Think you’ve never carried any hazmat? You’d be surprised…
OPERATIONS
You might think “hazmat” is not an issue for business aircraft and that you’ve never carried a hazardous material on board, but guess again. If you’ve carried fly fishermen, hunters, campers, scuba divers or skiers headed for an extreme skiing adventure, you’ve probably carried hazmat. Have you ever carried a survival kit that contains a flare gun, or how about fingernail polish, batteries or a thermometer? These are examples of apparently “innocent” items that can pose a risk to an aircraft and its occupants.
It is entirely possible that your passengers will not recognize the potential hazard of an item in their luggage. This occurred to me on the ramp at Bozeman, Montana, when picking up clients to fly back to California. As I walked into the FBO to greet the clients, their baggage included the characteristic carrying cases for exquisite fly rods. They had been fly fishing on some of my favorite waters nearby, which also happen to coincide with grizzly bear habitat. Wise outdoor adventurers carry bear spray cannisters for self-defense in that terrain.
After establishing a positive rapport with the clients about the flies they successfully used on these waters, I asked, “I always had the spooky feeling that I needed to watch over my shoulder during each cast to see if a grizzly was behind me. You were carrying bear spray, of course?” I did this with a tone and body language that insinuated they were “wise outdoorsmen” by having bear spray, to which they quickly answered, “Oh, you bet!”
Instead of focusing on a recitation of the federal regulation prohibiting the carriage of that hazmat, in a couple of sentences I explained the considerable risk to our safety if one of those cannisters released its noxious agent in the confines of the aircraft cabin. It quickly convinced these clients that we couldn’t carry bear spray on the aircraft.
Hazmat RegulationsThe statutory definition of a hazardous material is something harmful to persons, to goods or property, or any substance that can cause a hazard to control of the aircraft during the flight. This could be a corrosive liquid that spills and seeps onto the control cables, causing corrosion on those cables and compromising their strength. It could be an explosive that can cause an intense fire that may burn through structural members. Hazmat also can be a substance that is noxious to aircraft occupants, such as spilled fingernail polish, which produces an odor that can affect respiration. While the potential hazard of a hazmat may not seem like an issue during flight, it can certainly become an issue during an emergency egress on the ground. For instance, consider the hazard created by firearm ammunition that may discharge during a post-crash fire.
Title 49 of the U.S. Code of Federal Regulations (otherwise known as the Hazardous Materials Regulations, or “HMR”) deals with the transportation of hazmat and applies to aircraft of U.S. registry, anywhere, and any aircraft operating in the U.S. in air commerce. These regulations provide guidelines for communicating the presence of a hazmat in a package, how to classify it, how to package the hazmat properly, how to mark the package correctly, how to put the right labels on the package, how to notify future handlers about the hazmat, how to certify that it has been handled the right way, and finally, how to select the proper transportation mode to be used.
Lithium BatteriesProbably the most common hazmat carried on business aircraft these days are lithium batteries. There are several videos of lithium batteries combusting that will convince anyone who has any lingering doubts about the inflight fire risk they pose. These videos show the intense heat produced by a lithium battery fire and also illustrate that the standard fire-fighting equipment normally available in aircraft are insufficient for controlling these fires.
Many of our modern computing and communication devices are powered by lithium batteries. These items should be kept in carry-on baggage. If you have watched the videos of lithium battery fires, then you can plainly see the unacceptable risk posed if these are packed in a section of the aircraft that cannot be accessed immediately.
Spare lithium batteries must be carried with the passenger in the aircraft cabin. Any lithium-powered devices or spare batteries need to be protected from damage, accidental activation or short circuits. Battery terminals should be protected by manufacturer’s packaging or covered with tape and placed in separate bags to prevent short circuits. Damaged, defective or recalled lithium batteries must not be carried, due to the safety concern of overheating or catching on fire.
