including ICAO and other national authorities, IATA ensures that
the rules and regulations governing dangerous goods transport are both effective and efficient.
The goal is to make it just as easy to ship dangerous goods by air as any other product, so it
removes any incentive to by-pass the regulations.
Information is the key to any safety program, no less for dangerous goods in air transport. Through
its Dangerous Goods Regulations and a comprehensive and effective training program, IATA
ensures that shippers, forwarders, and carriers have the tools and resources to ship dangerous
goods safely.
AC 3 - The importance of continuous training and assessment in the area of Dangerous Goods is
explained in accordance with the International Civil Aviation Organisation regulations
The International Civil Aviation Organisation, a UN Specialised Agency, is the global forum for civil
aviation.
The ICAO works to achieve its vision of safe, secure, and sustainable development of civil aviation
through cooperation amongst its member States.
To implement this vision, the ICAO has established the following strategic objectives:
Safety - Enhance global civil aviation safety
Security - Enhance global civil aviation security
Environmental Protection - Minimise the adverse effect of global civil aviation on the
environment
Efficiency - Enhance the efficiency of aviation operations
Continuity - Maintain the continuity of aviation operations
Rule of Law - Strengthen law governing international civil aviation
Annex 18 deals with the "Safe Transport of Dangerous Goods by Air". In general, it sets down
broad principles, however, one of the Standards requires that dangerous goods are carried in
accordance with the Technical Instructions for the Safe Transport of Dangerous Goods by Air (the
“Technical Instructions”). States are required by Annex 18 to have inspection and enforcement
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procedures to ensure that dangerous goods are being carried in compliance with the
requirements.
Dangerous goods are carried regularly and routinely by air all over the world. To ensure they do
not put an aircraft and its occupants at risk there are international Standards which each State,
under the provisions of the Chicago Convention, are required to introduce into national
legislation. This system ensures governmental control over the carriage of dangerous goods by
air and gives world-wide harmonisation of safety standards.
ICAO has developed a new dangerous goods training programme. The programme consists of a
revised Dangerous Goods Training Manual (Doc 9375P1) and training courses which will assist
States in complying with the broad principles governing the international transport of dangerous
goods by air outlined in Annex 18 and detailed in the Technical Instructions. The programme is
directed towards safety inspectors responsible for dangerous goods, but it would benefit anyone
with a need for knowledge of the detailed provisions in the Technical Instructions. Individuals
who successfully complete a course receive a certificate directly from ICAO.
The Technical Instructions contain a very comprehensive set of requirements; among other
things they provide for the classification of dangerous goods and have a list of them. The list
identifies those goods which are:
a) forbidden under any circumstances
b) forbidden on both passenger and cargo aircraft in normal circumstances but could be carried
in exceptional circumstances subject to exemption by the States concerned
c) forbidden on passenger aircraft but permitted on cargo aircraft in normal circumstances
d) permitted on both passenger and cargo aircraft in normal circumstances
The Technical Instructions require that all dangerous goods be packaged and, in general, restrict
the quantity per package according to the degree of hazard and the type of aircraft (i.e.
passenger or cargo) to be used. There is generally no restriction on the number of packages per
aircraft. The Instructions also give the packing methods to be used and the packaging permitted,
together with the specifications for those packaging and the stringent testing regime they must
successfully complete before they are able to be used. There are requirements for the markings
and labels for packages and the documentation for consignments.
In the Technical Instructions, there is a requirement that every package of dangerous goods be
inspected externally by the operator before carriage to ensure it is in a fit state and appears to
comply with all the relevant requirements. Packages are subject to loading restrictions including
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segregation of those containing incompatible dangerous goods and securement to prevent
movement in flight.
The captain of an aircraft must be informed of what dangerous goods are on board and where
they are located. In the event of an emergency on board (not necessarily involving dangerous
goods) he/she, must inform the appropriate air traffic services unit of what is on the aircraft to
assist the emergency services in their response. The provision in the Technical Instructions allows
the captain to exercise discretion in regard to conveying the information about dangerous goods
since he/she must judge the risks involved in diverting his/her attention (or the co-pilot's
attention) away from controlling the aircraft in emergency situations.
Operators must be aware of what dangerous goods have been loaded on their aircraft. In the
event of an aircraft accident the Technical Instructions require that they must, as soon as
possible, inform the State in which the accident occurred of what was on board and where it was
located. However, since the development and growth of modern technology, most aircraft
manifests are available in electronic format, therefore, it is rate that, depending on the
circumstances and place of an accident, this information may not be available instantly. The
Technical Instructions also require that operators must report to the relevant authority accidents
and incidents involving dangerous goods. States in turn are required to have procedures in place
to investigate such occurrences.
The Technical Instructions contain training requirements which apply to everyone involved in the
shipping, handling and carriage of dangerous goods, cargo, and passenger baggage. These
include the need for refresher training at two-year intervals and the keeping of training records.
There are specific responsibilities for shippers and operators. Shippers must ensure staff
preparing consignments of dangerous goods receive training or that another organisation with
trained staff is used. Operators must ensure their own staff and those of their handling agents
are trained appropriately. Training programmes for operators are subject to approval by the
State of the operator.
AC 4 - Reporting accidents and incidents involving dangerous goods is explained in accordance
with its importance
In the event of an accidental release or imminent accidental release of dangerous goods from a
means of containment, a person who has possession of the dangerous goods at the time of the
accidental release must make an immediate report of the accidental release. This immediate
report is also known as the initial report, as must be followed up within 21 days by a written
report.
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For air transport, a person who has possession of dangerous goods at the time a “dangerous
goods accident” or a “dangerous goods incident”, as defined in the ICAO Technical Instructions,
occurs on board an aircraft, at an airport or at an air cargo facility must immediately report it to
the appropriate authorities including the nearest Regional Civil Aviation Authorities, the
Department of Transport, the carrier (airline) and the airport operator (ground handling).
RISK MA
It is essential in the interest of a safe aviation environment that all dangerous goods accidents,
incidents, undeclared and mis-declared dangerous goods are timeously reported as per the
South African Department of Transportation, Civil Aviation Act, 2009 (Act no 13 of 2009), Civil
Aviation Regulations of 2011, Part 92, (92.00.22) (92.00.25) and (92.00.26) as detailed below.
