Dangerous Goods Requirements for All Operators

The Civil Aviation (Safe Transport of Dangerous Goods by Air) Order 2020 (The Order) came into force on 1st December 2020.

The Order places responsibilities on all operators of M- Registered aircraft whether they are approved to carry dangerous goods or not.

From 1st December 2020, all M- Registered operators must: -

  • Ensure all operational staff receive initial and recurrent training within 24 months;
  • Provide guidance on the carriage of dangerous goods to all operational staff;
  • Provide information to passengers on what can be carried; and
  • Provide emergency response information.

Guidance on how to comply with these requirements can be found below.

Dangerous goods cannot be carried on-board an aircraft:-

  • unless the operator has been approved to carry dangerous on-board the specific aircraft by the IOMAR;
  • unless the items of dangerous goods are permitted to be carried by Passengers and Crew (see below);
  • for items required to provide Medical Assistance (see below); or
  • for items required to provide Veterinary Aid (see below).

Passengers and crew can only carry dangerous goods either in baggage or on their person provided they are:

  1. Permitted in accordance with The Order & the ICAO Technical Instructions; and
  2. For personal use only.

The Table of Permissible Items of Dangerous Goods is published in RL5.

As non-carry operator, only those items which are included in the table can be carried on-board.

An approval is not required for dangerous goods which are: -

  • to provide in-flight medical assistance to a patient, when those dangerous goods are placed on board with the approval of the operator; or
  • form part of the permanent equipment of the aircraft when it has been adapted for specialized use, providing that:
  1. gas cylinders have been manufactured specifically for the purpose of containing and transporting that particular gas; and
  2. equipment containing wet cell batteries is kept and, when necessary, secured in an upright position to prevent spillage of the electrolyte.

An approval is not required for dangerous goods which are carried for use in flight as veterinary aid or as a humane killer for an animal.  Such dangerous goods must be stowed and secured during take-off and landing and at all other times when deemed necessary by the pilot-in-command. 

The dangerous goods must be under the control of trained personnel during the time when they are in use on the aircraft.

All operational staff must receive initial and recurrent training (within 24 months) commensurate with their responsibility.

What does the term Operational Staff include?

Operational Staff includes Flight Crew, Cabin Crew, Flight Engineers, Loadmasters, Load Planners, and Flight Operations Officer/Flight Dispatchers.

From 1st January 2021, the ICAO Technical Instructions move to competency-based training, instead of the usual categories (e.g. Category 6 for Acceptance Staff and Category 16 for Flight Crew of non-carry operators).

From 1st January 2021, dangerous goods training must include:-
a) General awareness/familiarisation training (so personnel are familiar with the general provisions)
b) Function-specific training (so personnel can perform competently any function for which they are responsible); and
c) Safety training — (so personnel can recognize the hazards presented by dangerous goods, on the safe handling of dangerous goods, and on emergency response procedures).

To assist operators, the IOMAR has produced a template training course specifically written for non-commercial, non-carry operators.  Please refer to RP 57 for information on how to request a copy of the template training and the customisation requirements.

The operator must provide information to the flight crew on the actions to be taken in the event of an emergency involving dangerous goods.

Registry Leaflet 7 contains example checklists incidents involving dangerous goods.

ICAO publish the Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (ICAO Doc 9481), which can provide operators with additional guidance on how to handle such emergencies and includes the fully expanded checklists contained in RL7. Some operators choose to carry the latest copy of the manual on-board.  Copies are available from the ICAO Store.

Not all dangerous goods are easily identifiable.

Your passengers may not even be aware they are carrying dangerous goods.

In order to assist operators to prevent passengers inadvertently taking undeclared dangerous goods on-board, ICAO have produce a list of ‘General Descriptions of Dangerous Goods’ , a copy of the list is published in Registry Leaflet 6.

Operators of Large and TurboJet Aircraft should include a copy of the list in the Company Operations Manual.

For operators who do not require a Company Operations Manual, a copy of the list (or RL 6) should be provided to relevant operational staff.

Munitions of War (MoW) are : -

    1. weapons or ammunitions; or
    2. articles containing explosives, noxious liquids or gas; or
    3. any other thing, that is designed or made for use in warfare or against persons, including components or accessories for such weapons, ammunition or articles.

Sporting Weapons are: -

    1. weapons or ammunitions; or
    2. articles containing explosives, noxious liquids or gas; or
    3. any other thing, including parts, whether components or accessories, for such weapon, ammunition or article

that is not a munition of war.

Approval for the carriage of Sporting Weapons from the IOMAR is NOT required.

How must Sporting Weapons be stored on board the aircraft?

Sporting Weapons must be : -

    1. stored in the aircraft hold which is NOT accessible from the passenger cabin; and
    2. unloaded (if the sporting weapon is a firearm).

The operator must approve the carriage.

If the aircraft hold is accessible from the passenger cabin, the operator must contact the Registry to request an exemption.

An operator MUST have specific approval from the IOMAR to carry Munitions of War.

The PIC must have a copy of the approval issued by the IOMAR to carry munitions of war. 

The approval will include the type, mass/quantity and location of any munition of war on board or suspended beneath the aircraft and include any conditions imposed by the Registry.

Munitions of war must be stored in a compartment that is NOT accessible from the passenger cabin.

Operator who carry police protection officers or armed bodyguard must contact the Registry to discuss obtaining the required exemptions.