Recommendation

SUBJECT: CARRIAGE OF DANGEROUS GOODS ON PASSENGER AIRCRAFT





SAFETY DEFICIENCY



There is evidence to suggest that dangerous goods are being
carried on aircraft engaged in passenger carrying operations, with
cargo compartments which do not meet the appropriate certification
requirements.



BACKGROUND



Some attendees at a recent Dangerous Goods refresher course voiced
concerns to Bureau of Air Safety Investigators about the
simultaneous carriage of passengers and dangerous goods. Their
specific concerns related to:



(1) such operations in Fairchild Metro 23 aircraft. The reporters
believed that the main deck cargo compartment in Metro 23 aircraft
does not meet any of the International Civil Aviation Organisation
(ICAO) standards for the carriage of dangerous goods during
passenger-carrying operations; and



(2) the discretionary powers of the pilot in command. The
reporters felt that, under the current legislation, operators may
place pressure on flight crew to carry dangerous goods on aircraft
without appropriate cargo compartments.



ANALYSIS



The legislative requirements



The Civil Aviation Regulations (CARs) state that an aircraft is
permitted to carry dangerous goods only in accordance with the
Technical Instructions.



The document Technical Instructions for the Safe Transport of
Dangerous Goods by Air is approved and published by ICAO, and
states that:



"dangerous goods may be carried on the main deck cargo or baggage
compartment of a passenger aircraft provided that compartment meets
the certification requirements for a Class B aircraft cargo
compartment."



A Class B cargo or baggage compartment, as described in the ICAO
document, Emergency Response Guidance for Aircraft Incidents
Involving Dangerous Goods, is one in which:



"a) there is sufficient access in flight to enable a crew member
to effectively reach any part of the compartment with the contents
of a hand fire extinguisher;



b) when the access provisions are being used, no hazardous
quantity of smoke, flames or extinguishing agent will enter any
compartment occupied by the crew or passengers; and



c) there is a separate approved smoke detector or fire detector
system to give warning at the pilot or flight engineer
station".



This description of a Class B cargo compartment clearly indicates
that Metro 23 aircraft are unsuitable for the carriage of dangerous
goods whilst passengers are on board. This may also be the case for
other aircraft types used for passenger transport.



Current situation



Discussions with a number of operators who utilise Metro 23
aircraft, and similar types, revealed that dangerous goods are
being carried in passenger-carrying operations. Some operators
appear to be unaware of the requirements for the carriage of
dangerous goods in these types of aircraft. For example, one
operator felt that relevant information was not readily accessible
from the Technical Instructions. This operator considered that it
might be pertinent to contain such information within the text of
the CARs, and that it be a mandatory part of Dangerous Goods
Awareness Training Courses.



Dangerous Goods Manuals



The contents of company Dangerous Goods manuals appear to vary
considerably. Some manuals contain largely generic information with
no reference to aircraft types. Other manuals contain very
prescriptive information in which specific aircraft types are
referred to, with statements as to whether the aircraft type may
carry dangerous goods, and in what circumstances.



Discussions with CASA Dangerous Goods personnel revealed a view
that operators of smaller companies, such as regional airlines, may
be confused about what constitutes a Class B cargo compartment. It
is also evident that there may be differing views, both within the
industry and CASA, on whether the cargo areas of such aircraft as
the Metro 23 are part of the main deck or an external locker and
therefore have different requirements for the carriage of dangerous
goods. It was suggested that the inconsistent understanding of the
requirements is due, in part, to the fact that the Technical
Instructions are largely directed toward large international
aircraft.



Certification



The Bureau was also informed by CASA that the classification of an
aircraft cargo or baggage compartment is determined during the type
certification process. The basis of certification for the Metro 23
and other similar aircraft types, is Federal Aviation Regulation 23
(FAR 23). FAR 23.855 refers to cargo and baggage compartment fire
protection. Whilst these requirements are similar to those
mentioned in the Technical Instructions , the specifications which
must be met for a Class B cargo or baggage compartment appear to be
more comprehensive.



Seventeen Metro 23 aircraft which are certified in accordance with
FAR 23 are currently on the Australian aircraft register. There are
also a large number of commuter and charter aircraft, including a
further 15 earlier model Metro's, which are certificated to less
stringent standards. They are therefore unlikely to meet the
requirements for the carriage of dangerous goods on main deck cargo
compartments during passenger-carrying operations. The degree of
uncertainty within the aviation industry, and inconsistent
application of standards in relation to practices and procedures
for the carriage of dangerous goods, increases the potential for an
incident or accident.



Conclusion



The results of a major dangerous-goods related accident in the
United States, "Valujet Airlines Flight 592", support the need for
a vigilant and consistent approach by both CASA and operators. The
uncertainty and misinterpretation of the regulations need to be
addressed to ensure that all operators have a clear understanding
of the requirements. Dangerous Goods manuals need to be
standardised, with specific reference to aircraft types. The
content of Dangerous Goods training courses needs to be reviewed so
those people who are responsible for the acceptance of dangerous
goods on aircraft, particularly flight crew, are made aware of
these matters.



By addressing these issues through a process of education and
standardisation, it is less likely that operators will place
pressure on flight crew to carry dangerous goods on aircraft
without appropriate cargo compartments.



References



Civil Aviation Regulations

Federal Aviation Regulations

ICAO Technical Instructions for the Safe Transport of Dangerous
Goods by Air

ICAO Emergency Response Guidance for Aircraft Incidents Involving
Dangerous Goods (1997-1998 Edition)

IATA Dangerous Goods Regulations (38th Edition, 1997)