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Dangerous Goods accident and incident reporting (Part 92.00.22), pg. 623-624 of the SACAA
Regulations
RISK MA
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Notification of undeclared or misdeclared dangerous goods (Part 92.00.25): pg. 624-625 of the
SACAA Regulations
Retention of
documents
RISK MA
(Part 92.00.26): pg. 625 of the SACAA Regulations
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AC 5 - The parties to which Dangerous Goods Regulations apply are identified as it relates to the
transportation of dangerous goods by air
Any company or individual who are involved with the transportation of dangerous goods are
responsible for complying with the dangerous goods regulations. Below are the definitions as set
out in the IATA DGR.
Operator / Carrier - “A person, organisation or enterprise engaged in or offering to engage in an
aircraft operation.”
Freight forwarder - “A person or organisation who offers the service of arranging the transport
of cargo by air”.
Consignee - “Any person, organisation or government which is entitled to take delivery of a
consignment”
Air freight is almost always multi-modal. This is because it needs to be transported in some
manner (usually by road) to a departure airport and it also needs to be uplifted from its
destination airport.
Accidents can occur while dangerous goods are being transported, while they are being handled,
or during temporary storage pending transport. In the event of a transportation accident
involving dangerous goods, there is a requirement to report the accident. RISK MA
Reporting of a dangerous goods incident requires an initial (immediate, or as soon as practicable)
report and a later written report, which must be done within 30 days of the incident date.
Reports must be made to the appropriate authorities, the person’s employers, the consignor of
the goods, and, for a road vehicle, the owner, lessee, or charterer of the road vehicle.
In accordance with South African National Standards SANS 10231 – (2010): Transport of
dangerous goods – Operational requirements for road vehicles.
All accidents involving Dangerous Goods vehicles must be reported to the National Department
of Transport (NDOT).
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Extract from page 8 of SANS 10231
“As soon as practicable” means as soon as possible after the incident, without interfering with
the emergency response procedures.
“Dangerous goods incident” means any incident during the transportation or storage of
dangerous goods which involves leakage, spillage, fire or other unplanned occurrence of
dangerous goods or risk thereof and that caused, or, but for intervening events, could have
caused-
(a) the death of an individual, unreasonable bodily injury to an individual that interferes with his or
her health or comfort, or unreasonable harm to the health of an individual
(b) significant and unreasonable damage or harm to property or the environment
“Dangerous situation” means a situation where there is an imminent and high risk to people,
property, or the environment from dangerous goods.
For Major Hazard Facilities, “Major incident” means an incident, including:
• an emission of a Schedule 1 substance
• a loss of containment of a Schedule 1 substance
• a fire
• an explosion
• a release of energy
that causes serious harm to people, property, or the environment.
“Near miss” means an unplanned event that did not result in injury, illness, or damage but had
the potential to do so.
“Operator” means the person who operates the dangerous goods site or pipeline.
“Security Risk Substances” (SRS) means substances that could be used in the illegal manufacture
of explosives, and therefore pose a risk to the security of people and property.
“Unexplained loss” of Security Risk Substances (SRS) means any loss or apparent loss of the SRS
that cannot be explained by product density changes, spillage, calibration variances, the effects
of humidity, or by other like matter.
Examples of incidents that are reportable are:
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• any incident where explosives containers can be shown to have fallen from a vehicle while it
is in transit
• any incident where a bulk container carrying explosives or dangerous goods is subjected to
impact - typically through roll-over or collision.
• an unexpected fire or explosion (including sabotage) involving or impinging on explosives or
dangerous goods containers or storage facilities
• an incident where quantities emitted exceed the minimum reporting parameters
• small numbers of packages of security risk substances (SRS) are found on the roadside (with
or without contents) and their origins remain undetermined
• a stock-take of explosives or security risk substances (SRS) is conducted and there are
discrepancies between the expected total and actual total on hand
• there is a security breach (e.g. theft of SRS or explosives)
• explosives being left unattended
• premature explosion of an explosives charge
• incidents related to malfunction of safety critical and or non-critical equipment that could
have a potential for a major incident, particularly at major hazard facilities
• failure of refrigeration systems for ammonia or LNG (liquid nitrogen gas) storage
• failure of systems providing inert blanket in an explosive environment
• temperature sensor failure in exothermic reaction processes involving hydrogen or
formaldehyde
• near misses at major hazard facilities, as these can be indicative of a failure with the facility’s
safety management system
Examples of incidents that may not be reportable are: RISK MA
• small numbers of packages of dangerous goods (excluding explosives) are found on the
roadside (with or without contents) and their origins remain undetermined
• an escape of dangerous goods that is expected during normal operations, maintenance, or
transfers
• boxes of explosives at an explosives site falling from a forklift, sustaining minor damage, with
no leakage and no subsequent injury, property damage, or offsite effect
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• misfired shots not arising from product malfunction
• vehicle traffic incidents where the containers, their fittings and the dangerous goods remain
intact and have not been subjected to impact
• dangerous goods packages falling from forklift, sustaining damage and minor leakage (i.e.
below reportable losses) with no subsequent injury, property damage, or off-site effect
AC 6 - The shipper's roles and responsibilities are identified and explained in line with
organisational and legislative regulations
We have already seen that any person or company involved in the movement of dangerous
goods is responsible for complying with the dangerous goods regulations; However, the shipper
has the greatest responsibility. Before the shipper offers dangerous goods to be transported as
air cargo, they must ensure that the transport of the goods by air is not forbidden, which will be
detailed under section 4 of the DGR which is for Identification of the goods. Please see the below
example
UN / Proper Shipping Name/Description Class or Div. (Sub Passenger and Cargo
ID no.
Hazard) Aircraft
1950 Aerosols, flammable, containing 2.1 (8) Forbidden
substances in Class 8, Packing Group II
The shipper’s declaration must be filled out and signed by the shipper according to the IATA
regulations.
Two copies of the Shippers Declaration for Dangerous Goods must be attached to the air waybill
(stapled to the back of the air waybill) and both copies must be signed by the shipper.
It is a violation of law to tender cargo containing dangerous goods that have not been properly
declared, identified, packaged, marked, labelled, or documented.
It is the shipper’s responsibility to ensure this has been done and that all regulations have been
complied with.
