You can divide the air transportation world into two hazardous materials (HazMat) types: "will-carry" and "will-not-carry." The determination of which category you fall into is cut and dried in commercial aviation, but not so in general aviation.
— James Albright
"Will-carry" vs. "will-not-carry" — The requirements and risks involved with being an authorized HazMat carrier are quite high and I would argue if you haven't been thoroughly trained, you should be in the "will-not-carry" category. (My will-not-carry Rationale appears below.) What follows is aimed towards those of us in the "will-not-carry" world.
1 — "Will not carry" rationale
"Will not carry" rationale
Title 49 of the Code of Federal Regulations (Transportation), Subchapter C (Hazardous Materials Regulations), Part 175 (Carriage by Aircraft), is applicable to commercial operations. If you are an authorized "will-carry" operator, you should have Operations Specification A055, Carriage of Hazardous Materials, in accordance with FAA Order 8900.1, Vol 3, Chap 18, Part A.
(a) This part prescribes requirements that apply to the transportation of hazardous materials in commerce aboard (including attached to or suspended from) aircraft. The requirements in this part are in addition to other requirements contained in parts 171, 172, 173, 178, and 180 of this subchapter.
(b) This part applies to the offering, acceptance, and transportation of hazardous materials in commerce by aircraft to, from, or within the United States, and to any aircraft of United States registry anywhere in air commerce. This subchapter applies to any person who performs, attempts to perform, or is required to perform any function subject to this subchapter, including—(1) Air carriers, indirect air carriers, and freight forwarders and their flight and non-flight employees, agents, subsidiary and contract personnel (including cargo, passenger and baggage acceptance, handling, loading and unloading personnel); and
(2) Air passengers that carry any hazardous material on their person or in their carry-on or checked baggage.
(c) This part does not apply to aircraft of United States registry under lease to and operated by foreign nationals outside the United States if:
(1) Hazardous materials forbidden aboard aircraft by §172.101 of this subchapter are not carried on the aircraft; and
(2) Other hazardous materials are carried in accordance with the regulations of the State (nation) of the aircraft operator.
Source: 49 CFR 175.1, Purpose, scope, and applicability.
That pretty much covers the 14 CFR 91K, 121, and 135 worlds. But what about 14 CFR 91 general aviation? You could argue none of this applies to you. I believe if something goes wrong, you will be cited as follows:
Aircraft operations for the purpose of air navigation. No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.
Source: 14 CFR 91, ¶91.13(a)
In my opinion, if you haven't been specifically trained to carry hazardous materials, you are in the "will-not-carry" category. Of course this begs the questions: What constitutes a hazardous material? and Are there any exceptions?
Hazardous material means a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 CFR 172.101), and materials that meet the defining criteria for hazard classes and divisions in part 173 of this subchapter.
Source: 49 CFR 171, §171.8
Designating Material as Hazardous.—The Secretary shall designate material (including an explosive, radioactive material, infectious substance, flammable or combustible liquid, solid, or gas, toxic, oxidizing, or corrosive material, and compressed gas) or a group or class of material as hazardous when the Secretary determines that transporting the material in commerce in a particular amount and form may pose an unreasonable risk to health and safety or property.
Source: 49 USC 5103, ¶(a)
The current 49 CFR 172.101 Hazardous Materials Tables encompass 112 pages with about 25 line items each, giving a total of est. 2800 entries, not counting the additional tables of Hazardous Materials other than radionucleides (13 pages), radionucleides (7 pages) and Marine Pollutants (4 pages).
Transporting HazMat is regulated by 49 CFR. Handling of HazMat is more in the realm Occupational Safety and HazMat Communication, which is a completely different set of rules with sometimes/often different markings. Both areas of these activities require MANDATORY training. It is getting quite complicated, so let us restrict ourselves to TRANSPORT only.
If you see one of the following symbols on something meant for the aircraft that means it was meant for an aircraft with an approved hazardous materials program:
The following symbols are meant to designate hazardous materials:
Download: DOT Chart 15 Hazardous Materials Marking, Labeling and Placarding Guide.
