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3.9.13 Handling Dangerous Goods.
3.9.13.1 Process.
Identify the handling process, including the description of the movement from the acceptance point, to the loading ramp, or storage incidental to transport.
3.9.13.2 Personnel.
Identify the following personnel, duties, and information:
• The persons responsible for oversight of the handling function;
• The persons responsible for performing the handling job function;
• The job duties of the persons performing the handling job function;
• The job duties related to moving items from the acceptance point to either storage incidental to transport or the loading dock; and
• The special handling requirements necessary for packages containing dangerous goods.
3.9.14 Storage Incidental to Transport
3.9.14.1 Process.
Identify the location where items are placed in the certificate holder’s facility when entering “storage incidental to transport”.
• Specify how items are stored, including segregation or isolation procedures, to keep potentially reactive items separate;
• Describe the process for moving items into or out of “storage incidental to transport”; and
• Describe how certificate holder tracks items within their facility that are in “storage incidental to transport”.
3.9.14.2 Personnel.
Identify the person responsible for this function within the certificate holder’s facility.
3.9.15 Loading
3.9.15.1 Personnel.
For each loading area, certificate holder should identify the following:
• Management personnel responsible for overseeing loading; and
• Worker personnel, including any contractors, subcontractors, or affiliates acting on behalf of the certificate holder.
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3.9.15.2 Process.
For each loading area, identify the process for preparing the shipments prior to loading, and the actual loading onto the aircraft. The process should:
• Identify the responsible managers by loading location;
• Identify personnel, contractors, subcontractors, and affiliates acting on behalf of the certificate holder, performing this function by job description;
• Describe the process of preparing and consolidating the dangerous goods packages prior to loading onto the aircraft (i.e., use of unit load devices, palletizing shipments, etc.); and
• Describe the roles the ramp personnel have in verifying that the dangerous goods package is offered in compliance with the regulatory requirements for dangerous goods, to include:
1. Who makes decisions regarding where dangerous goods packages are placed in the aircraft (i.e., types of cargo compartments, location within compartments);
2. The process for verifying whether the loading process is consistent with the regulatory requirements for dangerous goods;
3. How dangerous goods packages are separated for loading into the different cargo compartments;
4. How cargo compartment quantity limitations are followed (e.g., under § 175.75 of the HMR);
5. The process for verifying that cargo is appropriately segregated on the loading ramp to prevent inadvertent shipment of cargo identified as non-compliant;
6. Who is responsible for ensuring that stowage limitations of §§ 175.78 and 175.501of the HMR, or the related ICAO Technical Instructions provisions, when applicable, are satisfied; and
7. How loading personnel are made aware any other risk mitigation strategies for dangerous goods.
3.9.16 Shipping Paper and Notification to Pilot in Command (NOPIC or NOTOC)
3.9.16.1 Personnel.
Identify the person responsible for compliance with the NOPIC requirements of §175.33 of the HMR, or the related ICAO Technical Instructions provisions, when applicable.
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3.9.16.2 Process.
Identify the process for complying with §175.33 of the HMR or the related ICAO Technical Instructions provisions, when applicable.
• Specify where (by location) the shipping paper information is stored;
• Describe the process for notifying the pilot in command; and
• Describe the process used to make NOPIC information available at the intended airport of arrival, and make available to authorized government officials.
3.9.17 Incident and Discrepancy Reporting.
Identify the process for reporting dangerous goods packages damaged or found to be leaking, undeclared dangerous goods, or packages that are otherwise determined to be non-compliant.
• Specify the person, by title or job description, responsible for the report;
• Specify how the report is made (electronic, paper form);
• Describe how the package is separated from other packages continuing in air transport;
• Describe what happens to the package once it is rejected;
• Specify when and how the shipper/offeror is notified; and
• Describe any follow-up actions taken with the shipper or analysis of reports.
Appendix A A-1 APPENDIX A. PREVENTING UNDECLARED DANGEROUS GOODS A.1 General Information.