Failure to properly identify a dangerous goods shipment can result in penalties or even
imprisonment. The shipping of hazardous materials can pose a serious danger to anyone who
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might come in contact with the shipment. There is also the danger of damage to property and
the environment
CASE STUDY:
ValuJet Airlines Flight 592:
CNN Interactive article:
ValuJet 592 crash to be blamed on oxygen canisters
November 15, 1996
Web posted at: 4:20 p.m. EST
From Correspondent Susan Candiotti
MIAMI (CNN) -- Investigators have concluded the cargo bay fire that caused the deadly crash of ValuJet
Flight 592 originated in volatile oxygen canisters mistakenly labelled and improperly packed, according to
a highly placed source.
The oxygen canisters were stored in the cargo bay. Federal investigators said many of the canisters were
missing safety caps, and a cargo manifest listed them as being empty when they were not.
"It was definitely not an electrical spark that ignited the fire," the source told CNN. "The canisters started
the fire. There was nothing in the cargo bay that could have ignited the canisters."
The National Transportation Safety Board begins a week of hearings Monday on the May 11 disaster that
killed all 110 people aboard the Miami-to-Atlanta flight. The hearings will be used as a forum to pin blame
to the canisters.
The canisters have been considered a prime culprit since shortly after the plane plunged into the
Everglades, a disaster that led to the carrier's grounding for 3 1/2 months and a sharp curtailment of its
operations after it resumed service this fall.
The Department of Transportation imposed an emergency ban on the shipment of oxygen canisters after
the crash.
During tests, this month at a Federal Aviation Administration facility in New Jersey, oxygen canisters
similar to those packed on Flight 592 were ignited and quickly reached temperatures of well over 1,000
degrees Fahrenheit.
It remains unclear whether the fire ignited before or after take-off. As previously revealed from the
cockpit voice recorder, smoke and fire in the passenger cabin were reported about six minutes after the
DC -9 left
Miami International Airport. RISK MA
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About three minutes after fire was discovered, the plane nose-dived into the Everglades. Sources say the
blaze burned through the jet's flight control cables that help steer the aircraft. The cables run the length
of the aircraft above the front cargo bay where the fire erupted.
The ValuJet DC-9 that crashed had no smoke detectors or fire- suppression system in the cargo hold.
CNN has learned the NTSB will also re-issue recommendations that smoke detectors and fire suppression
systems be installed in all Class D aircraft.
On Thursday, the FAA announced it was in the process of writing a rule to mandate those systems. It
would cover the following aircraft: 727s, 737s, DC-8, DC-9, DC-10, MD 80s, and Airbus 320s. The order
would cover roughly 2,800 older aircraft at an estimated cost of $500 million.
Source: http://edition.cnn.com/US/9611/15/valujet/index.html
Image: https://tailstrike.com/database/11-may-1996-valujet-592/
Discuss: Where did the shipper fail in their responsibilities regarding dangerous goods, and could
this occurrence have been avoided?
The shipper’s responsibilities are as follows:
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• The shipper must ensure that their employees are appropriately trained so that they may carry
out their functions for which they are responsible with regard to the transport of RISK
MA dangerous goods by air.
• The shipper shall limit all packages containing dangerous goods to the materials and
quantities authorised for air transportation as per the International Air Transport Association
(IATA) Dangerous Goods Regulations (DGR). This includes making sure that the articles and
substances are not prohibited.
• The shipper shall ensure that each shipment requiring a Shipper's Declaration of Dangerous
Goods under the IATA Dangerous Goods Regulations is accompanied by properly executed
declaration documents in conformity with the requirements of such IATA Regulations.
• The shipper must ensure that the substances and articles are appropriately identified,
classified, packed, marked, labelled, documented in accordance with the IATA dangerous
goods regulations.
Note from the IATA DGR – 1.3.2 (d) “Where a shipper does not have trained staff, the
“relevant persons” may be interpreted as applying to those employed to act on the shipper's
behalf and undertake the shipper's responsibilities in the preparation of the consignment.
However, such persons must be trained as required by Subsection 1.5;”
• The shipper shall also ensure, and the shipper hereby certifies, that, before tendering any
shipment containing dangerous goods to carrier, the contents of this consignment are fully
and accurately described on the shipping papers by proper shipping name PSN); are not
prohibited for transport by air by the DG Regulations; and are properly classified, packaged,
marked, and labelled, and in proper condition for carriage by air as required by the
dangerous goods regulations.
The shipper must declare that all of the applicable air transport requirements have been met.
This shall apply regardless of the routing or transportation mode by which the shipment is
transported. The carrier reserves the right to reject any shipment containing any known or
suspected dangerous goods.
The Proper Shipping Name (PSN) must be used for transport purposes on the documentation and
the labelling. The Proper Shipping Name is that name which appears in the IATA Dangerous
Goods Regulations (DGR) in bold text; any other text is only descriptive and is not part of the PSN.
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Please see the following example, Adhesives is the PSN, excluding the descriptive additional text
(containing flammable liquid)
UN / ID no. Proper Shipping Name/Description
1133 Adhesives
Containing flammable liquid
AC 7 - The operator's roles and responsibilities are identified and explained in line with
organisational standards and practices RISK MA
The South African Civil Aviation Authority (SACAA) was an agency of the Department of
Transport (DoT) and as a result, its activities are governed by a performance agreement signed
between the Board of Directors and the Minister of Transport. It is now a standalone authority.
Its mandate, defined more fully in the Civil Aviation Act No. 13 of 2009, can be summarised as
follows:
“Regulating the civil aviation industry to ensure security and safety by complying with
International Civil Aviation Organisation (ICAO) and taking into consideration the local context.”
The South African Civil Aviation Authority (CAA) was established on 1 October 1998 following the
enactment of the South African Civil Aviation Authority Act, No.40, in September of the same
year. This act has since been repealed by the Act of 2009
The Act provided for the establishment of a stand-alone authority charged with promoting,
regulating, and enforcing civil aviation safety and security.
The creation of the CAA reflected the Government's then priorities of policy development,
economic restructuring, addressing social inequalities and reducing the burden on the general
taxpayer by expanding the application of the "user-pays" system.
A further motivation in setting up a stand-alone civil aviation regulatory authority was done in
line with international trends in the aviation world where more and more states implemented
this option.
The South African Civil Aviation Authority (CAA) is governed by a Board of Directors appointed by
the Minister of Transport and is representative of aviation industry, management, and business
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expertise. Through a Performance Agreement with the Minister, the Board is accountable for the
performance of the Authority in carrying out its statutory functions and achieving objectives. The
NDOT will monitor the activities of the Authority.
