Considerations For Carrying Hazardous Materials, Part 3

Janssen vaccine vials

Janssen Covid-19 vaccine vials.

Credit: Johnson & Johnson

Infectious 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 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 is found in 49 CFR.  
 
Undeclared Hazmat
Undeclared 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 of 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-holder that is 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 175 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 ounces. 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 items as medicinal items, oxygen, implant medical devices, personal smoking materials, incubator units, and wheelchairs, hair curlers, and barometers, just as examples.  
 
Take HazMat Seriously
Air 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 crucial.   

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 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 Aircraft Rescue and Fire Fighting  incident commander so that they will take the proper precautions for suppressing any fire or when approaching the aircraft.

Considerations For Carrying Hazardous Materials, Part 1: https://aviationweek.com/business-aviation/safety-ops-regulation/consid…  

Considerations For Carrying Hazardous Materials, Part 2: https://aviationweek.com/business-aviation/safety-ops-regulation/consid…

Patrick Veillette, Ph.D.

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—including balloons, rotorcraft, sea planes, gliders, war birds, supersonic jets and large commercial transports. He is an adjunct professor at Utah Valley University.