The risk of undeclared or improperly prepared dangerous goods shipments in air transportation has been demonstrated through experience such as the loss of ValuJet flight 592 in 1996. In addition, many incidents of fire and the dangerous evolution of heat in both the cargo hold and cabin have been reported. While these incidents have been managed and mitigated to date, we must continue to work to ensure that the risks of future incidents are being reduced to the greatest extent possible. This work will further decrease the likelihood of a catastrophic event to the aircraft. The information in this AC is intended for use by certificate holders when implementing a plan for preventing and reacting to undeclared (noncompliant) dangerous goods shipments presenting an unknown risk when being transported as cargo or in a passenger’s checked or carry-on baggage. The information consists of regulatory and recommended risk controls and include, but are not limited to, communication, education, training, feedback, and collaboration, to prevent the noncompliant shipments from entering the air transportation system. Prevention is and should be the goal of everyone involved in the air transport system. The success of controlling this risk should include not only the certificate holder, but also collaboration and coordination with every entity in the supply chain. Evolving technologies are making it easier to leverage a variety of media sources to provide information, which can be a more effective means to communicate, improve business practices, and to ultimately prevent undeclared dangerous goods shipments from being transported by certificate holders. Moreover, being proactive and providing resources to prevent the likelihood of undeclared dangerous goods may reduce the certificate holder’s costs and the amount of resources needed to identify, handle, and report, undeclared shipments after entering the air transportation system, including disposal or the return of the shipment to the offeror.
A.2 Communication and Notification.
One of the key tools for use by certificate holders, when implementing preventive processes and procedures to control the offering of undeclared dangerous goods, is communication. Cargo shippers and passengers are the most significant control for preventing undeclared dangerous goods from being transported on an aircraft. As cargo shippers offer shipments carried in cargo holds onboard both cargo and passenger aircraft, the origination of the risk is broad based. The undeclared shipment can be brought into the cabin in carry-on baggage and checked baggage in the cargo hold, or offered and transported as cargo. To account for evolving technologies and/or certificate holder-specific conditions supporting an effective notification to cargo shippers and passengers, the dangerous goods permitted, and recognized items that are not permitted, should consistently be provided to all involved. Most cargo shippers and passengers do not intentionally introduce risk into the air transportation system. They are not aware of the risk they are posing to themselves or others. There are deliberate actions, but those are less frequent and potentially criminal. The FAA continues to support and collaborate with the aviation industry on actions to involve all entities in the
Appendix A A-2 transportation of dangerous goods by air in programs to better communicate the hazards of dangerous goods.
A.3 Proactive Actions to Prevent Undeclared Shipments.
Communication and notification methods for informing cargo shippers and passengers share a common outcome -- informing the originator of the dangerous goods restrictions. Therefore, in accordance with the certificate holder’s communication system, the most appropriate communication method necessary to implement and effectively deliver information to reduce or eliminate undeclared shipments will largely be dependent on the communication system the cargo shipper or passenger chooses to use.
A.3.1 Transporting Cargo.
For cargo shippers and those involved in the air transport system prior to the certificate holder accepting possession, the following processes may assist in prevention:
• Developing continuous communication with customers that are potential dangerous goods shippers (e.g., electronic device shippers, postal service) can serve as an effective means of preventing undeclared shipments from entering the air transportation system. This communication could direct customers to guidance and information on common undeclared dangerous goods and provide proper shipping practices:
1. Push Communication – Providing dangerous goods information directly to the cargo shippers; and
2. Pull Communication – Providing dangerous goods information on the certificate holder’s website, including brochures, videos, hotline number, etc., and directing the cargo shippers to that location.
• Processes that may be implemented by certificate holders:
1. Providing information or methods to find information on identifying dangerous goods in the business relationship (i.e., sales and marketing) with customers;
2. Informing customers about dangerous goods training requirements for shippers and others in the transport chain that may engage in functions related to dangerous goods transportation;
3. Providing procedures and information to educate shippers at cargo facilities is critical for reducing the occurrence of undeclared dangerous goods entering the air transportation system. This and other preventive measures are especially critical when the certificate holder’s cargo systems are automated, and do not use employees to recognize indications that the package should be rejected, as well as to implement reactive actions;
Appendix A A-3
4. Promoting possible incentives to shippers if they do not include undeclared dangerous goods in their shipments; and
5. Implementing any other means available to prevent or reduce the introduction of undeclared dangerous goods in the air transport system from the source.