The management of the CAA has been structured along three core responsibility levels:
The Strategic Management level which constitutes the Executive Management
The Project Management level which together with the Executive Management constitutes
Senior Management
The Operational level which is organised according to technical departments
The key role for the Executive is the strategic leadership of the organisation and the co-ordination
of policy formulation. The Executive’s function is to develop and maintain positive links with the
industry and to co-ordinate the CAA’s international relations with organisations such as the SADC,
ICAO, AFCAC, and other CAAs.
The Project Management level co-ordinates the technical activities of the key areas of oversight:
- aircraft, airports, airspace, and personnel. Oversight of Operations is coordinated by
Personnel and Aircraft, respectively. RISK MA
Technical departments report to the areas of oversight relevant to their specific activities. This
means that depending on the activity, a technical department may report to a different oversight
area. Within each area of oversight, the key responsibilities are to set, monitor and enforce
standards, as well as to promote safety.
The roles and responsibilities of the CAA revolve around the following nine areas of oversight:
Airport oversight involves the certification of airports and heliports and monitoring civil and
electrical engineering matters in relation to infrastructure on and around airports such as,
lighting, navigational aids, their repair, and maintenance.
Airworthiness oversight is concerned with ensuring that all aircraft that fly in our airspace
are airworthy to conduct such flights (fit for flight).
Certification oversight deals with all certification activities in relation to aircraft products
and parts. This includes the granting of permission for new aviation products to be imported
into the country.
Personnel oversight involves examining, licensing, and training of aviation personnel. All
relevant training and services are monitored to ensure that personnel and standards meet
international standards.
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Oversight of Operations is carried out in terms of monitoring information contained in the
operations manuals of every operator to ensure compliance with relevant legislation.
Airspace oversight ensures the effective management and provision of air traffic services
through the allocation of airspace by the statutory consultative body, the National Airspace
Committee (NASCOM).
Accidents and incidents investigation, while technically not an area of oversight, is a key
activity of the CAA carried out on behalf of Government. Investigations are conducted to
determine the cause of aircraft accidents, and to recommend measures to prevent
recurrence. Other key functions also include monitoring of trends regarding aircraft
accidents and incidents, identification of potential problem areas, possible safety
deficiencies and proposing safety recommendations to the CAA.
The Flight Inspection division does not fall under a specific area of oversight. The function of
this division is to calibrate the radio navigational aids used by aircrafts to ensure accuracy
and reliability. Many of these tests are performed on the ground, but to ensure that the
radio signals are interpreted accurately by aircraft receivers, it is also necessary to perform
airborne tests on the ground equipment.
The Information Services division provides aeronautical information to the industry and also
meets the information needs of the organisation.
The establishment of a stand-alone authority has resulted in the CAA widening its oversight
functions and becoming more visible in the industry. Entering the corporate sphere accelerated
the introduction of professionalism, accountability, and integrity in the inspectorate and indeed
the whole organisation.
When it was still part of the Department of Transport, the CAA fell within the huge government
bureaucracy. However, the setting up of a self-funding authority has resulted in the authority
becoming more accessible and accountable to its stakeholders.
Since attaining our democracy, the CAA has rightfully claimed its position as a regional leader in
the aviation regulatory sector in our region, the Southern African Development Community (SADC).
The CAA has hosted dozens of regional meetings and conferences since 1994 and is in the driving
seat of regional efforts to harmonise aviation regulations in the region and improving the level of
aviation surveillance in member states.
Also, in 2003, South Africa was elected to be a member of the International Civil Aviation (ICAO)
council, a move that sees the country participating at the highest forum with regards to aviation
matters.
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The CAA is funded by a combination of direct and indirect fees and Government funding of the
investigation of aircraft accidents.
Operators include airlines, cargo terminal operators and ramp handling operators. Airline staff
requires different training from cargo terminal operators, who in turn require different training
from ramp handling operators.
The operators have a responsibility to ensure that staff undergoes intensive Dangerous Goods
Training courses so that they can provide proper acceptance, storage, loading, inspection, and
provision of information criteria. These must be accurately met and strictly adhered to so that
ground handling staff, aircraft crew, passengers and cargo are never put at risk.
The responsibilities of the operator include:
Complete a dangerous goods check list
Check and verify the information provided on Shipper’s Declaration for DG and on AWB
complies with DGR.
Check each outer packing to make sure package is in good condition.
Verify that the general packing requirements and the specific packing instruction have been
followed.
Check all required marking and labelling has been properly marked/affixed for each package.
Check whether the shipment needs any additional handling.
Check and verify if all state and /or operator variations are applied.
Check the flight booking for specific dangerous goods (e.g. Cargo Aircraft Only).
Check whether special documents are attached to AWB or shipment if required (e.g. form
for infectious substances).
Identify hidden dangerous goods from export shipments
Prepare and sign NOTOC (Notification to Captain) for all dangerous goods.
Send pre-advice to destination for special handling information.
Observe and ensure the segregation of Dangerous Goods requirements.
Store Dangerous goods as according to IATA DGR requirements.
Secure Dangerous goods to prevent any movement during transport which would change
the orientation of the package.
Dangerous goods stowage inside aircraft must be based on IATA DGR & carrier’s
requirements.
Retain/file all related documents.
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SO2 - IDENTIFY AND APPLY THE LIMITATIONS ASSOCIATED WITH THE CARRIAGE OF
DANGEROUS GOODS BY AIR
AC 1 - Dangerous Goods forbidden (including the incompatibility of dangerous goods) in aircraft
under any circumstances are identified and described according to the International Civil Aviation
Organisation regulations.
The different types of dangerous goods are:
Dangerous Goods Totally Forbidden
Forbidden unless exempted (National Authority of the origin country may grant permission
depending on the type of shipment.)
Carried by passenger aircraft or cargo aircraft
Carried by cargo aircraft only (CAO)
Excepted Quantities / Limited Quantities
Treated as non-Dangerous Goods (Items, which do not come under the classification of the 9
classes)
Articles and substances classified as dangerous goods have various limitations imposed on them
depending on how dangerous they are.
Some goods are considered too hazardous to transport by air while others may be limited to
transport on cargo aircraft only and some may be acceptable on both cargo and passenger aircraft.