Recreational devices such as hoverboards and self-balancing scooters are also powered by lithium batteries. The same precautions must be followed for these as well. Any device that exceeds 160 Wh (watt-hours) is prohibited from carriage. This pertains to most unicycle scooters and Segway-type scooters.
Outdoor AdventurersMany of business aviation’s customers utilize our fleets of aircraft for transportation to and from outdoor recreation locations. Outdoor recreation activities may include equipment that can be a hazard to the aircraft and/or its occupants. Some of these threats are obvious, but some are not. An example of the latter is the new evolution in special avalanche--protection equipment for adventurous skiers. In recent years, skiers who venture into avalanche-prone back country terrain have begun wearing self-inflating backpacks that will form a protective cocoon around the skier if caught in an avalanche. Inflation is provided by a cartridge of compressed noninflammable gas.
The release of bear spray in the enclosed interior of an aircraft could disable the occupants. Credit: Mystery Ranch Spray Holder
Some of you may have flown campers and hunters who packed portable propane cylinders for their camping stoves. Or you may have carried scuba tanks for divers. If an improperly secured canister fell over in turbulence, the pressure could propel the canister around the cabin uncontrollably with the destructive force of a missile. Compressed gases also have the potential to form a violent flammable mixture.
Something as innocent as a package of matches can create quite a problem in flight if vibrations cause the matches to ignite, or if steel wool comes in contact with the ends of a battery.
Flammable solids such as these and cans of heating fluid require special handling.
Firearm ammunition is also a “hazmat.” Small arms ammunition for personal use must be packed in fiber, wood or metal boxes, or packaging specifically designed to carry small amounts of ammunition.
Some of you have probably carried fishermen back from Alaska with their coolers of fresh-caught halibut and salmon. Often these containers have dry ice to keep the delicious contents cool for the trip. Dry ice sublimates (i.e., turns directly from a solid into a gas) to gaseous carbon dioxide at typical temperatures and pressures in an aircraft cabin. Excessive carbon dioxide concentrations can cause aircrew incapacitation.
Small amounts of dry ice are allowed as long as the package is properly packed, is properly marked, the weight of the dry ice is less than 5.07 lb., and it must be carried in checked baggage. Dry ice intended for personal use to keep perishable food cool is allowed in carry-on baggage provided the package allows the release of carbon dioxide gas (obviously, a sealed container could develop dangerous pressure levels in flight), and doesn’t exceed 4.4 lb. per passenger.
Potentially Dangerous LiquidsThe most obvious example of a flammable liquid commonly carried on business aircraft is alcohol. Other examples of flammable liquids include paint, paint thinners, benzene, liquid cement, some cosmetics, and camp stove gas. The hazmat regulations allow alcohol as carry-on baggage as long as it is less than 140 proof. Interestingly enough, a few alcoholic beverages (such as rum 151) exceed 140 proof and thus are prohibited in aircraft. Be advised that the rules regarding passengers bringing their own alcohol are a different set of rules from the hazmat regulations.
Consumer commodities for household use, to include hair dyes, fingernail polish and aerosol cans, could cause extreme annoyance or discomfort to a flight crew member. An avid reader described an incident in which a passenger spilled a bottle of fingernail polish remover while in cruise flight. The vapor from the spilled fluid was so noxious that the crew had to perform an immediate precautionary landing. Post-flight inspection found a considerable amount of damage to the underlying structure caused by the spilled fluid.
If a package contains liquids, you must keep the package upright. In hazmat procedures, packages with liquids are marked with arrows that show the proper orientation of the package, and these directions must be followed. If you suspect that the package containing a liquid hazmat has been stored improperly on its side, you really must open the package and inspect it. You might be dismayed to learn that some containers have been designed and certified for carrying hazmat liquids but that the lids have sometimes been a weak point in the design. You should always keep packages containing liquids in the proper orientation during loading, storage and en route. Always secure these items so they won’t tip over in flight.
MedicalInfectious substances, drugs used in veterinary or human treatment, biological products, vaccines, urine samples and medical waste require special precautions and training for flight crews involved in transporting these materials.
