By JOHN CARR AND LES OMANS
The aircraft itself-full of fuel and hazardous systems fluids-represents a serious potential haz-mat event.
Clearly, these are perilous times for the commercial aviation industry. First responders must shoulder new responsibilities with respect to various aviation incidents. Not only are there concerns about hazardous materials in the cargo holds of commercial aircraft as well as enormous amounts of dangerous goods carried aboard freighter aircraft, but a new dragon has lifted its ugly head: The aircraft itself-full of fuel and hazardous systems fluids-represents a serious potential haz-mat event. Most importantly, as we have seen with the September 11 attacks on the World Trade Center and the Pentagon, commercial aircraft have become instruments of death and destruction. You must prepare for safe, effective response to these types of incidents.
CASE STUDIES
Case study #1. A Boeing 707 cargo freighter took off from a major eastern airport with full fuel tanks and a full load of cargo bound for Europe. (A freighter is any commercial or other type of aircraft that has been configured specifically for transport.) Aboard this particular flight was a cargo of 15,000 pounds of hazardous materials, most of which, unfortunately, was improperly packaged and labeled. It also lacked proper paperwork and, therefore, appeared on the flight cargo manifest inaccurately. Over the Atlantic Ocean, the three-member crew smelled and observed smoke coming from the main cargo deck area. The captain tried to determine the closest airport with runways that would accommodate his aircraft. Because of the smoke-obscured vision in the cockpit, the aircraft crashed on approach. The crew, cargo, and aircraft were lost.
The ensuing investigation revealed that several glass jars of nitric acid were packed in sawdust and shipped as ordinary materials. The acid leaked from the jars into the sawdust, causing spontaneous ignition, which triggered the fire and the eventual disastrous outcome.
The lessons learned are that more stringent shipping declaration as well as tighter controls on the part of air cargo contractors are needed.
New policies that make shipping hazardous materials much more difficult and expensive are now in effect. First, the air cargo contractor now must make a complete authentic declaration of what is being sent under penalty of federal law. Next, the materials must be in approved haz-mat containers and properly labeled. Third, and perhaps most important for the first responder, the material must be correctly listed on the cargo manifest, and its location on the aircraft must be noted.
As an example, a shipper sent some chain saws by air in their plastic containers. The shipper inadvertently failed to completely drain all the gasoline from some of the saws. When the cargo arrived at its destination, the offloading crew smelled gasoline, which led them to the saws. The Federal Aviation Administration (FAA) was alerted and contacted the shipper. The FAA issued a violation order, which resulted in a very stiff fine. Fortunately, there was no damage to the aircraft or crew and no need to declare an in-flight emergency.
Case study #2. On a crowded jetliner on a routine flight over the continental United States, passengers noticed a noxious odor emanating from an unknown source. They alerted the flight attendants, who reported it to the captain. Suddenly, the passengers and flight attendants began experiencing dizziness and nausea. The captain immediately sent the first officer to investigate and take charge of the situation. The first officer discovered what he believed to be a jet fuel leak into the fuselage. The captain declared an emergency and diverted to the nearest airport. On landing, the pilots taxied the aircraft off the active runway and immediately initiated an emergency evacuation. Numerous passengers were injured during the evacuation when several evacuation slides failed to fully inflate.
An investigation revealed that a passenger fueling his diesel vehicle prior to departure had spilled fuel, which has an odor similar to that of jet fuel, on his clothing. The incident, as mundane as it seemed, was a hazardous event that prompted the declaration of an in-flight emergency, which in turn resulted in various needless injuries.
Case study #3. A female passenger was transporting a bottle of a common household stripping solution in her carry-on luggage. During the flight, the bottle began to leak on her and the carpeted floor of the aircraft. The woman sustained chemical burns and damaged the aircraft.
This was another in-flight emergency that caused a needless ground evacuation and additional injuries. The enormity of what is personally carried aboard aircraft without forethought can easily become a nightmare for the crew, passengers, and especially first responders.
Case study #4. A narrow-body jetliner was en route to a southern airport when a strong acrid odor began filling the cabin, followed by smoke. The crew found a section of the cabin floor that felt hot and spongy. Then they discovered that some seats in that area were beginning to show signs of a burn pattern. The captain assumed it was from a previous problem he had experienced with the auxiliary power unit, so he downplayed the severity of the situation and did not take immediate action. In the meantime, the flight attendants began moving passengers away from the affected area and had them cover their noses and mouths with wet towels. During the final approach, the smoke became thicker and infiltrated the flight deck. With great difficulty, the pilots managed to land the aircraft. The flight crew initiated an emergency evacuation as the fire department arrived. Some firefighters deployed the slides while others opened cargo doors and observed heavy smoke and flames from the rear cargo area. During the ensuing evacuation, two firefighters, three flight attendants, and nine passengers were transported to nearby hospitals for treatment for smoke inhalation.