Certain dangerous goods normally not acceptable for transport by air may be transported under
exemption by the state of origin, the state of destination and all states in the flight path.
Dangerous goods forbidden in aircraft under any circumstances are:
Explosives which ignite or decompose when subjected to a temperature of 75ºC (167ºF) for
48 hours.
Explosives containing both chlorates and ammonium salts.
Explosives containing mixtures of chlorates with phosphorous.
Solid explosives which are described as extremely sensitive to mechanical shock.
Liquid explosives which are described as moderately sensitive to mechanical shock.
Any article or substance, as presented for transport, which is liable to produce a dangerous
evolution of heat or gas under the conditions normally encountered in air transport.
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Flammable solids and organic peroxides having, as tested, explosive properties and which
are packed in such a way that the classification procedure would require the use of an
explosives label as a subsidiary risk label.
Extract from the IATA DGR from section 2.1.1:
“2.1.1 Dangerous Goods Forbidden in Aircraft Under Any Circumstances
Any article or substance which, as presented for transport, is liable to explode, dangerously
react, produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive
or flammable gases or vapours under conditions normally encountered in transport must not be
carried on aircraft under any circumstance.”
The relevant regulations such as the IATA Dangerous Goods Regulations provide information on
storage compatibility and transportation and segregation of different classes of dangerous goods
and these must be consulted. Load compatibility charts also exist and can be consulted.
Incompatible goods must be segregated from one another during storage and transport. For the
purposes of segregation, two substances or articles are considered mutually incompatible when
their stowing together may result in undue hazards in the case of leakage, spillage, or any other
accident.
The extent of the hazard arising from possible reactions between incompatible dangerous goods
may vary and the segregation arrangements required shall also vary as appropriate. In some
instances, such segregation may be obtained by requiring certain distances between
incompatible dangerous goods. Intervening spaces between such dangerous goods may be filled
with cargo compatible with the dangerous substances or articles in question.
Radioactive materials (class 7) and explosives (class 1) should be deemed incompatible with all
other dangerous goods.
Please see the following extract from the IATA DGR – this is the Segregation table used to
determine if two or more classes may be packed together.
Compatible goods
Two or more goods are compatible provided that their interaction does not give rise to any of
the following outcomes:
➢ Harm to persons, property, or the environment.
➢ Fire or explosion, or generation of toxic, flammable, or corrosive vapours/gases.
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➢ Accelerate the combustion of other goods/liquids in the event of fire.
➢ Release of the contents results in the premature degradation/corrosion of other dangerous
goods or combustible liquids' packaging/means of containment.
➢ During the event of a fire/spill/release, the interaction of dangerous goods/combustible liquids is
incompatible with fire-fighting or dispersal media.
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Some materials are water reactive and should be stored away from other goods that are reliant on
water or foam as a firefighting/dispersal/suppression media).
Compatible goods guidance notes include:
• In most cases materials of the same class will be compatible. However, not all materials with
different UN Numbers will always be compatible. The MSDS should be checked.
• In many cases the goods will be compatible. Must check for subsidiary risk compatibility.
Please check the Material Safety Data Sheet (MSDS).
• If one of the goods present is also a 'fire risk substance' (one of class 2.1, 3, 4, 5, a
combustible liquid or has a subsidiary risk of one of these) or elevated temperature goods,
segregation is required by at least 3 m or more. Sub-risk MUST be considered. Other
exceptions apply. Please check the MSDS.
• Not all class 5.1 goods are compatible as follows:
a. Ammonium nitrate is not compatible with tetranitromethane, dichloroisocyanuric acid,
any bromate, chlorate, chlorite, hypochlorites, or chloroisocyanurate, or any inorganic
nitrate; and
b. Calcium hypochlorite (and its mixtures) are incompatible with dichloroisocyanuric acid,
ammonium nitrate, or any chloroisocyanurate.
• Organic peroxides are highly reactive materials. Please check the MSDS to ensure
compatibility.
• Where one of the goods to be stored together is a concentrated strong acid and the other a
concentrated strong alkali, they should be deemed incompatible.
• Class 4.3 goods must not be stored next to goods that are in a solution containing water, or
where water or foam is the chosen fire-fighting/spill/leak dispersal or suppression media for
the storage area.
• Toxic gases ammonia and chlorine must be segregated due to risk of explosion. It is
important to refer to the MSDS for incompatibilities within this class division. It is strongly
recommended that each different toxic gas (Class 2.3) be segregated unless information in
the MSDS says otherwise.
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AC 2 - Dangerous Goods Forbidden unless exempted are identified and described according to the
International Civil Aviation Organisation regulations
Chapter 4 of Annex 18 of the International Civil Aviation Organisation Technical Instructions (TI)
covers “Limitation on the Transport of Dangerous goods by Air” and this includes Chapter 4.2
which covers Dangerous goods forbidden for transport by air unless exempted.
The dangerous goods described hereunder shall be forbidden on aircraft unless exempted by the
States concerned or unless the provisions of the Technical Instructions indicate they may be
transported under an approval issued by the State of Origin: RISK MA
a. articles and substances that are identified in the Technical Instructions as being forbidden for
transport in normal circumstances; and b) infected live animals.
Limitations on dangerous goods acceptable for air transport are to be found in the lists based on
the recommendations of the Committee of Experts in IATA DGR (International Civil Aviation
Association Dangerous Goods Regulations) or the ICAO TI (International Civil Aviation
Organisation Technical Instructions).
Remember the IATA DGR will be the more restrictive than the ICAO TI, therefore when packing
dangerous goods for air transport the IATA DGR will have to be met.
AC 3 - Hidden dangerous goods are identified and listed according to the International Civil
Aviation Organisation regulations.
Besides other threats such as hijacking and sabotage, the safety of civil aircraft is threatened by
substances carried on board in passengers’ baggage (whether in the cargo hold or in the cabin)
or shipped as cargo. A serious threat is the increased number of dangerous goods produced for
use by all manner of legitimate businesses and tendered for shipment by air. Although the list of
dangerous goods that are permitted to be carried by air is regularly revised, it is a challenge for
even the most careful of shippers and carriers to stay up-to-date on dangerous goods and the
safest methods of handling, storing, and transporting them.
There is a difference between ‘hidden’ dangerous goods and ‘undeclared’ dangerous goods. In
the case of ‘undeclared’ dangerous the shipper is aware of the hazard and yet does not declare it,
or misdeclares the cargo as something which it is not. This is a deliberate and unlawful act.
