And while the UN is concerned about flammable and other hazardous freight on all forms of transportation, Rooney knows that ICAO’s regulation over airlines is a big responsibility. But in terms of so-called dangerous goods — anything from paint (flammable) to some pharmaceuticals (radioactive) to lithium batteries (explosive) — flown on passenger and cargo flights, Rooney has seen the number of additions to ICAO’s dangerous goods framework diminish in the last few years. This, she says, may be because there is simply a limit to new chemicals and substances being released. While there may be fewer substances to cover, there has been a lot of media coverage of the goods that still need to be regulated.
Rooney recently took time out of preparing for her June meeting at the UN — where agenda topics would range from electronic transmission of dangerous goods information to exemptions and changes to dangerous goods signage — to talk with Air Cargo World about how the ICAO Dangerous Goods Panel approaches dangerous goods and the evolving state of hazardous freight.
Air Cargo World: Is dangerous goods regulation a big part of ICAO?
Katherine Rooney: Within ICAO, the secretary general most recently has recognized the increasing importance of dangerous goods and has decided to devote a separate section to dangerous goods in our hierarchy, showing the importance on dangerous goods that he is placing on the subject. Before, it was part of flight operations.
ACW: How does ICAO develop its regulations toward dangerous goods?
Rooney: Practically no air journey is going to be done in isolation; you’re going to be transporting with other modes of transport involved. We work very closely with the UN Committee of Experts on the Transfer of Dangerous Goods. They publish recommendations on model regulations every two years. We then take those model regulations, look at them from an aviation perspective, and make changes, if necessary. For multimodal harmonization purposes, all the modes are encouraged as much as possible to keep to what’s decided on at the UN.
The general principle with the UN is to try to regulate dangerous goods so as to prevent, or at least mitigate as much as possible, any incidents that endanger public safety or harm the environment. The regulations are a balancing act between getting the regulations so that they provide safety, while at the same time, don’t hinder the movement in the transport side. You’re basically reducing the risks to a minimum while making transport feasible.
ACW: How are new substances added to the dangerous goods list?
Rooney: If you were to take all uniquely identified chemicals — the last count I heard was over 60 million registered substances on the chemical abstract service — there’s no way that we can handle that number. So they came up with a series of tests and criteria to determine which substances can be identified as being dangerous goods in transport. They take into account the physical and chemical characteristics, the type of packaging or containment that’s going to be used, and what type of response procedures that would be most appropriate if there was an accidental release.
Based on that, the UN came up with nine classes of dangerous goods, with a listing of very approximately over 3,000 items of dangerous goods, some of which are very generic family names such as alcohols. The classes of dangerous goods — there’s no particular order or precedence — you’ve got things such as explosives and radioactive material, you’ve got flammable liquids. With each of those classes, we then sit down and work out the correct packaging — what can we do to ensure that whilst in transport, the danger that’s imposed by that chemical or article is reduced to a minimum should there be an incident?
If it’s to be declared as an item of dangerous goods, that implies a large set of responsibilities that then have to be undertaken by the shipper, who is declaring that as an item of dangerous goods; by the airline, who are supporting it; by the freight forwarders, who are moving it from the shipper to the airport; and of course, by the authorities, who are going to ensure that the compliances are being observed at all parts.
ACW: Currently, air transportation of lithium batteries has been in the news. What’s ICAO’s view on lithium batteries?
Rooney: The UN decided a very small number of batteries can be exempted from most of the requirements using a special provision if it has met certain UN tests. For air transport, we’ve decided that for those excepted lithium batteries, those which have been transported as cargo — not packed with equipment or contained in equipment— we have, to a very large extent, removed or certainly reduced the number of exemptions that are possible. Now, with a very few exceptions, they will have to meet most of the requirements in the technical instructions. One of the most important aspects is that it now means that the pilots will be notified that these shipments are onboard.
We are aware of bulk shipments of these batteries being transported on aircraft. When the UN were designing this system originally, I don’t think that the idea of 80,000 batteries in a bulk shipment [crossed their minds], and yet that is what has happened. We’ve had these very large bulk shipments coming through. We’ve had lengthy discussions in the ICAO panel; lithium batteries is certainly one of the hot topics.
We believe that we now have a fairly balanced approach, that we addressed the needs of operators, the pilots, the shippers and the regulators. It is fair to say that ICAO has devoted considerable attention to the subject of lithium batteries. We had our panel meeting last October; we were unable to come to a final decision on lithium batteries, and we held a special working group of the panel last February. The amendments will come through for 2013.
ACW: On an issue like this, how does the UN react when you make the rules more restrictive?
Rooney: We would obviously inform the UN when we are being more restrictive. But they are also aware that air transport is, after all, the only mode of transport where the dangerous goods are being transported along with passengers. The UN understands the reason for the extra stringency that we apply.