Can I pack that?
We follow the rules about dangerous goods when we travel on RPT, and there are trained people and security processes to make sure we comply, but do we know how they apply to our light aircraft? The carriage of dangerous goods can be tricky. Extremes of temperature, changes in pressure, and aircraft vibration can turn the tables on an otherwise “safe” item of luggage. Some dangerous goods are more obvious than others, eg chainsaws, explosives, radioactive items and volatile chemicals. But what about those ‘harmless’ aerosols and spare batteries you’ve thrown into your bag? Can you head outback with the can of Aerogard onboard?
CASA released a “Top Ten Least Wanted’ Dangerous Goods (DG) list in 2016 identifying the ten most common and potentially dangerous items carried by air travellers on RPT aircraft in Australia.
- Lost and damaged smartphones
- Spare batteries and portable power packs
- Chainsaws, whipper snippers and other devices with internal combustion engines
- Gas cylinders and camping stoves
- Paint and paint related products
- Nail polish remover (Acetone)
- Compressed Oxygen
- Lighters and matches
After a challenging day of no-progress circuits, there would arguably be a few instructors who have felt a little under-equipped without item 3, but items 1 and 2, should alert us to being more aware of the possible risk of everyday carry-ons.
The average private/general aviation pilot will encounter four main types of dangerous goods.
- Those which are part of the aircraft’s operating equipment (tyres, batteries, fire extinguishers, fuel, agricultural spray, feral animal baits etc.)
- Replacements for aircraft equipment (fuel control units, carburettors, batteries, damaged tyres)
- Those which can be carried by passengers
- Those which they do not know about
We’ll leave aircraft parts and replacements for another day and focus on passengers and private operators.
CASA’s Dangerous Goods Inspectors have investigated many dangerous goods occurrences over the decades. The most dangerous of goods are those that you don’t know about; with the vast majority of chemical leakage, fires and spontaneous and rapid disassembly come from hidden and misdeclared dangerous goods.
You’ll find quite a few answers about the carriage of dangerous goods on the CASA website, with useful information on aerosols, camping equipment, fuel cell systems, lithium batteries, thermometers etc. Check it out. If in doubt, ask the question. Send an email to dg [at] casa.gov.au or phone 131757.
Batteries and portable power packs
This is the age of the portable electronic device. We’ve all got at least one; some have far too many for the good of their marriage. In any case, spare batteries are becoming passé. These devices have self-contained batteries and need charging. And some devices are marketed as a torch with the power and ability to jumpstart your car. The AA alkaline, NiCad, NiMH and similar dry-cell batteries we use for equipment like headsets and some handheld GPS units do not store the high amount of energy that a lithium battery does, so you can safely carry spare ones in your baggage; however, you’ll find that all Australian airlines require all spare batteries to be carried in the cabin.
Short-circuiting batteries have been responsible for numerous on-board fires, so it’s important that all spare batteries have their terminals protected properly. You can do this by:
- keeping batteries in original retail packaging; or
- insulating the battery terminals by taping over exposed terminals; or
- placing each battery in a separate plastic bag or protective pouch
Lithium batteries bring a different set of challenges. Lithium metal (non-rechargeable) batteries are usually very stable, have a long shelf-live but will burn with devastating effect in a fire. Lithium button cells (the small flat ones found in watches and hearing aids) are far more benign.
Lithium ion (rechargeable) batteries tend to be more volatile and can become unstable under certain conditions. Certainly don’t think about packing any battery that looks unhealthy (eg bulging, discolouration, split case, leaking fluid). Other risk mitigation measures with rechargeable batteries include not recharging or discharging your batteries just prior to departure; taking them at a 30-50% State of Charge; not leaving them in a hot car or aircraft cockpit. Typically the batteries that power your phone, laptop and camera are all under the 100 watt-hour (Whr) rating. Larger batteries (i.e. e-bikes) often exceed the 160 Whr limit and are not permitted as part of the normal passenger provisions.
DG regulations limit flammable aerosols to medicinal or toiletry articles. Examples are hair sprays, colognes, deodorants, shaving foam, personal disinfectant (hand sanitizer), personal insect repellent, etc. In short, if you would spray it on your body, you can probably take it.
If you wouldn’t spray it on your body, (think window cleaner, fly spray, furniture polish) then only those with a non-flammable propellant are allowed. (There goes your can of Mr Sheen, sorry! It’s marked “Flammable Gas”)
Good news for private pilots
Civil Aviation Safety Regulation 92.175 relates to goods carried by private operators. This regulation permits aircraft owners and private operators a lot more flexibility when carrying dangerous goods. Check it out.
The rationale is that a private operator, as the carrier of the goods and operator of the aircraft, should be able to make a reasonable judgement and self assessment of the risk presented by the dangerous goods that they intend to carry.
Beyond asking if it’s legal, the more important consideration for private operators is to weigh up whether the proposed carriage of dangerous goods is safe.
If you are hiring the aircraft, you should check on the aero club's, or owner/operator's policy; they may prohibit certain items and their insurer’s policy may not cover incidents arising from dangerous goods.
Even though you’ve done everything that you can reasonably think of - now is the time to think through what you’ll do in an emergency. Communicate those action plans to the passengers. Give particular thoughts to actual emergencies – i.e. engine failure, engine fire and fire in the cabin; and potential emergencies – noticing fuel or gas fumes.
Remember, for the private pilot, CASR 92.175 is a rule that gives you flexibility in carrying DG. Just think about the risks and how you can reduce them. Invariably, if you think and plan carefully ahead, and apply some common sense and caution, you will not have to put your emergency drills into practise, nor have an awkward conversation with your insurer!
If you find that CASR 92.175 doesn’t help you, then contact the Dangerous Goods Inspectors at CASA on 131757 or dg [at] casa.gov.au. There may be other options available that can be explored with you.
Fly safe and have fun.