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Hidden dangerous goods may be innocently taken on board an aircraft or shipped as cargo when
the shipper/agent/operator ships the goods but is not aware of the hidden or concealed danger.
Hidden dangerous goods are a huge threat to the safety of the aircraft, passengers, and crew.
These goods are not packed, labelled, stored, or controlled in any way and could pose a serious
threat.
Hidden dangerous goods are articles or substances which may contain hazardous
items/substances/properties which are not apparent. Below examples are from the list of hidden
dangerous goods from the IATA DGR:
Aircraft on Ground (AOG) spares
Battery-powered devices
Breathing apparatus
Camping equipment
Chemicals
Consolidated shipments
Diagnostic specimens
Expeditionary Equipment
Frozen fruit and vegetables
Gas cylinders
Household goods
Medical supplies
Personal effects
Swimming pool chemicals
Vaccines
To tackle the problem of hidden dangerous goods inside air cargo consignments, The International
Civil Aviation Organisation (ICAO) has imposed a requirement that staff of freight forwarders,
regardless of whether they are involved in the direct processing of dangerous goods, should
receive dangerous goods training commensurate to their functions. This requirement has been
stipulated under Chapter 4 of Part 1 of ICAO Technical Instructions (TI) for the Safe Transport of
Dangerous Goods by Air and Section 1.5 of the IATA DG Regulations (DGR).
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On the 28th November 1987 South African Airways Flight SA 295, a Boeing 747, crashed into the
Indian Ocean near Mauritius after a fire in the cargo hold. All 159 aboard died. It is suspected that
undeclared dangerous goods in the cargo hold started the fire.
In 1996, a major passenger airline carried undeclared dangerous goods - calcium hypochlorite and
liquid bleach - on a flight from California to Jamaica. Upon arrival, airport personnel discovered
smoke coming from the aircraft’s cargo doors and encountered toxic fumes when they opened the
cargo compartment.
The box of undeclared dangerous goods was leaking and burst into flames shortly after the airport
personnel removed it from the cargo hold.
In 1998, an undeclared shipment of electric storage batteries (considered “wet” because they
contain either electrolyte acid or alkaline corrosive battery fluid) burst into flames whilst on route
by truck to an airport, where it had been scheduled to be placed aboard a major passenger aircraft.
In 1999, a major cargo carrier transported an undeclared shipment of liquefied petroleum gas
from Portland, Oregon, to New York on a regularly scheduled cargo flight. One day after arriving in
New York, the package burst into flames at the carrier’s sorting facility.
CLASS EXERCISE:
You the student needs to look in your day-to-day activities/surroundings and identify 10 hidden
dangerous goods. This will be discussed in class.
AC 4 - Dangerous goods carried by passengers and crew are identified and described according to
the International Civil Aviation Organisation regulations
When we discuss dangerous goods in this context, we generally mean cargo, as dangerous goods
are prohibited in passenger baggage, with a few exceptions. Hazardous substances in passenger
baggage can, however, pose a greater threat to air safety than cargo as they may easily find their
way onto an aircraft unnoticed. The travelling public cannot be expected to have the knowledge of
the characteristics of air transport that professionals in the industry have, or even of the potential
dangers of articles they carry in their baggage.
Therefore, it is the responsibility of all staff involved in passenger and cargo handling, as well as
aircrews, to be vigilant to signs of potential hazards. The operator/carrier has the final
responsibility to make sure the passengers are informed and aware of regulations and technical
instructions.
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There are limitations and exclusions to dangerous goods carried on an aircraft. These are goods
which have been declared and of which the airline/airline staff are aware, and include such
dangerous goods carried on aircraft:
• by passengers and crew.
• as part of the airworthiness or operating equipment.
• in cargo.
Items of airworthiness or operating equipment which are also dangerous goods (e.g. fire
extinguishers, life-rafts, batteries, aerosols, etc.) are excluded from the requirements, except for
replacements which must comply, in most respects, with the normal provisions for transport as
dangerous goods (such as spares, or replacements shipped as cargo and which are classified as
dangerous goods).
Section 2.4.1 of the International Civil Aviation Organisation’s Technical Instructions (ICAO TI)
states that articles and substances which would otherwise be classed as dangerous goods, but
which are required to be aboard the aircraft in accordance with the pertinent airworthiness
requirements and operating regulations, or for those specialised purposes identified in the
Technical Instructions, shall be excepted from the provisions of Annex 18.
Section 2.4.3 of the International Civil Aviation Organisation’s Technical Instructions (ICAO TI)
states that specific articles and substances carried by passengers or crew members shall be
excepted from the provisions of Annex 18 to the extent specified in the ICAO Technical
Instructions.
Passengers and crew can have certain items of dangerous goods in their baggage and, to a certain
extent, this is acceptable. These include alcoholic beverages, medicinal and toilet articles
(including aerosols, hair spray, deodorant, shaving foam, etc.), safety matches or lighter and gas-
powered hair curlers. Some of these items are subject to restrictions on quantity and where they
can be packed (e.g. in carry-on baggage, checked baggage, etc.). Individual airlines provide
information for passengers about dangerous goods. Dangerous goods, as such, are not permitted
in passenger baggage. It would not be proper to discriminate against disabled passengers who
need electric wheelchairs, so these are allowed. Some forms of cosmetics such as hairspray and
perfume may be hazardous, but it would be very difficult to get passengers to abstain from
bringing these on their journeys (the duty-free trolley onboard the aircraft is packed with
perfumes).
On the next page, there is a table taken from IATA DGR that indicates what is acceptable and to
what extent.
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The major problem in this case is to locate the passenger who is carrying unacceptable articles. It
is mainly up to passenger handling staff to be on the lookout for signs of potential hazard as it
would be unethical or illegal to search the baggage.
Examples of potentially hazards goods could be:
Camping or hiking equipment may contain butane or flammable liquids, matches,
emergency flares and many other dangerous articles.
Toolboxes may contain some forms of measuring equipment which may be radioactive.
There may be gas-powered soldering irons, explosives, adhesives, corrosives, resins, paints
solvents etc.
Diving equipment includes the breathing apparatus; divers may be carrying diving torches
that generate extremely high heat when operated in air.
Motion picture and stage articles may involve articles for special effects that may contain
explosives or flammables.
