Notice of Public Meeting: 78 FR 59413 - International Civil Aviation Organization's (ICAO) Dangerous Goods Panel;

I am planning to attend this.  There are several topics of interest that are being brought to the ICAO Panel.  I think It will be good to weigh in on some of it.  

Notice of Public Meeting (FAA)

78 FR 59413 - International Civil Aviation Organization's (ICAO) Dangerous Goods Panel; Notice of Public Meeting

Panel urges electronics use on plane landing, takeoff

From My perspective there is not EMI or HazMat concerns.  The battery has the risk all the time and EMI testing has proved to be negative on interference.  I say why not?  

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WASHINGTON (AP) — A Federal Aviation Administration advisory committee recommended Thursday that airline passengers be allowed to use smartphones, tablets, e-readers and other personal electronic devices during takeoffs and landings, according to industry officials familiar with the committee's deliberations.

Panel urges electronics use on plane landing, takeoff

The Loadstar » US suspends military shipments from Afghanistan to Dubai after bomb find

IED found on some military cargo.  Good article that explains a little at the end about how the DG rules apply to Military Charters.  

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“Military charter of commercial aircraft is where it gets a bit grey,” explained a spokesman for IATA. “There are really two types – military charters where the aircraft is operated as a ‘military’ flight, in which case military rules apply. Then there are military charters that are operated as commercial flights. Here the full DGR provisions apply, and any dangerous goods that are not permitted must be carried under either an approval or exemption, as applicable for the dangerous goods in question.”

See the full Story here:  

the Loadstar » US suspends military shipments from Afghanistan to Dubai after bomb find

1.3 tons of cocaine found on Air France flight - CNN.com

Would narcotics be a Hazardous Material?  If so, what would the class or division be?  6.1? or 9 sub 6.1?  perhaps?  That is an interesting question, I may have to investigate this.  Anyone have an opinion on this?  
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There was something odd about the 30 suitcases that showed up on a flight from Venezuela. The colorful bags weren't registered to any of the passengers on the plane.  See the CNN.com story here:  

1.3 tons of cocaine found on Air France flight - CNN.com

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F.A.A. Nears New Rules on Devices - NYTimes.com

The little lithium battery devices that make our lives easier are in the news again, this time in a good way.  The power cells aren't why they are not permitted, it is more about the electromagnetic interference they may create with the ship's systems.  But studies show that this may no longer be an issue. 
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The rules on when to turn off electronic devices on airplanes have long been a sour, and sometimes contentious, point for travelers. But faced with a surge of electronics on airplanes and under pressure from a growing number of tech-savvy — and increasingly tech-dependent — passengers, the Federal Aviation Administration recognized that change was inevitable. 

See the NY Times Article here : 

F.A.A. Nears New Rules on Devices - NYTimes.com

GHS impact on Air Transportation.

Third day of the IATA DGB.  It has been quite the experience, today the EU is doing a presentation on the UN GHS program which will impact transportation and how we need to train our front line employees.  One of the interesting comments made by the experts was that it really isn't Global nor is it Harmonized.  Each member State can pick and choose how they want to implement the program.  It will be a number of years before the system is global or harmonized.  The program is also very dynamic and will change often.  It has a two year cycle where updates and modifications can be made. 

The first issue that the transport industry has is that the GHS has adopted diamond shaped hazard communication labels.  This is a problem, because the front line transportation employees are taught to identify diamond shaped labels to determine that these items are restricted for transportation.  The reality is that the diamond shaped GHS "pictogram" does not denote restrictions for transport.  This will lead to confusion and the frustration of cargo in order to determine transportation acceptability.

A shipment comes in to a cargo facility with pictograms on the package, but no Shippers Declaration or indication on the AWB.  How do we handle it?  Frustrate it in the warehouse is a reality.  A pilot sees a package being loaded onto the aircraft with a pictogram on it, but there is no pilot notification.  How long will that flight be delayed to determine its status or does the crew just remove it from the flight and frustrate the cargo?  The consensus is that these things can and will happen until the status of "Not Restricted" can be verified. 

We have been advised by the experts that these pictograms are set in stone and will not change.  The UN has determined that they are the best way to communicate the hazard.  So the idea that we can modify that has been eliminated.  We will have to deal with it by other means.

A complication to this is that the GHS program indicates that there is only a minimum size for pictograms mandated.  This means that the pictogram may be seen as large as hazard labels or larger, depending on the size of the package and what the shipper desires. 

In the past, the MSDS was one of the ways to verify transport status.  A positive bit of the GHS program is the standardization of the MSDS, which will now be called the SDS (Safety Data Sheet).  In the EU, the REACH program will ensure and enforce the accuracy in SDSs.  There will also be a standard format and required content.  The EU has a robust enforcement arm, but not so true in other countries or regions.  The US has adopted everything that the EU REACH has except section 14 the transport section.  Why?  The enforcement is  in the hands of OSHA, but section 14 belongs to the DOT and of course, the two do not work together.  So this means that some or many SDSs in the US may have an empty Section 14.

