After two years of CAA guidance, help, and training, we want to be sure that operators’ DG procedures are being actively updated.
Image: Australian War Memorial. Peter Hanley, Shark Zero Two coming home, (2005, synthetic polymer paint on canvas, 61.5cm x 61.5cm) AWM ART92744. Hanley painted this honouring the nine Australians killed in the Nias Island crash.
In 2005, nine Australian defence force personnel died when their Sea King helicopter (call sign Shark Zero Two) crashed on the island of Nias, in Indonesia.
While the cause was found to be mechanical failure due to poor maintenance, the subsequent board of inquiry found that at least four of the seven who survived the initial impact, died of asphyxiation due to smoke inhalation, or burns, from a post-accident fire.
The fire was reportedly due, at least partially, to exploding butane gas cylinders loaded on to the helicopter, allegedly by an aid worker.
While a tragedy the scale of the Sea King helicopter crash is fortunately rare, the CAA continues to receive reports of poor handling or transport of dangerous goods.
“What happened on Nias Island shows how critical to safety the correct shipping, acceptance, and carriage of DG is,” says CAA Chief Advisor of Dangerous Goods and A-cat (H) Jim Finlayson.
“We want the whole community that carries dangerous goods to ensure we never have such a catastrophic accident.”
The CAA can help you do that
Jim says a small team of dangerous goods specialists is able to help with drafting a DG manual, at no cost, to kick off an operator’s exposition amendment. Email dg@caa.govt.nz.
“And we’re continuing to run training courses for operators, particularly Parts 135 and 137 participants who carry DG as part of their normal business.”
At the start of 2023, new requirements from ICAO regarding dangerous goods training came into effect, which is why Jim’s team is so motivated to help operators understand and meet DG safety standards.
“We signalled these changes back in 2021, so we really need to see operators taking up this training, and becoming proactive about amending their expositions regarding carrying dangerous goods. But some of them are waiting until their five-year renewal to do that.”
Jim believes that compromises safety, and his team expects expositions to be updated as soon as possible.
He says meeting new Part 92 requirements is so important that CAA inspectors will be asking to look at dangerous goods procedures contained in expositions, when they’re conducting other certification tasks.
“They will expect operators to have up-to-date, compliant dangerous goods manuals, relevant to their organisation, and to have all employees who have DG responsibilities trained and current, according to the standards in Part 92.
“It’s not enough for an operator to have ‘DG procedures’ in their manual and believe that’s all that’s needed. Their procedures must be sufficient and correct so that rule 92.13 is properly understood and applied by their pilots and loaders,” says Jim.
“There are significant requirements for the carriage of dangerous goods cargo that must be explained in the exposition.
“Part 135 operators also need to be sure their DG manual meets the requirements of rule 92.11(c), but at present we’re seeing a number of expositions not doing that.”
It’s not just the civil aviation rules
Meeting the requirements of Part 92 is also a significant step toward your responsibilities under the Health and Safety at Work Act 2015, and the Hazardous Substances and New Organisms Act 1996.
It also means you’re on the right side of the ICAO Technical Instructions.
“So operating according to Part 92 gives you ‘bang for buck’ in meeting what other safety legislation requires you to do,” says Jim.
Book your place now
The CAA training courses, while popular, sometimes have space for more participants.
What some dangerous goods rules say
92.13 Carriage by passenger or crew member
A person shall not carry dangerous goods or cause dangerous goods to be carried aboard an aircraft in checked or carry-on baggage or on their person unless permitted by the (ICAO) Technical Instructions.
92.177 Information in cargo acceptance areas
Each operator shall display notices to the public at cargo acceptance areas providing information about the carriage of dangerous goods.
92.179 Information to passenger
An operator of an aircraft must inform a passenger of the type of goods that he or she is prohibited from carrying aboard an aircraft.
92.11 (c) Exceptions
A person may offer or accept dangerous goods for carriage by air that are for the recreational use of a passenger without complying with this Part if —
(1) the dangerous goods are carried in an unpressurised aircraft that —
(i) has a MCTOW of 5700 kg or less; and
(ii) is on a domestic VFR flight; and
(2) the dangerous goods are not listed in the Dangerous Goods List in the Technical Instructions as being forbidden for carriage by air in an aircraft that carries passengers; and
(3) safety and emergency procedures for the carriage of the dangerous goods are established; and
(4) each item of dangerous goods is identified; and
(5) the pilot-in-command is informed of the hazardous nature of the goods; and
(6) the dangerous goods are —
(i) in a proper condition for carriage by air; and
(ii) segregated if they are likely to react dangerously together; and
(iii) stowed, secured, and, if necessary, packed, to prevent leakage or damage in flight; and
(7) the only passengers carried aboard the aircraft are passengers who are associated with the dangerous goods.
There are more rules to become familiar with, particularly if you’re carrying DG cargo – you must be fully aware of the safety requirements, trained, and have appropriate procedures in place.