Of course you may encounter hazardous materials that do not come with easily recognizable labels, for example:
- Cleaning solvents
- Matches, lighters
The list goes on and on. Many of the traveling public don't understand that something that is perfectly safe at ground level may become deadly at lower pressures or in the face of a rapid decompression. It has always been a problem but awareness should improve. Starting January 1, 2015, commercial air passengers must acknowledge that they have been advised what they can bring on board or not as carry-on or checked in luggage before a reservation is confirmed and a "ticket" is issued.
In corporate aviation, where no ticket need be issued, it is up to the operator to ensure passengers are made aware of what can, and cannot be carried aboard aircraft. It might be easier to consider the exceptions.
The actual list of exceptions is contained in 49 CFR 175, §175.10, and it makes fascinating reading. But it is long and hard to find what you are looking for. But there is a much easier to use list and you can download that here: Hazardous Materials Carried by Passengers and Crewmembers. You might also consider the FAA document: Pack Safe.
Exceptions for operator equipment and items of replacement.
(a) Operator equipment. This subchapter does not apply to—
(1) Aviation fuel and oil in tanks that are in compliance with the installation provisions of 14 CFR, chapter 1.
(2) Hazardous materials required aboard an aircraft in accordance with the applicable airworthiness requirements and operating regulations. Items of replacement for such materials must be transported in accordance with paragraph (a)(3) of this section.
(3) Items of replacement (company material (COMAT)) for hazardous materials described in paragraph (a)(2) of this section must be transported in accordance with this subchapter. When an operator transports its own replacement items described in paragraph (a)(2), the following exceptions apply:
(i) In place of required packagings, packagings specifically designed for the items of replacement may be used, provided such packagings provide at least an equivalent level of protection to those that would be required by this subchapter.
(ii) Aircraft batteries are not subject to quantity limitations such as those provided in §172.101 or §175.75(c) of this subchapter.
(4) Unless otherwise addressed by FAA regulation or policy (e.g. Advisory Circular), hazardous materials used by the operator aboard the aircraft, when approved by the Administrator of the Federal Aviation Administration.
(b) Other operator exceptions. This subchapter does not apply to—
(1) Oxygen, or any hazardous material used for the generation of oxygen, for medical use by a passenger, which is furnished by the aircraft operator in accordance with 14 CFR 121.574 or 135.91. For the purposes of this paragraph, an aircraft operator that does not hold a certificate under 14 CFR parts 121 or 135 may apply this exception in conformance with 14 CFR 121.574 or 135.91 in the same manner as required for a certificate holder. See §175.501 for additional requirements applicable to the stowage of oxygen.
(2) Dry ice (carbon dioxide, solid) intended for use by the operator in food and beverage service aboard the aircraft.
(3) Aerosols of Division 2.2 only (for dispensing of food products), alcoholic beverages, colognes, liquefied gas lighters, perfumes, and portable electronic devices containing lithium cells or batteries that meet the requirements of §175.10(a)(18) carried aboard a passenger-carrying aircraft by the operator for use or sale on that specific aircraft. A liquefied gas lighter design must be examined and successfully tested by a person or agency authorized by the Associate Administrator.
(4) A tire assembly with a serviceable tire, provided the tire is not inflated to a gauge pressure exceeding the maximum rated pressure for that tire, and the tire (including valve assemblies) is protected from damage during transport. A tire or tire assembly which is unserviceable or damaged is forbidden from air transport; however, a damaged tire is not subject to the requirements of this subchapter if it contains no material meeting the definition of a hazardous material (e.g., Division 2.2).
Source: 49 CFR 175, §175.8
Exceptions for passengers, crewmembers, and air operators.