An unidentified individual had shipped a 50 percent solution of hydrogen peroxide (a strong oxidizer) and sodium orthosilicate (a corrosive) undeclared and listed it as laundry equipment. During the flight, these two materials were liberated from their containers, mixed together, reacted, and ignited. The aircraft sustained more than $1 million in damage. Structurally, five support floor beams were destroyed and 63 control cables were either damaged or destroyed, which accounted for the difficult landing. The aircraft and its occupants were very fortunate under these circumstances.
EVERY INCIDENT A HAZ MAT
These are all true events involving hazardous materials aboard commercial aircraft. It is apparent that more and more freight shippers are using the airways as a quicker means to ship in this “I need it yesterday” world. Many trucking companies have formed alliances with air carriers, and the United States Postal Service now has its own fleet of air freighters. Without question, airfreight and dangerous materials carried aboard are increasing at an alarming rate. And many remain unreported for a multitude of reasons-negative publicity, sensitivity of the flying public, not enough enforcement staff, competition, cost factors, archaic legislation, and just plain negligence.
Thus, you must treat all aircraft incidents as haz-mat situations. Aircraft carry large amounts of fuel, flammable metals, and plastics that emit toxic gases and carbon fiber materials (similar to asbestos hazards when airborne or burning). Aircraft system fluids such as hydraulic fluids, compressed air cylinders, and high-pressure wheel and tire assemblies filled with nitrogen represent some of the dangers associated with the aircraft alone. Military aircraft add a whole new dimension to the overall problem responders face. You must recognize and be prepared for explosive canopies, rocket-powered ejection seats, liquid-oxygen systems, exotic fuels such as hydrazine, and extensive composite material construction as well the ever-present danger of munitions.
Air refuelers are another huge concern. These flying gas stations carry a maximum fuel load at times in excess of 58,000 gallons, and they are constantly airborne over the continental United States. No airport or its communities are out of bounds when one of these aircraft is in trouble.
AIR CARGO REGULATIONS
So how do we regulate this dangerous business? Who makes the rules? Who enforces those rules?
“Hazardous materials” is a fire department term. In the aircraft arena, hazardous cargo is called “dangerous goods.” There are two regulatory standards applicable to shipping dangerous goods by air.
The first is Title 49 of the Code of Federal Regulations (49 CFR). The second is the “Technical Instructions for the Safe Transportation of Dangerous Goods by Air,” published by the International Civil Aviation Organization (ICAO). The ICAO is the United Nations governing body that exercises authority over international air transportation. This organization meets every two years to issue and update directives and technical instructions. These regulations are enforced worldwide, including in the United States.
Most air cargo carriers use a document called the “Dangerous Goods Regulations,” published annually by the International Air Transport Association (IATA). Based on the ICAO Technical Instructions, this document contains additional information about requirements and procedures recognized as standards worldwide by the airfreight carriers. Each set of regulations has tables listing more than 200 chemicals that direct how each material must be packaged, labeled, and loaded and the maximum allowable quantities that can be transported. If a shipper wants to transport a material not listed in these tables, a chemist must analyze the chemical, and then it can be categorized, packaged, and labeled as a similar material as listed in the tables.
Both 49 CFR and the IATA Dangerous Goods Regulations are extremely complex and detailed-too much information to commit to memory. Thus, have copies of both the ICAO and IATA documents readily available, and make them part of your game plan. You must have a working knowledge of these documents. Visit your nearest air cargo facility and become familiar with their procedures, shipping documents, and cargo manifests carried aboard their aircraft. Carry emergency phone numbers of all air carriers on all responding apparatus. They are critical for making safe tactical decisions.
Air carriers have emergency teams with invaluable resources and information that can immediately tell responders where the aircraft came from; the number of the crew; and, most importantly, if there is cargo of significance aboard. Remember, cargo and commercial air carriers are not mandated to have 704 placarding on the fuselage, and the Surgeon General has not stamped on the aircraft “This product can be hazardous to your health.”
