Handling of Dangerous Goods: Be Aware
Monday, June 10, 2019 at 2:52PM
John L. Enticknap and Ron R. Jackson, ABSG in Dangerous Goods, Employee Awareness Training, FBO Best Practices, Hazardous Materials, Liability

Operating an FBO certainly has its challenges, especially when a customer wants you to handle dangerous, hazardous, irregular or unusual goods.

For the most part, we recommend that FBOs have a policy of not handling these types of goods or materials. However, all employees must have awareness training to identify what constitutes dangerous and hazardous goods and what to do if they encounter any.

FBO employees may encounter dangerous goods in a variety of ways, including as passenger carry-on items, maintenance repair part shipments, packages for third-party individuals, packages arriving at the front counter, and general mail or shipper deliveries.

In an FBO setting, dangerous goods include a rather broad spectrum of items such as hazardous material (HazMat), firearms, ammunition, human remains and live animals. For the sake of training on how to handle these items, we also include perishables, valuable cargo, fragile goods, diplomatic cargo and some mail.

The reason these items are included is that not only are they a potential danger to the employee, but also there are liability issues in handling certain items.

If an employee encounters suspected dangerous goods, goods that are labeled dangerous or any of the aforementioned items, the response should be the same: “We do not handle these types of goods.”

The employee should then notify a supervisor and immediately impound the suspected goods in a designated quarantine area.  

If the questionable dangerous goods are on an arriving aircraft or are to be loaded onto a departing aircraft, the employee should inform the pilot-in-command (PIC) of the aircraft and/or passengers, as appropriate, that the company’s policy prohibits handling such goods. The PIC or passengers will then be notified that they assume responsibility for handling the suspected goods and, as appropriate, removing such items or material from the facilities.

We recommend that dangerous goods labeling requirements, as well as a poster of label examples, be displayed in the line service area, on the employee information board and at the front counter for easy access and viewing by passengers and crew. The notification will cover what constitutes dangerous goods and what items can and cannot be transported on aircraft. These types of posters and displays are similar to the ones viewable at post offices and when booking an airline ticket. 

Employee Awareness Training

We recommend that FBOs incorporate the following best practices for employee dangerous goods awareness training into their standard operating procedure (SOP) manual.

Employee awareness training for recognizing dangerous goods should be commensurate with their responsibilities and in accordance with the International Air Transportation Association (IATA) dangerous goods regulations Subsection 1.5. At a minimum, the training should include:

  1. General philosophy limitations
  2. Labeling and marking
  3. Recognition of undeclared dangerous goods
  4. Provisions for passengers and crew emergency procedures.

All employees should complete NATA Safety 1st Module: HazMat No Carry Online Training.

Module 1: HazMat No Carry Overview and Training

During the HazMat No Carry training, students will learn about the applicable requirements of Title 49 CFR Parts 171-180, which delineates classification, packaging, hazardous communication, emergency reporting, training, transport, incident reporting and security.

Access to Dangerous Goods Regulations

For a more definitive description, refer to the IATA Dangerous Goods Regulations, as defined in Section 1.0, Dangerous Goods Regulations 60th edition effective 1/1/2019, as well as NATA Safety 1st Training Module: HazMat No Carry Online Training.

We recommend your FBO maintain a library, available to all employees, of various aviation and industry regulations. Include in the library:

  1. IATA Dangerous Goods Regulations, current edition, and Dangerous Good Regulations Quick Reference Guide (2019 Edition)
  2. A description of NATA's Safety 1st Training Module: HazMat No Carry Online Training
  3. 49 CFR Chapter I, Subchapter C – Hazardous Materials 
  4. IATA Dangerous Goods Hazard and Labels Chart, www.iata.org/dgr
  5. IATA Dangerous Goods “Not Cleared for Takeoff” Passenger Hazard Chart

 

Please leave any comments you have about this blog post below. If you have any questions, please give us a call or send us an email: jenticknap@bellsouth.net, 404-867-5518; ronjacksongroup@gmail.com, 972-979-6566.

ABOUT THE BLOGGERS:

John Enticknap has more than 35 years of aviation fueling and FBO services industry experience and is an IS-BAH Accredited auditor. Ron Jackson is co-founder of Aviation Business Strategies Group and president of The Jackson Group, a PR agency specializing in FBO marketing and customer service training. Visit the biography page or absggroup.com for more background.

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