(a) This subchapter does not apply to the following hazardous materials when carried by aircraft passengers or crewmembers provided the requirements of §§171.15 and 171.16 (see paragraph (c) of this section) and the requirements of this section are met:
(1) (i) Non-radioactive medicinal and toilet articles for personal use (including aerosols) carried in carry-on and checked baggage. Release devices on aerosols must be protected by a cap or other suitable means to prevent inadvertent release;
(ii) Other aerosols in Div. 2.2 (nonflammable gas) with no subsidiary risk carried in checked baggage only. Release devices on aerosols must be protected by a cap or other suitable means to prevent inadvertent release; and√(iii) The aggregate quantity of these hazardous materials carried by each person may not exceed 2 kg (70 ounces) by mass or 2 L (68 fluid ounces) by volume and the capacity of each container may not exceed 0.5 kg (18 ounces) by mass or 500 ml (17 fluid ounces) by volume.
(2) One packet of safety matches or a lighter intended for use by an individual when carried on one's person or in carry-on baggage only. Lighter fuel, lighter refills, and lighters containing unabsorbed liquid fuel (other than liquefied gas) are not permitted on one's person or in carry-on or checked baggage.
(3) Implanted medical devices in humans or animals that contain hazardous materials, such as a heart pacemaker containing Class 7 (radioactive) material or lithium batteries; and radiopharmaceuticals that have been injected or ingested.
(4) Alcoholic beverages containing:
(i) Not more than 24% alcohol by volume; or
(ii) More than 24% and not more than 70% alcohol by volume when in unopened retail packagings not exceeding 5 liters (1.3 gallons) carried in carry-on or checked baggage, with a total net quantity per person of 5 liters (1.3) gallons for such beverages.
(5) Perfumes and colognes purchased through duty-free sales and carried on one's person or in carry-on baggage.
(6) Hair curlers (curling irons) containing a hydrocarbon gas such as butane, no more than one per person, in carry-on or checked baggage. The safety cover must be securely fitted over the heating element. Gas refills for such curlers are not permitted in carry-on or checked baggage.
(7) A small medical or clinical mercury thermometer for personal use, when carried in a protective case in carry-on or checked baggage.
(8) Small arms ammunition for personal use carried by a crewmember or passenger in checked baggage only, if securely packed in boxes or other packagings specifically designed to carry small amounts of ammunition. Ammunition clips and magazines must also be securely boxed. This paragraph does not apply to persons traveling under the provisions of 49 CFR 1544.219.
(9) One self-defense spray (see §171.8 of this subchapter), not exceeding 118 mL (4 fluid ounces) by volume, that incorporates a positive means to prevent accidental discharge may be carried in checked baggage only.
(10) Dry ice (carbon dioxide, solid), with the approval of the operator:
(i) Quantities may not exceed 2.5 kg (5.5 pounds) per person when used to pack perishables not subject to the HMR. The package must permit the release of carbon dioxide gas; and
(ii) When carried in checked baggage, each package is marked “DRY ICE” or “CARBON DIOXIDE, SOLID,” and marked with the net weight of dry ice or an indication the net weight is 2.5 kg (5.5 pounds) or less.
(11) A single self-inflating personal safety device such as a life jacket or vest fitted with no more than two small gas cartridges (containing no hazardous material other than a Div. 2.2 gas) for inflation purposes plus no more than two spare cartridges. The personal safety device and spare cartridges may be carried in carry-on or checked baggage, with the approval of the aircraft operator, and must be packed in such a manner that it cannot be accidentally activated.
(12) Small compressed gas cylinders of Division 2.2 (containing no hazardous material other than a Division 2.2 gas) worn by the passenger for the operation of mechanical limbs and, in carry-on and checked baggage, spare cylinders of a similar size for the same purpose in sufficient quantities to ensure an adequate supply for the duration of the journey.
(13) A mercury barometer or thermometer carried as carry-on baggage, by a representative of a government weather bureau or similar official agency, provided that individual advises the operator of the presence of the barometer or thermometer in his baggage. The barometer or thermometer must be packaged in a strong packaging having a sealed inner liner or bag of strong, leak proof and puncture-resistant material impervious to mercury, which will prevent the escape of mercury from the package in any position.