The issue at hand is the reliability of the SDS to be used to verify transportation acceptability.  Because the pictograms do not mean that the item is found in the ICAO or 49 CFR tables of regulated materials, there needs to be guaranteed or reliable way to determine transportation acceptability.  Particularly when a shipment shows up with pictograms but no DG documentation for transportation.  In the past the MSDS was a means to do this, however, it was not reliable as there was no standardization or accuracy enforcement.  There needs to be an easy way for front line employees to make this determination for the purpose of customer service. 

IATA needs to look at this and how they will approach ICAO on the best way to implement a "best Practice" or industry standard on how to best communicate the GHS program and how it impacts our industry since most Aviation Authorities had no inclusion in the implementation of the GHS system at the UN.

I was unfortunate enough to raise my hand and now find myself on an IATA task force to put together the 2015 DGR inclusion of GHS.  There were a couple of good papers submitted by some member airlines which we will merge and use as a starting point.  Our goal is to have a clean draft for the 104th meeting of the DGB in Los Angeles. 

Training will be the key and the EU experts are indicating that this is their recommendation.  To ensure that the frontline employees have the proper training to know and understand the basics of the program and how it will impact our industry.  Pilot training will also be important so that they know and understand that these labels do not necessarily indicate restrictions for transport.

The EU experts are also recommending that we help educate our customers who also need to be aware of how it will impact their shipments.  What we put into the DGR will impact training designs all around, so we need to be careful with what we implement.  The EU Experts recommend that we refrain from making anything seem regulatory in nature.  In addition, what ICAO puts into the TI needs to be very brief and purely informational. The EU Experts will submit some recommendations to IATA for consideration and will work with us on the TTF.

 A very interesting topic which will be closely watched across the board.  

For those that are interested, the OSHA guidance is found here:



https://www.osha.gov/dsg/hazcom/index.html

Volume to mass converion for HazMat

In the past, I had written about the need for the US to convert to metrics.  The fact that we are not completely on the metric system, opens up a lot of other associated difficulties with conversions and understandings of the system as a whole.

One of the things which I have encountered is the conversion of liquid volume to mass.  Now, those that know, you can't make that conversion properly without the specific gravity factor of the liquid in question.  Some liquids weigh more than others.

However, often enough, having to do those calculations is not always feasible and the SI indicates that a generic factor of 1liter can be converted to 1 kilogram based on the specific gravity of water at 40 degrees.

In aviation, the FAA has dictated that we can not load more than 25 kilograms of dangerous goods per inaccessible compartment of an aircraft (49CFR175.75).  This means that front line employees are required to determine the weight of certain commodities to establish compliance with this regulation.  The catch is that the regulators do not require shippers to provide the specific gravity of liquids being shipped.

This makes it difficult, if not impossible for front line employees to determine.  In this case, it should be allowed to use the 1 for 1 conversion factor, particularly since we are using this for quantities of 25 - 50 kilograms.

I presented a paper to the IATA DGB indicating that  this conversion factor is alluded to in a paragraph talking about chemical kits and how to convert the volume to mass for these items since they are class 9 and the weight is required rather than volume.  It allows the 1 for 1 conversion for this commodity.  However, that same conversion should be the industry standard for all applications.  Including the calculation of mass in order to determine compliance with the IATA DGR USG-13 (175.75) compliance.

The IATA DGR are not true regulations in a sense, so adding this doesnt make it a rule, but it will draw the attention of ICAO, which could make it a rule and eventually the US DOT will notice this and recognize the question and need for guidance.

So as it exists, how can I comply with the 25kg limit as placed in 175.75 if the regulator does not make the information available to the operator  which allows the operator to determine the exact calculation (Volume * Specific Gravity = Mass) .  It is in my opinion that the regulators accept the industry standard conversion factor. 

LabelMaster Blog Article on Globally Harmonized System (GHS), and the Chemical Industry | Labelmaster Blog

Interesting Article from the LabelMaster Blog:

When the Occupational Safety and Health Administration (OSHA) revised the United States Hazard Communication Law (Ref: US 29 CFR 1910.1200) in May of 2012, it set off an avalanche of change in the Environmental, Health, and Safety (EH&S) circles of American industry.

Go to the LabelMaster Blog for the whole story:

29 CFR 1910.1200, the Globally Harmonized System (GHS), and the Chemical Industry | Labelmaster Blog

IATA Dangerous Goods Board

Final Preparations are being made for my Trip to Amsterdam.  I will attend the IATA DGB as an observer, representing my Company.

There looks to be a very full Agenda and a lot of good discussion coming up.  I will write about what I can and post a few photos if possible to the blog.

I look forward to it, this will be my second trip to the board meeting, the last time was in SDF at this time last year.

Transportation Safety Board of Canada - Media - TSB calls on Canadian and U.S. regulators to ensure properties of dangerous goods are accurately determined and documented for safe transportation

Not air, but the info is still relevant and of interest to Air DG Professionals.

See the report on the Canadian TSB's site:  

Transportation Safety Board of Canada - Media - TSB calls on Canadian and U.S. regulators to ensure properties of dangerous goods are accurately determined and documented for safe transportation