HIGH-ALTITUDE HAZ MATZ
A Boeing 707 cargo freighter takes off from a major East Coast airport with a full load, bound for Europe (a freighter is a large aircraft that transports cargo only). On board is more than 15,000 pounds of hazardous materials. Most of it is improperly packaged and labeled, and it lacks the proper paperwork. Over the Atlantic Ocean the three-member crew smells and observes smoke coming from the main cargo deck. The captain declares an emergency and sets a return heading for the nearest airport on the mainland United States. They crash land on the airport approach, and if crew, cargo, and aircraft are a total loss. The resulting investigation discovers that several glass jars of nitric acid were packed in sawdust and shipped as ordinary machinery. This strong acid leaked and reacted with the organic sawdust, generating heat and eventually fire.
A crowded passenger aircraft is on a routine flight between two Midwestern airports. The flight attendants and numerous passengers smell a strong chemical odor coming from the rear of the aircraft. Several passengers complain of dizziness and nausea. The captain is notified and the first officer investigates. The first officer reports that it smells like a fuel leak inside the fuselage. The captain declares an emergency and diverts to the nearest airport. Upon landing, the pilots taxi the aircraft off the active runway and immediately start an emergency evacuation. Sixteen passengers suffer back and leg injuries from using the evacuation slides. The resulting investigation indicates that just prior to the flight a passenger had spilled gasoline on his pants while filling up his rental car.
A female passenger boards an aircraft with several carry-on bags. In one of the bags is a bottle of a common household stripper, sold over the counter in most hardware and paint stores. During the flight some of the stripper leaks out, dissolving parts of her purse, her shoes, and the aircraft carpet and burning her legs and feet. Several of the passengers complain of discomfort and nausea. The crew has not been trained to handle a situation of this type and has no idea what to do.
A narrow-body passenger aircraft is en route to a Southeastern airport. Many passengers, the flight attendants, and a deadheading pilot (a pilot riding as a passenger) smell a strong, acrid odor. A considerable amount of smoke appears from the floor vents and fills the passenger cabin. Conditions deteriorate to the point that a section of the floor begins to feel hot and spongy and several chairs in the area begin to char. The deadheading pilot calls the flight deck and recommends declaring an emergency and making a quick descent to the nearest airport. The captain does not take the situation seriously, assuming the smoke is from a previous problem with the auxiliary power unit. The flight attendants move passengers away from the obvious problem area. On the final approach to the airport of destination, the smoke is bad enough to affect the pilots on the flight deck. The plane touches down and on reaching a clear taxiway, the crew begins an emergency evacuation using the slides. The airport fire department is notified and responds. On arrival, firefighters open the involved cargo hold and observe heavy smoke and moderate flame from the back of the compartment. During the incident two firefighters, three airline employees, and nine passengers are sent to the hospital for smoke inhalation. A 50 percent solution of hydrogen peroxide (a strong oxidizer) and sodium orthosilicate (a corrosive) had been shipped undeclared, as laundry equipment, in a contaminated fiberboard drum. (Fifty percent solutions of hydrogen peroxide are forbidden and cannnot be legally carried on any aircraft—cargo or passenger.) The materials came in contact with each other during the flight, reacted, and ignited. The aircraft sustained more than a million dollars worth of damage. Five floor beams and 63 control cables were destroyed or damaged. The plane and the people on board were lucky to have landed safely, considering the circumstances.
These are all true stories involving hazardous-material incidents on aircraft. Our research indicates that more and more shippers are turning to air cargo to move valuable, fragile, or time-critical shipments rapidly across great distances. Many trucking companies have expanded into air carrier activities. Even the United States Postal Service has a fleet of aircraft. It is clearly evident that air cargo operations are increasing significantly every year, along with the number of aircraft-related hazardousmaterial incidents. These incidents often go unreported to minimize adverse publicity.
All aircraft accidents must be considered and treated as hazardous-material incidents. They involve large amounts of fuel and quantities of toxic hydraulic fluids. In the search for lighter and stronger aircraft construction materials, more and more composite materials are being used. These materials, especially the carbon fiber type, can present respiratory and skinirritant hazards similar to those of asbestos. Responding firefighters also will be confronted with explosive compressed gas cylinders, high-pressure nitrogen-filled tire assemblies, and extensive quantities of combustible magnesium. Plastic, foam rubber, and leather used in aircraft interior finishes and personal items give off a wide assortment of toxic gases under fire conditions. Military aircraft incidents can involve weapons, high explosives, composite materials, radioactives, and exotic fuels such as hydrazene. The presence of hazardous cargo only complicates this already extremely dangerous situation.