A.3.2 Transporting Passengers.
For certificate holders that transport passengers and their baggage, the dangerous goods restrictions are required to be included in a passenger notification system. The intent here is to clearly communicate with passengers and prevent dangerous goods from being carried on the aircraft. Specifically, certificate holders are responsible for designing and implementing processes and procedures, as well as a passenger notification system to communicate to passengers, that dangerous goods are forbidden in carry-on or checked baggage. Key to the success of the notification process is the ability of certificate holders to reach passengers early and often; prior to transporting their carry-on or checked baggage. In addition, the notification system should provide flexibility to address changing circumstances, conditions and environments even if those changes are temporary.
• The passenger notification system includes a process for an acknowledgement by the passenger, or someone acting on their behalf, that he or she has been presented with the information about dangerous goods that are forbidden as carry-on or checked baggage, or conversely that he or she has been presented with the information about dangerous goods that are permitted as carry-on or checked baggage. Acknowledgement is required at:
1. The point of ticket purchase, or if not practical, made available in another manner to passengers prior to issuing a boarding pass; and
2. The time the boarding pass is issued, or when no boarding pass is issued, prior to boarding the aircraft.
• The information provided to passengers about dangerous goods forbidden or permitted to be carried aboard an aircraft are required to be presented at each location where the following processes take place:
1. Tickets are issued;
2. Boarding passes are issued;
3. Passenger baggage is dropped off;
4. Aircraft boarding areas; and
5. Any other location where passengers are issued boarding passes and/or checked baggage is accepted.
• In order to accommodate passengers who may not speak the national language, and to ensure that the information is communicated effectively, visual examples would substitute or supplement any text.
Appendix A A-4 A.3.3 Message Delivery.
For both cargo shippers and passengers, the messaging content and method of delivery should be appropriate for the location. For example, local operating characteristics should be taken into consideration and technology should be widely considered to support effectiveness and efficiency of message delivery.
• Appropriate information should be included, such as:
1. Information required by regulation;
2. Commonly confiscated/rejected items from specific locations or globally;
3. Information gathered from previous incidents or reports;
4. Regional or seasonal operating characteristics; and
5. Other regionally or globally known information.
• Examples of methods of delivery to communicate information:
1. Electronic displays;
2. Websites;
3. Verbal discussions;
4. Applications on smartphones;
5. Kiosks;
6. Printed matter;
7. Personal contact;
8. Announcements; and
9. Letters and information attached to general business correspondence or regular general communication.
• Technology should continually be reviewed for improved processes to communicate information. As new technologies, such as self-check-in or electronic shipping papers, are developed or incorporated into the certificate holder’s processes, the manual should be updated to reflect those changes.
A.3.4 Incentives for Safety.
An effective plan to mitigate the risk of undeclared dangerous goods offered for transportation by air from shippers or passengers should result in an increased level of safety. Promoting educational information on the prevention of undeclared dangerous goods to certificate holder’s customers should focus the information on the highest-risk group known. For certificate holders with cargo shippers and passengers, the plan should include appropriate interaction between all parties to inform them about the risks inherent to the air transportation of undeclared dangerous goods. The plan should also be flexible to recognize and accommodate any other means that might be available to cargo shippers and passengers to prevent or reduce the introduction of undeclared
Appendix A A-5 dangerous goods in the transport system, as doing so, will also contribute to reducing the level a risk.
A.4 Reactive Actions to Prevent Undeclared Shipments.
A.4.1 Legal Requirement.