TYPES OF HAZARDOUS CARGO
There are four categories of dangerous goods. The first category includes materials forbidden on any aircraft, in any quantity and under any circumstances. These materials are listed in the chemical tables of both sets of regulations. The 50 percent hydrogen peroxide mentioned earlier is a prime example of a forbidden material. The maximum allowable concentration of hydrogen peroxide is only 32 percent, and it can be transported on cargo aircraft only (not passenger) and is limited to a one-quart container per package. However, even these materials can be transported in certain circumstances under a special permit. Therefore, you must be prepared to encounter anything on an aircraft.
 (1) This label is a warning of an extremely dangerous commodity. Packages carrying this label are found near the cockpit area. (Photos by authors.) |
The next category includes materials that can be transported on cargo aircraft but are forbidden on passenger aircraft. An orange and black “Cargo Aircraft Only” label must be attached to the container. This label should be a red flag to those working this incident that they have a serious situation on their hands. Under these conditions, the flight crew is mandated to have direct access to these dangerous materials during the flight. Except for “Cargo Aircraft Only” packages that are specifically addressed as “radioactives,” these materials usually will be in containers or on pallets close to the flight deck (cockpit). If a multitude of pallets of these materials are aboard the aircraft, there must be an 18-inch pathway that gives the crew access to these materials for surveillance purposes or initial fire suppression activities.
The third category includes materials allowed on passenger or cargo aircraft in inaccessible cargo holds, which generally are stowed in the lower luggage compartments on most passenger aircraft. These materials are limited to a maximum of 150 pounds of compressed gas and 50 pounds of other materials per compartment. An exception to this regulation involves aircraft carrying passengers and cargo in accessible cargo areas on the main cabin deck. These types of aircraft, often used by foreign carriers, may be encountered at major international airports. Additionally, dangerous goods are permitted on passenger aircraft with certain limitations. For example, hunters are permitted to carry limited amounts of ammunition aboard commercial carriers provided that they declare that they are shipping it and they fill out the appropriate paperwork. However, an important point to remember is that any packages labeled “Cargo Aircraft Only” are forbidden on any passenger aircraft regardless of the purpose. Some passenger airlines also may limit the types and amounts of materials allowed on their aircraft. Many will not carry poisons or flammables of any kind.
Airline personnel are required by law to check closely all shipments of declared dangerous goods, regardless of the type of aircraft on which they are ship-ped. They are re-quired to complete a questionnaire or checklist and to affix a copy to the package. This information should appear on the flight manifest under “cargo of significance.”
Our research has found that thousands of packages are refused daily because of improper packaging, paperwork, and labeling. In contrast, thousands of packages somehow do find their way aboard aircraft as shippers find loopholes in the systems and disregard the dangerous situations created by dishonesty. Clearly, the aviation industry and the flying public have been very fortunate that the number of incidents involving dangerous goods has not increased dramatically; however, they have not decreased either. The need for tighter legislation and monitoring procedures must move forward as never before.
The fourth category is an unofficial one that involves undeclared dangerous goods. These are shipments about which the airline has no knowledge. On thousands of flights daily, dangerous goods are in luggage, in mail, and in other packages, and those who carry or ship them are totally ignorant of the regulations or deliberately attempt to conceal information because of the additional shipping costs associated with these dangerous materials. The first scenarios we examined earlier serve as prime examples. Various products purchased in grocery, hardware, sporting goods, and variety stores fit the dangerous goods criteria. Yet, individuals and manufacturers continue to challenge the very regulations that prohibit and regulate air transport of dangerous goods and that provide our blanket of safety.
A statement warning passengers and shippers about undeclared dangerous goods is required to be displayed at airline ticket counters and cargo check-in areas. These posters often are not as conspicuous as they should be, or they have been discarded. Airline personnel, although required to ask specific questions of passengers, many times take the word of the passenger. Usually, if a package is not labeled or leaking or showing other unusual symptoms, they are not scrutinized unless the shipper acts suspiciously or makes a suspect statement. Our research has shown that more than one-half of the aircraft incidents involving dangerous goods are linked to undeclared materials.
THE AIRCRAFT
If history has proven anything about dangerous situations or equipment-especially the events surrounding the September 11, 2001, attack-it is that aircraft are dangerous and they alone represent a dangerous goods incident just waiting to happen, regardless of the cargo in their holds. The best rule of thumb is to always suspect dangerous goods when responding to aircraft incidents and plan for the worse-case scenario. Never discount the possibility of dangerous goods being aboard private aircraft. Many large airfreight companies subcontract private aircraft owners to ship freight from smaller airports to central distribution points or ” HUBS.” These “feeder aircraft” make just about every airport, regardless of size, a potential target for a dangerous goods incident.