Automobile accessories which may include substances for corrosive protection and fuel
additives such as nitromethane.
Here is an example of a notice that would be found at an airport as a means of educating
passengers regarding the possible carriage of dangerous goods:
RISK MA
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From website: https://airraro.com/dangerous-goods/?doing_wp_cron=1655569989.1291120052337646484375
Most passengers cannot be expected to be familiar with the normal conditions in an aircraft such
as the changes in temperature and pressure. Nor can they be expected to always consider the
dangers inherent in the everyday objects we all surround ourselves with. A large supply of
matches on a pantry shelf does not seem particularly lethal but packed in a bag on board an
aircraft it can be very hazardous. Information about dangerous goods in baggage must be
provided to the passengers.
As a minimum, this must consist of placards at check-in counters and having it printed on tickets
or ticket folders. Though it might prove difficult or impractical in a congested situation it is good
practice for all check-in staff to ask each passenger if they are carrying any of the articles on
these placards.
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RISK MA
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Provisions which have become mandatory after 2013 include passengers who are able to check in
remotely (e.g. via the internet) being unable to complete the check -in process until they have
indicated that they have understood the restrictions on dangerous goods in baggage. This will also
be extended to include passengers who are able to check in at an airport without the involvement
of any other person (e.g. automated check-in facility) being unable to complete the check-in
process until they have indicated that they have understood the restrictions on dangerous goods
in baggage. New recommendations include that operators should provide information about
dangerous goods which passengers are permitted to carry - either via their websites or in some
other way.
AC 5 - Dangerous goods that are the property of the operator are identified according to the
International Civil Aviation Organisation regulations
Section 2.4.1 of the International Civil Aviation Organisation’s Technical Instructions (ICAO TI)
states that articles and substances which would otherwise be classed as dangerous goods, but
which are required to be aboard the aircraft in accordance with the pertinent airworthiness
requirements and operating regulations, or for those specialised purposes identified in the
Technical Instructions, shall be excepted from the provisions of Annex 18.
A permanent approval is required in order for an operator to be allowed to carry dangerous goods
with the exception of four instances.
These are:
1. Articles and substances required for the airworthiness of the aircraft.
2. Catering or cabin service supplies.
3. Veterinary aids or humane killers for animals.
4. Medical aids for a patient.
Articles and substances required for the airworthiness of the aircraft under (1 above) includes such
things as oxygen and fire extinguishers. Catering or cabin service supplies (2 above) includes such
things as dry ice and alcohol (whiskey is classified as dangerous goods).
Medical aids for a patient (4 above) can include many articles, the most common being oxygen or
compressed air, and electric wheelchairs.
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Other dangerous goods that are the property of the operator are such goods that in other
circumstances would be forbidden on aircraft, but their presence is required according to security
or operating regulations, such as:
• aircraft equipment
• aircraft spares
• carbon dioxide solid (dry ice) used in food and beverage service
• consumer goods, such as aerosols, alcoholic beverages, perfumes, colognes
etc
The provisions of the Dangerous Goods Regulations (DGR) do not apply to articles and substances
which form an integral part of the aircraft equipment such as fire extinguishers, oxygen bottles,
life rafts, first aid kits etc. or consumer commodities for use or sale on the aircraft. Dangerous
goods to provide medical aid to passengers are also considered as the operator’s property.
AC 6 - Dangerous goods that can be carried in accepted quantities are identified and described
according to the International Civil Aviation Organisation regulations
Note: The heading above (as taken from the SAQA US) is incorrect and should read “Dangerous
goods that can be carried in excepted quantities....” and not “accepted quantities...”
Very small quantities of dangerous goods may be transported in such a manner that they may be
excepted from the marking, labelling and documentation requirements. This is known as
“Dangerous goods in Excepted Quantities” and is only applicable to goods acceptable on
passenger aircraft.
The following provisions must also be met: (summary from the IATA DGR)
Substances of division 2.2 without a subsidiary risk
Substances of class 3, all packing groups
Substances of class 4, packing groups II and III but excluding all self-reactive substances
Substances of division 5.1, packing groups II and III
Substances of division 5.2, only when contained in a chemical kit or first aid kit
Substances of division 6.1, all substances in this division, except those having an inhalation
toxicity requiring packing group I
Substances of class 8, packing groups II and III but excluding Gallium and Mercury
Substances and articles of class 9
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Note: Articles and substances in the above classes, divisions and packing groups may also be
radioactive materials in excepted packages
The concept “excepted quantities” cannot be applied to passenger baggage or airmail. There is
also an extensive list of goods not acceptable as cargo in excepted quantities (i.e. the opposites of
the above list).
When we speak of “very small quantities” we are dealing with, for instance, 1g or 1mL for solids or
liquids of packing groups I or II in division 6.1 or requiring a subsidiary toxic label, or 30g or 30mL
for other substances. For non-flammable gases with no subsidiary risk we are limited to
receptacles with a water capacity of 30ml.
The combination of packages in an outer package allows, with a few exceptions: RISK MA
Packing group I – 300g or 300mL
Packing group II – 500g or 500mL
Packing group III – 1L or 1kg
Always refer to ICAO TI or IATA DGR for details.
Though excepted quantities do not require the regular labelling of dangerous goods they do
require labels stating that they are “Dangerous Goods in Excepted Quantities” stating class and
UN-number of the contents. When packing these goods, it is not necessary to use the approved
packages normally required for dangerous goods. It is sufficient to use “good quality” packaging
according to the specifications in the regulations.
For inner packaging, they should be constructed of plastic, glass, earthenware, or metal.
To ship a hazardous material under the Dangerous Goods in Excepted Quantities limitations you
must first have the proper shipping name for your material as found in the dangerous goods list.
The Proper Shipping Name can be determined by the following methods:
You can check the dangerous goods list to see if your material is specifically listed, i.e.,
“methanol.”
You can refer to your products material safety data sheet and see if they list a proper
shipping name under the shipping info section.
With that information in hand you can turn to the blue pages in the IATA manual, the list of
Dangerous Goods, look up the proper shipping name and checked in column F.
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You will find a code listed ether E0, E1, E2, E3, E4, or E5. You then look at Table 2.6.A as extracted
below:
* For gases, the volumes indicated for inner packaging refers to the water capacity of the inner
receptacle and the volume indicated for outer packaging refers to the combined water capacity
of all inner packaging within a single outer packaging.