In accordance with 14 CFR part 121, subpart G and part 135, subpart A, each certificate holder must ensure that the procedures and information described in its manual are sufficient to assist each person performing or directly supervising the acceptance, rejection, handling, storage, packaging, and loading, of items for transport onboard an aircraft in identifying and rejecting packages and baggage that show signs of containing undeclared dangerous goods.
A.4.2 Identifying.
A.4.2.1 Transporting Cargo.
Procedures and training for personnel to recognize signs of undeclared or noncompliant dangerous goods shipments in general cargo should include, but is not limited to, the following information:
• Hazard labels or markings on a package that may indicate the presence of dangerous goods;
• Packaging characteristics, such as metal or plastic drums, that generally are used for dangerous goods transport;
• Packages that, when handled, provide indications that a dangerous good may be inside;
• Documents, when provided, that indicate that there may be a dangerous good being offered; and
• Other available information in the certificate holders’ systems.
A.4.2.2 Transporting Passenger.
When passenger’s carry-on and checked baggage are being processed for air transportation, procedures and training for personnel to recognize signs of an undeclared or noncompliant baggage should include, but are not limited to, the following information:
• Hazard labels or marking on the outside of a box that may indicate the presence of dangerous goods;
• Suspicious baggage or boxes that may contain dangerous goods;
• Questions that passenger asks regarding possible prohibited items; and
Appendix A A-6
• Providing adequate communication to the passenger for them to identify a prohibited item.
A.4.3 Rejecting.
Certificate holders are required to reject packages or baggage that show signs of containing undeclared dangerous goods.
A.4.3.1 Transporting Cargo.
Procedures for rejecting cargo shipments should include, but are not limited to:
• How the shipment is removed from the cargo stream;
• How the shipment is returned, disposed of, or stored;
• How record keeping of rejected shipments is implemented; and
• How the originator and others in the transport system are notified of a non-compliant shipment.
A.4.3.2 Transporting Passenger.
Procedures for rejecting dangerous goods in passenger baggage should include, but are not limited to:
• How the dangerous goods are removed from baggage, if prior to screening during check in;
• How to coordinate with security screening personnel to handle prohibited items found in screening;
• How the method of returning, disposing, or storing these items is determined;
• How record keeping of rejected shipments is implemented; and
• How the originator and others involved are notified.
A.4.4 Notifying.
Where the barriers to prevent undeclared dangerous goods entering the air transportation system fail, the certificate holder is required to notify the FAA when packages or baggage are found to contain undeclared dangerous goods, subsequent to their being offered and accepted for transportation. The procedures to notify and provide information to support oversight activities are essential to reducing the risk of future undeclared shipments. These procedures are part of the aviation safety system, as they provide the FAA information to evaluate compliance of others in the transport chain, and continually conduct safety trend analysis. This collaboration is a significant mitigation for risk management in aviation safety.
A.4.5 Evaluating.
Appendix A A-7 The certificate holder should implement processes and procedures for correction and evaluation of the root cause to prevent reoccurrence of undeclared dangerous goods.
This process should include the means to mitigate the risk of undeclared shipments in the certificate holder’s policies for risk management.
A.5 Plan Considering Proactive and Reactive Actions.
It is essential to educate personnel that conduct acceptance, rejection, handling, storage, packaging, and loading of items for transport onboard an aircraft on the techniques for preventing the transport of undeclared dangerous goods by air. Certificate holders have historically trained their personnel in the transport job functions to prevent noncompliant and undeclared dangerous goods shipments from entering the air transportation system. However, most actions performed by certificate holder’s personnel could be considered reactive, as the undeclared shipment has already entered the air transportation system when offered by the shipper. In this Appendix, proactive is an action that could prevent a shipper or passenger from offering undeclared dangerous goods to be transported by the certificate holder. The object of a complete plan would be to complement the reactive with proactive actions to mitigate the risk of having the noncompliant shipment in the system.
Advisory Circular Feedback If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by (1) emailing this form to Thomas.L.Kenny@faa.gov or (2) faxing it to the attention of the Office of Hazardous Materials Safety – Systems Oversight at (202) 267-9450.
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