(14) Electrically powered heat-producing articles (e.g., battery-operated equipment such as diving lamps and soldering equipment) as checked or carry-on baggage only and with the approval of the operator of the aircraft. The heat-producing component, the energy source, or other component (e.g., fuse) must be removed to prevent unintentional functioning during transport. Any battery that is removed must be protected against short circuit by placement in original retail packaging or by otherwise insulating terminals (e.g., by taping over exposed terminals or placing each battery in a separate plastic bag or protective pouch).
(15) A wheelchair or other battery-powered mobility aid equipped with a nonspillable battery or a dry sealed battery when carried as checked baggage, provided—
(i) The battery conforms to the requirements of §173.159a(d) of this subchapter for non-spillable batteries;
(ii) The battery conforms to the requirements of §172.102(c)(1), Special provision 130 of this subchapter for dry sealed batteries, as applicable;
(iii) Visual inspection including removal of the battery, where necessary, reveals no obvious defects (removal of the battery from the housing should be performed by qualified airline personnel only);
(iv) The battery is disconnected and the battery terminals are protected to prevent short circuits, unless the wheelchair or mobility aid design provides an effective means of preventing unintentional activation, and
(v) The battery is—
(A) Securely attached to the wheelchair or mobility aid;
(B) Is removed and placed in a strong, rigid packaging marked “NONSPILLABLE BATTERY” (unless fully enclosed in a rigid housing that is properly marked);
(C) Is removed and placed in a strong, rigid packaging marked with the words “not restricted” in accordance with paragraph (c)(2) of §172.102, Special provision 130, of this subchapter; or
(D) Is handled in accordance with paragraph (a)(16)(iv) of this section.
(16) A wheelchair or other battery-powered mobility aid equipped with a spillable battery, when carried as checked baggage, provided—
(i) Visual inspection including removal of the battery, where necessary, reveals no obvious defects (however, removal of the battery from the housing should be performed by qualified airline personnel only);
(ii) The battery is disconnected and terminals are insulated to prevent short circuits;
(iii) The pilot-in-command is advised, either orally or in writing, prior to departure, as to the location of the battery aboard the aircraft; and
(iv) The wheelchair or mobility aid is loaded, stowed, secured and unloaded in an upright position, or the battery is removed, and carried in a strong, rigid packaging under the following conditions:
(A) The packaging must be leak-tight and impervious to battery fluid. An inner liner may be used to satisfy this requirement if there is absorbent material placed inside of the liner and the liner has a leakproof closure;
(B) The battery must be protected against short circuits, secured upright in the packaging, and be packaged with enough compatible absorbent material to completely absorb liquid contents in the event of rupture of the battery; and
(C) The packaging must be labeled with a CORROSIVE label, marked to indicate proper orientation, and marked with the words “Battery, wet, with wheelchair.”
(17) A wheelchair or other mobility aid equipped with a lithium ion battery, when carried as checked baggage, provided—
(i) The lithium ion battery must be of a type that successfully passed each test in the UN Manual of Tests and Criteria (IBR; see §171.7 of this subchapter), as specified in §173.185 of this subchapter, unless approved by the Associate Administrator;
(ii) The operator must verify that:
(A) Visual inspection of the wheelchair or other mobility aid reveals no obvious defects;
(B) Battery terminals are protected from short circuits (e.g., enclosed within a battery housing);
(C) The battery must be securely attached to the mobility aid; and
(D) Electrical circuits are isolated;
(iii) The wheelchair or other mobility aid must be loaded and stowed in such a manner to prevent its unintentional activation and its battery must be protected from short circuiting;
(iv) The wheelchair or other mobility aid must be protected from damage by the movement of baggage, mail, service items, or other cargo;
(v) Where a lithium ion battery-powered wheelchair or other mobility aid is specifically designed to allow its battery to be removed by the user (e.g., collapsible):
(A) The battery must be removed from the wheelchair or other mobility aid according to instructions provided by the wheelchair or other mobility aid owner or its manufacturer;
(B) The battery must be carried in carry-on baggage only;
(C) Battery terminals must be protected from short circuits (by placement in original retail packaging or otherwise insulating the terminal e.g. by taping over exposed terminals or placing each battery in a separate plastic bag or protective pouch);
(D) The battery must not exceed 300 Watt-hour (Wh); and
(E) A maximum of one spare battery not exceeding 300 Wh or two spares not exceeding 160 Wh each may be carried;
(vi) The pilot-in-command is advised either orally or in writing, prior to departure, as to the location of the lithium ion battery or batteries aboard the aircraft.