Another key point to remember is that only a large cargo net attached to a lightweight bulkhead separates the entire cargo area from the cockpit. In case of a hard landing or a crash, it is probable that the cargo will be resting in the cockpit, making entry through door 1 unlikely or impossible. Remember, these types of aircraft came from the commercial fleet and have cockpit escape areas-most likely door one left (1-L). The crew on these aircraft is vulnerable and represents the chief concern, rescue.
Responders must be familiar with their respective cargo aircraft. Information should be aboard all responding apparatus; do not rely solely on committing it to memory. Usually, the cargo manifest and a copy of the DOT Hazardous Materials Guidebook will be on the aircraft. Most responders may have the handbook, but the manifest is the most important document onboard.
When responding to these types of incidents, request as soon as possible the response of an airline official, preferably an aircraft mechanic familiar with the aircraft involved. As with any aircraft incident, responding firefighters should understand the location and how to disconnect the aircraft batteries and shut down auxiliary power units as well as safely pin the landing gear assembly. Stabilizing the aircraft is paramount. If first responders are not trained to complete these tasks, they are placing themselves at risk.
SHIPPING DOCUMENTS
The documentation accompanying dangerous goods varies from carrier to carrier. You should be familiar with the types of aircraft and carrier operations that are common for your airports.
The shipper is responsible for properly packaging, labeling, and marking the package and completing the “Shipper’s Declaration of Dangerous Goods.” This is a multipage form. The shipper and the cargo facility of departure each keep one copy. One copy is affixed to the package in a clear plastic envelope. If there is more than one package in the shipment, the form will be attached to only one package in the shipment and must be clearly visible. A copy of the document should also be in or close to the flight deck.
On major carriers, the crew has a form called “Pilot’s Notification for Loading Restricted Articles” or “Dangerous Goods Load Notification to Captain.” Although carriers may call the document by different names, the same information is recorded. The cargo facility loading the aircraft is responsible for compiling all the information and recording it on this form.
The shipper’s Declaration of Dangerous Goods has a considerable amount of valuable information about the material involved. When responding, make every attempt to secure a copy of this document before initiating any action. It lists the names of the shipper and the consignee as well as the address and telephone numbers of individuals to contact for information in an emergency. The shipper may be held accountable for the costs associated with cleaning up the incident site. The form also identifies the airport of departure and of destination and specifies whether the material is radioactive, Cargo Aircraft Material Only, or allowed aboard a passenger aircraft. The shipper must list the proper shipping name, the hazard class (such as flammable, corrosive, or poisonous), the UN/NA number, the number and type of packages, the weight, and additional handling information (such as “Keep away from foodstuffs and animals”). Again, look for the red candy-striped envelope.
 (2) The restraining net between the main cargo compartment and the flight deck-position #1, where “Cargo aircraft only” dangerous goods are stored. |
There should be a waybill or airbill attached to the shipment. The airbill indicates whether the material is a dangerous good. Some shipments, such as radioactives, require an additional permit or certificate. The crew will also have a “Load Planning Sheet,” which indicates the weights and locations of the cargo at each position on the aircraft. The initials “DG” may be written in the position square on the form, indicating the location of the dangerous cargo.
The paperwork may be anywhere on or near the flight deck, or it might be in the possession of a crew member exiting the aircraft. Ask the crew for the paperwork before starting an extensive and unproductive search.
PACKAGING
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Properly packaging dangerous goods is always a concern. For example, a hazardous leak is a real problem on the ground; imagine how complex it becomes to mitigate an unconfined leak while airborne. Packages become damaged during loading and offloading operations. Although air carriers are very careful and accidents are rare, they do happen.
There are very detailed and extensive packaging, labeling, and marking regulations based on a thorough and rigorous testing process designed especially for air cargo. Different types of packaging systems are subjected to stacking, burst, and altitude pressure tests. There are also drop tests, and some packages must survive a six-foot drop and survive intact.
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Another set of packaging has been designed for radiological shipping. Liquids must have an inner and an outer package. A sufficient amount of a nonreactive absorbent, such as vermiculite, must be between these two layers of protection, to absorb the entire inner package liquid without penetrating the outer layer of protection.