AIR CARGO REGULATIONS
“Hazardous materials” is a fire department term. In aircraft, hazardous cargos are 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). These standards are issued by the Department of Transportation. They apply to all modes of transportation, including trucks, trains, ships, pipelines, and aircraft. They are applicable only in or over the United States.
The second set of regulations 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 body with authority over air transport issues. Its Dangerous Goods Panel meets every two years to issue or update the Technical Instructions. These regulations are enforced worldwide, including in the United States.
Most carriers use a document called the “Dangerous Goods Regulations,” published annually by the International Air Transport Association (LATA). Based on the ICAO Technical Instructions, it contains additional information on requirements and procedures recognized in the air carrier industry throughout the world. Firefighters most likely will encounter this document when visiting air cargo facilities on or near their airport.
Each set of regulations has tables that list more than 2,000 chemicals ancl identify how the material must be packaged, labeled, and loaded and the maximum allowable quantities that can be shipped. If a shipper wants to transport a material not listed in the tables, the chemical must be analyzed by a chemist, shipped like a material with similar hazards and characteristics listed on the table, and have a special permit.
Both 49 CFR and the I ATA Dangerous Goods Regulations are extremely complex and detailed. Although copies of each should be in the fire station library, firefighters only need a very general familiarization with the regulations. It is extremely critical that fire personnel be able to recognize when dangerous goods are involved in an airport or aircraft incident and take the necessary steps to protect themselves and the public. Such knowledge comes from preplanning cargo aircraft and facilities and learning what the packaging and paperwork look like, how and where the dangerous cargo will be loaded, what resources are available for help, other sources of information, and proper first responder standard operating procedures.
TYPES OF HAZARDOUS CARGOES
There are four categories of dangerous goods. The first category includes materials forbidden on any aircraft, in any quantity, under any circumstances. These materials are listed in the chemical tables in both sets of regulations. The 50 percent solution of hydrogen peroxide mentioned earlier is such a forbidden material. The maximum allowable concentration of hydrogen peroxide is 32 percent, and it can be transported on cargo aircraft only (not passenger) and is limited to one quart per package. However, even these forbidden materials can be carried in certain situations with a special permit. Therefore, you’re liable to encounter anything on aircraft.
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 affixed to the package. 1 his label should be a signal to firefighters that the involved chemical or chemicals are extremely hazardous. Packages of these materials must be accessible by the crew during flight. Except for “Cargo aircraft only” radioactives, these materials usually will be in containers or on pallets next to the flight deck (cockpit). If there are multiple pallets of these materials on the aircraft, there must be a minimum of an 18-inch pathway across each pallet for the crew to access and check the shipments.
The third category includes materials allowed on passenger or cargo aircraft in inaccessible cargo holds, which are the lower 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 that carry passengers and cargo in accessible cargo areas on the main deck. These types of aircraft often are used by foreign carriers and may be encountered at large international airports. Narrowbodied ones are used in Alaska by several domestic carriers. There are no restrictions on amounts of dangerous goods allowed on passenger aircraft in cargo areas accessible during flight. “Cargo aircraft only” materials are forbidden on passenger aircraft. Some passenger airlines also may limit the types of materials allowed on their aircraft. Many will not carry poisons or flammables of any kind.
(Photos by authors.)
Airline personnel closely check all shipments of declared dangerous goods, whether on cargo or passenger aircraft. They complete a questionnaire or checklist and sometimes affix a copy to the package. Thousands of packages are refused every day because of problems with the paperwork, labeling, marking, and packaging.
The fourth category is an unofficial one and involves undeclared dangerous goods. These are shipments that the airline does not know are on board the aircraft. They are materials in luggage, mail, or packages, and the person responsible either does not realize they are dangerous, is ignorant of the regulations, or deliberately is trying to conceal them to avoid the extra cost. The first three scenarios described earlier are examples. There are many products that can be purchased in grocery, hardware, sporting goods, or variety stores that would be dangerous in an aircraft environment. (A sportsperson can carry weapons and up to five pounds of ammunition on board in an approved locked container.)
A statement warning passengers and shippers about undeclared dangerous goods is required to be posted at ticket counters and cargo check-in areas. These posters often are difficult to see or are nonexistent. Airline employees rarely question shippers unless the package is labeled as dangerous, is leaking something, is hot to the touch, or is emitting smoke or vapor or the shipper says something to arouse suspicion. More than half of aircraft haz-mat incidents involve undeclared dangerous goods.