(18) Except as provided in §173.21 of this subchapter, portable electronic devices (e.g., watches, calculating machines, cameras, cellular phones, laptop and notebook computers, camcorders, medical devices etc.) containing dry cells or dry batteries (including lithium cells or batteries) and spare dry cells or batteries for these devices, when carried by passengers or crew members for personal use. Portable electronic devices powered by lithium batteries may be carried in either checked or carry-on baggage. Spare lithium batteries must be carried in carry-on baggage only. Each installed or spare lithium battery must be of a type proven to meet the requirements of each test in the UN Manual of Tests and Criteria, Part III, Sub-section 38.3 and each spare lithium battery must be individually protected so as to prevent short circuits (e.g., by placement in original retail packaging, by otherwise insulating terminals by taping over exposed terminals, or placing each battery in a separate plastic bag or protective pouch). In addition, each installed or spare lithium battery must not exceed the following:
(i) For a lithium metal battery, a lithium content of not more than 2 grams per battery; or
(ii) For a lithium ion battery, the Watt-hour rating must not exceed 100 Wh. With the approval of the operator, portable electronic devices may contain lithium ion batteries exceeding 100 Wh, but not exceeding 160 Wh and no more than two individually protected lithium ion batteries each exceeding 100 Wh, but not exceeding 160 Wh, may be carried per person as spare batteries in carry-on baggage.
(iii) For a non-spillable battery, the battery and equipment must conform to §173.159a(d). Each battery must not exceed a voltage greater than 12 volts and a watt-hour rating of not more than 100 Wh. No more than two individually protected spare batteries may be carried. Such equipment and spare batteries must be carried in checked or carry-on baggage.
(iv) Articles containing lithium metal or lithium ion cells or batteries the primary purpose of which is to provide power to another device must be carried as spare batteries in accordance with the provisions of this paragraph.
(19) Except as provided in §173.21 of this subchapter, battery-powered portable electronic smoking devices (e.g., e-cigarettes, e-cigs, e-cigars, e-pipes, e-hookahs, personal vaporizers, electronic nicotine delivery systems) when carried by passengers or crewmembers for personal use must be carried on one's person or in carry-on baggage only. Spare lithium batteries must be individually protected so as to prevent short circuits (by placement in original retail packaging or by otherwise insulating terminals, e.g., by taping over exposed terminals or placing each battery in a separate plastic bag or protective pouch). Each lithium battery must be of a type which meets the requirements of each test in the UN Manual of Tests and Criteria, Part III, Sub-section 38.3. Recharging of the devices and/or the batteries on board the aircraft is not permitted. Each battery must not exceed the following:
(i) For lithium metal batteries, a lithium content of 2 grams; or
(ii) For lithium ion batteries, a Watt-hour rating of 100 Wh.
