LEGAL SPIN
BY JASON DICKSTEIN
BY JASON DICKSTEIN
Hidden Hazmats in Aircraft Parts – Are You Protected?
Hazardous materials, also known as dangerous goods, are a tremendous concern for the aviation industry for several reasons. First, there are a great many hazmats in aircraft and aircraft parts. Second, the hazards are not always obvious to the untrained eye, so it is easy to overlook a serious safety problem unless you have the right training. Third, hazardous materials have caused aircraft accidents – the best known example was the 1996 Valujet accident caused by chemical oxygen generators but there are many other less-well-known examples. Fourth, because of the history of aircraft accidents caused by hazardous materials, regulator tend to be unforgiving when it comes to hazmat violations. During the past ten years, the United States has made efforts to amend its hazardous materials rules so that they are more in compliance with international standards. At the same time, the remainder of the world has increased its expectations with regards to safe shipping of these articles. This has made international compliance much easier, but it has also removed most of the excuses available for non-compliance.
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Do you get Periodic Training? Training is at the root of the international hazmat enforcement regime. Under United States law, anyone who makes any decision affecting the safe transport of hazardous materials is required to be hazmat-trained. This means shipping personnel must be trained and certified, but it also means that supervisory personnel and support personnel must also be trained and certified. If one person places an aircraft part in a box, and then the shipping department seals and ships the package, then the person who placed the aircraft part in the box also is subject to the training requirements. One Department of Transportation interpretation memo explains that even administrative assistants must be trained if they (for example) merely participate in the creation of hazmat shipping papers (like merely typing the information into a form based on hand-written notes created by someone else).
The international standards for periodic training require recurrent training every two years. U.S. law applies the two year standard to air carrier personnel (and those performing transport related functions for air carriers) and applies a more relaxed three year recurrent training standard to non-air carrier personnel. For those shipping internationally from United States manufacturing, repair or distribution businesses,
this probably means that they must get training every two years to meet the standards of the nations to which they ship, even though U.S. law may only require recurrent training every three years.
What Aircraft Parts are Hazmats? A surprisingly broad range of aircraft parts are considered to be hazmat. Aircraft parts with hazmat residues in them continue to be regulated as hazmats. This means that engine components with residual fuel in them are regulated as hazmats. Any amount of residue will usually make the part a hazmat, so a good rule of thumb is that if you can smell the fuel residue, then the part is regulated as a hazmat. Bear in mind that a fuel stain on
36 Aviation Maintenance |
avm-mag.com | February / March 2013 re you violating the hazmat shipping regulations without even knowing it?
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