** Where different dangerous goods with different codes are combined, the total quantity
allowed in the outer packaging must be limited to the most restrictive amount. RISK MA
NB!! The Shipper’s Declaration for Dangerous Goods (DGD) in not required.
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The Excepted Quantity Package Mark
AC 7 - Dangerous goods accepted in limited quantities are identified and described according to the
International Civil Aviation Organisation regulations
The regulations also allow for “Dangerous Goods in Limited quantities”. This means is that some
forms of dangerous goods may be packed in simpler, though good quality, packages if the quantity
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is less than a given amount. The list is fairly detailed and is therefore not included here. These
goods still need to be marked, labelled, and documented as dangerous goods.
The net amount allowed as limited quantities is specified in the List of Dangerous Goods along
with packing requirements. The gross weight of a limited quantity package must, however, not
exceed 30kg.
In order to make life a little easier for those who are not well versed in chemistry or nuclear
physics, dangerous goods are assigned what is known as a “proper shipping name n.o.s.” (not
otherwise specified).
In many cases, it can be impractical or of little value to show a long and complicated name on an
air waybill or NOTOC (Notification to Captain). Then it is more useful to use the generic or n.o.s.
proper shipping name.
An example listed in IATA DGR is methyl-n-amyl carbinol. This is an alcohol with a flashpoint of
54ºC and is not listed by name. As the scientific name is meaningless to most pilots and cargo
handlers, the proper shipping name is more relevant. The most descriptive name is “Alcohol
n.o.s.” which is what is on all the documentation; the full name in parenthesis (brackets) must be
provided on the documentation.
For the same purpose, the UN identification numbers as assigned by the “Committee of Experts”
are also used. By using these numbers for cross-reference all qualified personnel can easily
identify the goods and its’ associated hazards. In an emergency, it can be a clear and concise way
of informing rescue teams of what they will encounter.
The principle of limited quantities is to package down from large packages to very small packages
that are placed inside outer packages. The double-packaging protects the product and potentially
contains any small leakage.
The following example helps illustrate the terminology used and shows the difference between
‘limited’ and ‘excepted’.
We want to send two shipments that may be dangerous goods. One is a very large bottle of
whiskey and the other is a bottle of Stroh Rum. The volume of the whiskey bottle is 5 litres and the
alcohol content are 43% by volume. The Stroh Rum is also 5 litres but 80% alcohol.
Section 4 of IATA DGR has following entries in the list of dangerous goods:
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Since the bottle of whiskey is only 5L, it can be shipped as “Limited quantity” as this allows up to
10L. It must be packed according to packing instruction Y 344 which is somewhat simpler than
that required for receptacles of more than 10L. Although it can be sent as “Limited quantity” it still
needs all the labels and documentation required for dangerous goods. “Excepted quantities” is not
applicable since these are limited to 1L in the case of flammable liquids.
The bottle of Stroh Rum, on the other hand, is too much for “Limited quantities” and therefore
needs the full treatment. If it had been 1L or less it could be sent it as “Limited quantities”.
If only 30mL of Stroh Rum was being sent, then it could be sent as “Excepted quantities” in which
case the package would not need to be labelled as “Flammable liquid” or documented as
dangerous goods. It would only require an “Excepted quantities” label.
Limited Quantities Mark:
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NB!! The packing need not be UN approved packaging; however, the Shipper’s Declaration for
Dangerous Goods (DGD) is still a requirement.
AC 8 - State and operator variations are identified and described according to the International
Civil Aviation Organisation regulations
Definitions
Below are the definitions as set out in the IATA DGR.
Operator / Carrier - “A person, organisation or enterprise engaged in or offering to engage in an
aircraft operation.”
State of Origin - the country (State) in the territory of which the consignment is to first be loaded
on an aircraft.
State of the Operator - the country (State) in which the operator’s principal place of business is
located or, if there is no such place of business, the operator’s permanent residence.
The state and operator variations may impose further requirements on a shipment. They are
located in Section 2 of the IATA Dangerous Goods Regulations (Attachment 3 in ICAO) and
amended in post publication addenda circulated by both organisations.
The state and operator variations are requirements applied by individual governments or airlines
in addition to the provisions spelled out in the regulations.
Not every state (country) or operator (carrier/airline) has the same laws, rules, regulations and
requirements, and the variations of each are stated in Section 2. State and operator variations may
vary for packing, marking, training, acceptance, and handling.
There is nothing in the Technical Instructions and Supplement that prevents an operator from
having variations to them, providing these variations are more restrictive. If operators have
variations to the Technical Instructions, it has become the practice for these variations to be filed
in the IATA Dangerous Goods Regulations, under the Limitations, Section 2.
ICAO and IATA have almost identical requirements. However, ICAO recognises state variations
while IATA recognises state and operator variations.
• An example of a state variation is USG 12, which requires all consignments passing through
the USA to have emergency response information on the dangerous goods declaration. This
information must include a 24-hour emergency contact phone number that provides
immediate access to a knowledgeable person.
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• An example of an operator variation is Qantas variation QF-04. The IATA Regulations
stipulates that: Oxygen or air, gaseous cylinders required for medical use and/or carried by
medically trained persons, are only accepted for carriage in or as carry-on baggage.
Some states (countries) and operators (carriers/airlines) place additional restrictions or
constraints on certain shipments only. For example, some countries prohibit entry of infectious
substances without prior approval by the authorities and some airlines will not carry infectious
substances. These restrictions are included within the IATA regulations as state and operator
variations.
Many airlines require advance arrangements to be made for the transport of dangerous goods.
Unless a specialist dangerous goods agent/courier is used, senders of infectious substances are
advised to always contact the operator/airline to check on their specific requirements for a
particular shipment and to make any necessary arrangements for the consignment.
It is particularly important to note that some of the additional restrictions applied by certain
operators are not consistent with the principles of regulations.
See for example see Air France:
Although the IATA DGR makes provision for the safe packaging and transport of Lithium ion and
metal batteries. Even if all the IATA requirements are met, Air France has an Operator Variation
that overrides this as it is more restrictive than the publication, it is also clearly defined in the
listed variations.
Many states and operators prohibit the carriage of infectious substances in their mail services;
these have been identified in their variations.
Below, are some examples of variations - of both operator and state (there are too many to list all
of them here so refer to the DG regulations for the full list) - which provide examples:
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