(20) Fuel cells used to power portable electronic devices (e.g., cameras, cellular phones, laptop computers and camcorders) and spare fuel cell cartridges when transported personal use under the following conditions:
(i) Fuel cells and fuel cell cartridges may contain only Division 2.1 liquefied flammable gas, or hydrogen in a metal hydride, Class 3 flammable liquid (including methanol), Division 4.3 water-reactive material, or Class 8 corrosive material;
(ii) The quantity of fuel in any fuel cell or fuel cell cartridge may not exceed:
(A) 200 mL (6.76 ounces) for liquids;
(B) 120 mL (4 fluid ounces) for liquefied gases in non-metallic fuel cell cartridges, or 200 mL (6.76 ounces) for liquefied gases in metal fuel cell cartridges;
(C) 200 g (7 ounces) for solids; or
(D) For hydrogen in metal hydride, the fuel cell cartridges must have a water capacity of 120 mL (4 fluid ounces) or less;
(iii) No more than two spare fuel cell cartridges may be carried by a passenger or crew member as follows:
(A) Fuel cell cartridges containing Class 3 flammable liquid (including methanol) and Class 8 corrosive material in carry-on or checked baggage; and
(B) Division 2.1 liquefied flammable gas or hydrogen in a metal hydride and Division 4.3 water-reactive material in carry-on baggage only;
(iv) Fuel cells containing fuel are permitted in carry-on baggage only;
(v) Fuel cell cartridges containing hydrogen in a metal hydride must meet the requirements in §173.230(d) of this subchapter;
(vi) Refueling of a fuel cell aboard an aircraft is not permitted except that the installation of a spare cartridge is allowed;
(vii) Each fuel cell and fuel cell cartridge must conform to IEC 62282-6-100 and IEC 62282-6-100 Amend. 1 (IBR; see §171.7 of this subchapter) and must be marked with a manufacturer's certification that it conforms to the specification. In addition, each fuel cell cartridge must be marked with the maximum quantity and type of fuel in the cartridge;
(viii) Interaction between fuel cells and integrated batteries in a device must conform to IEC 62282-6-100 and IEC 62282-6-100 Amend. 1 (IBR, see §171.7 of this subchapter). Fuel cells whose sole function is to charge a battery in the device are not permitted; and
(ix) Fuel cells must be of a type that will not charge batteries when the consumer electronic device is not in use and must be durably marked by the manufacturer with the wording: “APPROVED FOR CARRIAGE IN AIRCRAFT CABIN ONLY” to indicate that the fuel cell meets this requirement.
(21) Permeation devices for calibrating air quality monitoring equipment when carried in checked baggage provided the devices are constructed and packaged in accordance with §173.175.
(22) An internal combustion or fuel cell engine or a machine or apparatus containing an internal combustion or fuel cell engine when carried as checked baggage, provided—
(i) The engine contains no liquid or gaseous fuel. An engine may be considered as not containing fuel when the engine components and any fuel lines have been completed drained, sufficiently cleaned of residue, and purged of vapors to remove any potential hazard and the engine when held in any orientation will not release any liquid fuel;
(ii) The fuel tank contains no liquid or gaseous fuel. A fuel tank may be considered as not containing fuel when the fuel tank and the fuel lines have been completed drained, sufficiently cleaned of residue, and purged of vapors to remove any potential hazard;
(iii) It is not equipped with a wet battery (including a non-spillable battery), a sodium battery or a lithium battery; and
(iv) It contains no other hazardous materials subject to the requirements of this subchapter.
(23) Non-infectious specimens transported in accordance with §173.4b(b).
(24) Insulated packagings containing refrigerated liquid nitrogen when carried in checked or carry-on baggage in accordance with the ICAO Technical Instructions (IBR, see §171.7 of this subchapter), Packing Instruction 202, the packaging specifications in part 6, chapter 5, and special provision A152.
(25) Small cartridges fitted into devices with no more than four small cartridges of carbon dioxide or other suitable gas in Division 2.2, without subsidiary risk with the approval of the operator. The water capacity of each cartridge must not exceed 50 mL (equivalent to a 28 g cartridge).
(b) The exceptions provided in paragraph (a) of this section also apply to aircraft operators when transporting passenger or crewmember baggage that has been separated from the passenger or crewmember, including transfer to another carrier for transport to its final destination.
(c) The requirements to submit incident reports as required under §§171.15 and 171.16 of this subchapter apply to the air carrier.
Source: 49 CFR 175, §175.10
Examples of HazMat related mishaps
49 CFR 175, Title 59, Transportation, Carriage by Aircraft, Department of Transportation
FAA Orders 8400 and 8900
Gulfstream G450 Aircraft Operating Manual, Revision 35, April 30, 2013.
Gulfstream G450 Airplane Flight Manual, Revision 36, December 5, 2013
Gulfstream G450 Maintenance Manual, Revision 18, Dec 12, 2013
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