Be prepared also to encounter various types and sizes of packaging-from fiberboard boxes and drums to glass carboys, lead pigs, plastic and steel drums, jerry cans, and compressed gas cylinders. Only DOT-IATA-approved packaging can be used. It must be accompanied by the required official paperwork, which, as already noted, usually has a 24-hour emergency phone number.
EMERGENCY ACTION STEPS
Without question, good sound judgment and a detailed size-up are critical. If you don’t have a dedicated haz-mat response team, call for one immediately. Follow your department’s standard operating procedures to the letter. Don’t get creative. Gather all the information you can before committing to action. If the airport has around-the-clock freight operations, go directly to that facility and ask for assistance. Simply calling the airport of departure and contacting the freight agency that loaded the aircraft can make the incident much safer and easier to mitigate. The alternative can be disastrous and deadly.
Set up wide inner and outer perimeters. You can always decrease the zone, but you may not always be able to increase it. Consider the need to evacuate not only the immediate area but also the airport and surrounding communities. Avoid contact with the released materials to the greatest extent possible. Build several decontamination areas immediately. Attempt rescues only if prudent and your department is familiar with the aircraft and aircraft rescue. If not, find some help. Why make the situation worse by committing and exposing more troops who are not able to accomplish the task?
Keep in mind that it is the cargo company’s aircraft and problem. You are to provide the appropriate support under the company’s guidelines.
Do not fight stubborn cargo hold fires with conventional methods. A safe, effective procedure is to cut holes in the fuselage and insert nozzles to flood the interior of the fuselage. Piercing nozzles off an aerial are excellent for combating these types of confined space dangerous goods fires. Using thermal imaging cameras to pinpoint the seat of the fire eliminates the need to commit personnel to a fact-finding mission. The selection of agents is also important; halon replacement agents and mass dry chemical applications are excellent choices and minimize damage and personnel exposure.
GUIDELINES
We have touched only lightly on an extremely complex subject. Other than becoming an expert in this field, perhaps the best offense is a great defense. We offer the following guidelines for inclusion in your action plan.
- Visit annually with appropriate responders your local airfreight carriers and airport.
- Make sure that all designated responding apparatus are equipped with relevant information: the DOT Guidebook, airfreight regulations, emergency phone numbers and contact personnel, graphic floor plans highlighting the dangerous goods loading positions, crew rescue areas and procedures, and aircraft hazardous systems locations for respective freighter aircraft.
- Confess and communicate to the additional responders you call for. Call for help. This is not the time or place for heroics.
- Don’t rush in. Be patient. Develop a well-thought-out plan that emulates your department’s.
- While en route, dial the 24-hour emergency number for the airfreight company. Hopefully, it is in your response plan. Ask for assistance and the response of its key personnel.
- When they arrive, give them a complete report. Document your action steps. There will surely be an investigation. An inexpensive audio recorder in your turnout pocket (with fresh batteries) greatly facilitates documentation.
- Be prepared for a large-scale evacuation. Make sure you have radio compatibility with all local branches of law enforcement. Use these agencies to clear areas so you do not deplete your staff. These agencies are trained for large-scale evacuations.
- Make sure that your department and additional responders know how to set up effective hot zones and cold zones and multiple contamination areas and that you have the equipment to do these things.
- Be prepared for sustained operations. Any large-frame aircraft incident involving dangerous goods will be lengthy. Our research has shown that these types of incidents are very time consuming and labor intensive.
- Be prepared to assist with cleanup, but don’t take the lead unless you and your department are experts in this arena. Let the air carrier control the incident. It is this company’s aircraft, material, and problem-most importantly, its employees have the expertise.
- Train as though your life depends on it. It does.
John Carr, a 24-year career veteran fire officer (retired), graduated from the USAF Firefighting School and has held many positions including flight engineer, cargo aircraft, USAF; advisor to the Airline Pilots Safety Committee; ARFF Committee secretary, IFSTA; and coordinator for ARFF/Airlines Personnel Recurrent Aircraft Emergency Egress Training. He has a bachelor’s degree in management and is a consultant on aircraft rescue. Carr is special sales accounts manager and editorial advisory board member of Fire Engineering and a member of the FDIC West-Sacramento Advisory Board.
Les Omans is a 27-year fire officer with the San Jose (CA) Fire Department. He is a firefighter with the California Air National Guard and was a firefighting instructor with the U.S. Navy. He has participated in committees for the NFPA, IFSTA, ARFF Working Group, and other nationally recognized fire service organizations.
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