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