Suspect dangerous goods on board almost any type of aircraft, from general aviation to the commercial passenger and cargo. Anyone can charter or hire an aircraft to transport hazardous materials. No airport is immune to this type of activity. Many cargo carriers will move goods on smaller feeder aircraft to the larger airports, where the materials are transferred to largerframe aircraft destined for a major cargo hub.
Aircraft void of windows behind (aft of) the flight deck area probably are carrying cargo. Many older passenger aircraft have been retrofitted to carry cargo. Often they still have the original passenger windows or window frames. Except for door one left (L-l), die other service doors and escape hatches may not operate from the outside. On most larger cargo aircraft, door L-l usually has an evacuation slide that may be armed and ready to inflate if the door is opened in an emergency crew evacuation situation.
The aircraft is divided into a large, open, upper, or main cargo deck and two or more lower cargo holds. The main cargo deck has designated positions numbered sequentially from the nose to the tail. On the large-frame jet cargo aircraft such as the Boeing 727 and 747, cargo is loaded into the unit load devices placed at each position. Unit load devices consist of a metal or metal/plastic container, sometimes called an igloo, or a thin metal cookiesheet-like pallet. The cargo is secured to a pallet with netting and plastic covering to eliminate any moisture during loading. By properly stacking the packages, you can construct a pathway across the pallets if necessary. The containers or igloos are designed to closely fit the interior walls of the aircraft. Once the aircraft is loaded with containers, you cannot move around or over them. There are also half containers called demi containers. Two demi containers will be placed at one position. large jet aircraft also have containers designed to fit in the lower cargo areas. The smaller jet transports are bulk loaded in their lower areas. These bulk loads usually do not exceed 75 pounds apiece.
Federal Express Corporation calls containers loaded with dangerous goods “haz cans.” It paints the tops of these containers red, and there is a fitting that a halon extinguishing system is connected to during flight. Dangerous goods must be secured in the containers with restraining nets. This requirement does not apply to ordinary cargo. In a clear plastic envelope or wired to the outside of the pallet or container is a card identifying the types of dangerous goods on or in that unit load device. It has a red candy-striped border and lists the hazard class numbers of the materials at that position. For example, a “3” for flammable liquids and a “6.1” for poison B might be written on the card, indicating that these types of materials are inside the container or on the pallet. Remember that any cargo paperwork with a red candystriped border should warn firefighters of the presence of hazardous materials. The aircraft and containers will not have placarding, such as is found on trucks and trains, to indicate contents. Although there are segregation regulations that prohibit certain noncompatible materials from being loaded in the same container, we have seen some frightening combinations of dangerous goods.
Unit load devices may be loaded at facilities on or off the airport and trucked to the aircraft. The containers or pallets are raised by a lifting device to a large cargo door and then slid on rollers to their designated position, where they are secured in place with locking devices. Tail stands may be installed to stabilize the aircraft during the loading.
Type and location of cargo doors vary from aircraft to aircraft and carrier to carrier. Most large-frame cargo aircraft have a large cargo door on the left (port) side, either forward or aft of the wings. The nose areas of a few aircraft (some 747s) raise up to accommodate loading unit load devices from the front. The tail swings sideways to open the rear of some older propeller aircraft. Main cargo doors on large-frame jet aircraft and some lower cargo area doors operate on either hydraulic, electrical, or compressed gas power.
The only separation between the cargo and the crew is usually a restraining net and a lightweight bulkhead. Some aircraft flight decks can be positive-pressured to help keep smoke or fumes out. The flight crew usually is equipped with portable extinguishers, permanent crew breathing oxygen in the flight deck, a 15minute portable self-contained breathing apparatus, and a copy of the orange DOT Hazardous Material Guidebook.
When responding to an incident, request as soon as possible the response of an airline representative and preferably an aircraft mechanic familiar with the operation of the involved aircraft. As with any aircraft incident, responding firefighters should consider disconnecting the power to the aircraft at the batteries, flight deck, and auxiliary and ground power units. The aircraft landing gear must be pinned and the wheels chocked.
The documentation that accompanies dangerous goods varies from carrier to carrier. Firefighters must be familiar with the types of aircraft and carrier operations that frequent their area.
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 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 is affixed to one of the packages visible from the outside of the shipment. The flight crew (pilot) may have a copy for each shipment in or around the flight deck area.
On the major cargo carriers, the crew usually has a form called “Pilot’s Notification for Loading of Restrictive Articles” or “Dangerous Goods Load Notification to Captain.” Each carrier has a slightly different name and format for this form, but the same information is documented. Fite cargo loading facility compiles the information from all the Shipper’s Declarations onto this one form.