Some medical equipment may have radioactive components. Radioactive substances are measured and classified according to the amount of radioactivity that they emit, and a “Transport Index” is assigned to this amount. The total amount of the Transport Indices on the aircraft establishes the required separation from passenger compartments. This chart can befound in 49 CFR.
Containers of freshly caught halibut and salmon often utilize dry ice to keep the contents cool for the trip. Dry ice sublimates to gaseous carbon dioxide at typical temperatures and pressures in an aircraft cabin, which could pose a hazard for aircrews. Credit: Patrick Veillette
Undeclared HazmatUndeclared hazmat is a serious issue. Any person offering hazmat for transportation is responsible for properly identifying, describing and classifying the material. In addition, they are also responsible for properly completing the communications and packaging requirements prior to offering the shipment for transportation.
It is vital for pilots and any other company personnel who have duties that may include the loading and handling of baggage to become familiar with clues indicating potential hidden hazmat. Employees should be especially vigilant when screening all cargo and baggage to prevent the inadvertent acceptance and transportation of unauthorized materials.
If you work for an air carrier certificate-holde r authorized to carry hazmat, you cannot accept a hazmat shipment unless the shipment is properly described in the shipping papers, required certifications are on the shipping papers, the package is marked and labeled as required, and the shipment is authorized to be carried on an aircraft.
Regulation 49 CFR 175 requires that packages containing hazardous materials that might react dangerously with other packages may not be placed next to each other. They should also not be positioned so that a leaking package could allow a dangerous interaction. There is a Stowage Compatibility Chart in 49 CFR 1 75 that describes which classes of hazmat cannot be carried next to other classes of hazmat. For example, corrosive materials should not be stowed next to or in contact with flammable liquids and solids, explosives, blasting agents, flammable solids or oxidizers. Oxidizers should not be carried next to explosives, flammable liquids and solids and oxidizers.
If the shipping container is damaged in any way, you need to be suspicious. Before loading any cargo, you should inspect each package for holes, leakage or other obvious signs that the packing is starting to fail.
Hazardous Material Regulation (HMR 175.10) does grant some exemptions. For example, it is possible to carry a tire assembly with a serviceable tire provided the tire is not inflated to a gauge pressure exceeding the maximum rated for the tire.
Under HMR 175.10, self-defense sprays are exempted from the hazmat requirements if the units contain less than 4 oz. It must have a positive means to prevent accidental discharge and must be carried in checked baggage only.
The list of other exempted items is contained in HMR 175.10 and includes such things as medicinal items, oxygen, implant medical devices, personal smoking materials, incubator units, and wheelchairs, hair curlers, and barometers, just as examples.
Take HazMat SeriouslyAir carriers operating under 14 CFR 135 are required to have a formal hazmat training class and procedures that conform with the 49 CFR. Whether you hold an air carrier certificate or not, clearly you are held responsible for obeying these regulations, and as a matter of good risk-management practice, even if there wasn’t a set of regulations about this, it would make good sense to follow the regulatory guidelines. Like many of the FARs, nearly every line in 49 CFR is also written in blood. Hazmat is something to be taken seriously, and like most aviation problems, prevention is always the best option.
The bottom line is that you can’t be too careful about the items you carry in the aircraft.
In the event that you experience an aircraft emergency and need to perform a precautionary landing, notify the nearest ATC facility that you have these hazmat items on board. It’s helpful to tell the controllers where these items are located and the quantity or weight. This information will be passed along to the ARFF incident commander so that they will take the proper precautions for suppressing any fire or when approaching the aircraft.
Upon his retirement as a non-routine flight operations captain from a fractional operator in 2015, Dr. Veillette had accumulated more than 20,000 hours of flight experience in 240 types of aircraft, from balloons, rotorcraft, sea planes, gliders, war birds, supersonic jets and large commercial transports. He is an adjunct professor at Utah Valley University.