The “Shipper’s Declaration of Dangerous Goods” has a considerable amount of valuable information about the involved material. Responding firefighters should make every attempt to get a copy. It identifies the shipper’s and consignee’s addresses. Both may be able to provide information and assistance with the involved material, and some may even have a response team. The shipper may be responsible for paying cleanup costs. The form identifies the airports of departure and destination, whether the material is radioactive, if the material is “Cargo aircraft only” (more dangerous), or if it can be transported on passenger aircraft. It lists the proper shipping name, each hazard (such as flammable, corrosive, or poisonous), the hazard class, the UN/NA number, the number and type of packages, the quantity, the weight, and additional handling information (such as “Keep away from foodstuffs and animals”). It will have the characteristic red, candy-striped border.
There also may be an air waybill or airbill. A copy also may be affixed to the shipment. There usually is not much information on the airbill except that the material is a dangerous good. Some shipments, such as radioactives, require an additional permit or certificate. The crew also has a “1-oad Planning Sheet,” which indicates the weights and destinations of the cargo at each position. The initials “DG” may be written in the position square on the form to indicate dangerous goods loaded at that location. The hazardous materials on board also may be listed on this form.
The paperwork can be anywhere on or near the flight deck. It must be accessible by the crew and may be found on a clipboard, in a sleeve or slot mounted on a bulkhead, or in a briefcase. Do not expect the crew to bring the shipping paper with them when they evacuate the aircraft in an emergency.
Problems with properly packaged dangerous goods are rare unless the package is damaged during loading operations or from an aircraft incident. There are extensive and detailed packaging, labeling, and marking regulations. These regulations are based on a thorough and extensive testing process. Different types of packaging systems are subjected to stacking, burst, and pressure tests. There are drop tests—and some types of packages have to survive a six-foot fall. There is another group of tests especially for radioactive packaging.
Liquids must have an inner and outer package. Between the two there must be enough of a nonreactive absorbant, such as vermiculite, to absorb the entire inner package liquid contents without penetrating the outer package.
You may encounter any type and size of packaging—from fiberboard boxes and drums to glass carboys, lead pigs, plastic and steel drums, jerry cans, and compressed gas cylinders. Only DOTor IATA-approved packaging can be used and must be indicated on the shipment and papers.
Besides the copy of the “Shipper’s Declaration of Dangerous Goods” attached in a clear plastic envelope, a considerable amount of information is found on the package itself. The name and address of the shipper and consignee are listed as well as a label for each hazard, the proper shipping name, the UN/NA number, the weight, and the quantity of the material. If the material is a liquid, arrows and/or “This end up” will indicate the upright position. There also may be additional handling information as well as a 24-hour information telephone number.
EMERGENCY ACTION STEPS
We strongly recommend that all first responders have immediate access to the DOT Emergency Response Guidebook. A list of your department’s hazardous-materials standard operating procedures should be permanently listed on the back of this reference book.
First responders must approach cautiously from upwind. At the first indication of a possible hazardousmaterial situation, stop and position at a safe location. Report the exact location, give a good report on conditions, and call for the necessary assistance such as law enforcement, an air carrier representative, the shipper (if known), airport operations, an ambulance, and specialized hazardous-material response teams. Establish the initial control zones, security perimeters, and decontamination zone and isolate the area from nonessential personnel. Consider the need to evacuate endangered persons.
Avoid all contact with the released material or materials. Standard turnout or bunker gear provides very little protection from many types of hazardous materials. Confined areas encountered in cargo aircraft, shipping containers, and airport cargo facilities further concentrate and intensify the conditions. Rescue injured or trapped persons only if you can do so safely. Eliminate ignition sources by disconnecting the aircraft batteries and power units and by shutting off nearby vehicles.
If there is a fire in an unaccessible part of an aircraft cargo area, consider flooding the aircraft interior with large quantities of carbon dioxide or halon from tank trucks. Close up and secure all openings to the aircraft until the fire is controlled. Thermal imagers can be used to locate hot spots in the cargo or aircraft.
Start collecting information, determining the conditions, and identifying the released material. Obtain the shipping papers, interview the crew or cargo facility personnel, and read the information on the involved packages from a safe location. Do not get involved in any cleanup operations. First responders should stabilize the situation only. Let properly trained and equipped personnel manage and conduct all specialized operations. Be part of the solution, not part of the problem.
If you would like a packet of information concerning cargo aircraft, cargo operations, and dangerous goods regulations with samples of shipping papers and other related forms, send a check or money order for S8.00 to Aviation Emergency Training Consultants, 21095 Lauretta Drive, Cupertino, CA 95014.