Are You Shipping Hazmat? Also, Bonus Video on Shipping Lithium Batteries

September 7, 2022 by Leave a comment

Aircraft parts are full of hazmat:

  • Batteries;
  • Squibs;
  • Self-inflating emergency equipment;
  • Compressed gas tanks;
  • Passenger service units with oxygen generators;
  • Residual fuel in a component (even if it is just a small amount);

These are just a few examples of the sort of hazmats that aircraft parts distributors see every day. I have received calls from ASA members whose business models did not involve hazmats; but then they received an air carrier inventory with “extra items.” Extra items that included hazmats.

If you receive unwanted or unexpected hazmat from a business partner, you cannot simply return it without thought. You need to make sure that even a return shipment meets the requirements of the hazmat rules. Civil penalties for getting this wrong can easily exceed $100,000. This means that you need to have trained personnel to identify hazmats, and you need to have trained personnel to classify, package, label and ship the package to wherever it needs to go (the training is required and defined by regulation).

Our next hazmat training class is scheduled for October 4-5, 2022. ASA members get a discount and there is also an additional early registration discount. The deadline for the early registration discount is September 13, 2022.

Our training is offered as a live, online class. You can take the class from the comfort of your desk without any travel. Because it is a live class, we can answer your questions in real-time to make sure you are getting everything you need from the class.

Lithium Batteries

If you are shipping lithium batteries, then you may want to check out our free video on shipping lithium batteries. This video is posted on Youtube.

Make sure you are watching the video for the correct year! We started posting these videos in 2021 and each year we post an updated video reflecting the changing rules surrounding lithium battery shipments. The year is part of the title.

Also please note that the training video is meant to be a supplement to our training class. It is a useful guide for shipping lithium batteries but it is not stand-alone training and it does not take the place of training that meets all of the regulatory requirements.

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Hazmat System (and Training) for “No-Hazmat” Distributors

July 13, 2020 by Leave a comment

Some of the companies accredited to the ASA-100 standard have struggled with the AC 00-56B requirement for a hazmat system because they have a “no-hazmat” policy (as a matter of company policy, they neither ship nor receive hazmat). This article addresses how to build a hazmat system that complies with the AC 00-56B requirement, while also meeting the limited needs of the “no-hazmat” company.

The FAA published its “Voluntary Industry Distributor Accreditation Program” in FAA AC 00-56B.  The accreditation program requires that accredited distributors have “[a] system for hazmat control and transport that meets Title 49 of the Code of Federal Regulations (49 CFR) requirements.” This is listed as one of the required quality system elements described in the advisory circular.

Each of the required quality system elements described in the advisory circular must be adequately addressed in the accredited distributor’s quality manual. This means that the accredited distributor’s hazmat control and transport “system” must be described in the quality manual. ASA has implemented this requirement in its own quality standard, ASA-100, and the implementation can be found in sections 1(E)(16) and 15.

If an accredited distributor knows that it does not ship hazmat, then it still has an obligation to meet the requirements for the hazmat control and transport system (including a “system” in the manual).

Even if the accredited distributor does not ship hazmat, there is still a risk of hazmat getting into the business’ system. In the 1990s, the FAA published Handbook Bulletins that explained that certificate holders, like repair stations, could reasonably receive unintended hazmats, based on industry shipping norms. This was later the rationale for requiring that repair stations must provide hazmat training to their personnel (14 C.F.R. 145.53(c)) and that accredited distributors must have hazmat transport and control systems under AC 00-56B.  On a more personal note, I have received many calls and emails, over the years, from ASA members and accredittees who’ve adopted “no-hazmat” policies and then received an unwanted hazmat.  This is a problem that really does occur.

ASA has taken the position that a minimum system must include appropriate training.  ASA also requires the system to be published in the quality manual.  For an accredited distributor that plans to adopt a “no-hazmat” policy, I recommend that the manual include:

  • A statement of the company policy of not receiving and/or shipping hazardous material;
  • Requirements concerning hazardous materials recognition training (to support the company policy); and
  • A process for addressing inadvertently received (or otherwise discovered) hazardous materials.

Of course, the distributor’s record-keeping program should include records of the hazardous materials recognition training.  But what about the details of that training?

When a company knows that it does not ship hazardous materials, then I feel that the training should be focused on preventing such shipments (and preventing such items from entering the system to mitigate the danger of them being pulled from stock for shipment). This means training appropriate personnel in (1) how to recognize hazardous materials, (2) the company policy of not shipping hazardous materials, and (3) what to do if hazardous materials are inadvertently received into, or discovered in, the system.

ASA has provided hazmat recognition training to the ASA community on several occasions. Most recently, we provided a live, online webinar addressing hazmat recognition in an aircraft parts environment (on April 14, 2020). That webinar was recorded and the recording is available to ASA members who need to provide training to their personnel.

When a company maintains a “no-hazmat” policy,” I have recommended that at least five classifications of personnel should receive hazmat identification training:

(1) Quality Personnel who are responsible for drafting, publishing, auditing, and managing the procedures associated with the hazmat system;
(2) Purchasing Personnel, so they will be aware of company limits and forbear from purchasing articles that would contravene those limits;
(3) Sales Personnel, so they will be aware of company limits and forbear from selling articles that would contravene those limits;
(4) Receiving Personnel, so they can recognize hazmats if they are inadvertently received, quarantine them pending appropriate disposition, and notify appropriate decision-makers within the company;
(5) Shipping Personnel, so they can recognize hazmats and forbear from shipping them in violation of company policy and/or regulatory limits.

By training these five classifications of personnel, you help to ensure that the company’s “no-hazmat” policy can be successful.

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The Importance of Accurate Training Logs

May 11, 2020 by Leave a comment

FAA has proposed a 1.29 million dollar civil penalty against against the City of Chicago Department of Aviation.  The Department is accused of falsifying airport firefighter training logs.

There is an important lesson to be learned from this civil penalty.  While the ASA community may not include firefighters, we do have mandatory training, including hazmat training for hazmat employees.  Falsifying the training logs can yield a very expensive civil penalty, and a lot of bad publicity.

We offer low-cost hazmat certification training (open to anyone).  Also, ASA members can also access free hazmat recognition training for non-shipping staff (a video from the ASA webinar series).  For a link to the hazmat recognition video, ASA members can send an email to ASA and they will forward a link to the session recording and a copy of the presentation.

ASA, MARPA and AFRA have also been offering free webinars for members. They have been providing training on variety of useful subjects every Tuesday and Thursday in order to keep skills sharp for the industry.

The FAA’s Press release describes the civil penalty allegation against the City of Chicago Department of Aviation:

The FAA alleges that between April and August 2019, three firefighters at Chicago O’Hare International Airport were assigned to a High Reach Extendable Turret vehicle for a total of 18 shifts when they had not completed required training on operating the turret. One of the firefighters, a lieutenant, falsified 13 training-log entries to make it appear he had completed the training, the FAA alleges.

Additionally, a captain at Chicago Midway International Airport was assigned to a vehicle for two shifts when she had not completed required recurrent training, the FAA alleges. That firefighter also accessed the airfield during nine shifts when she was not properly badged or under proper escort.

The FAA also alleges the City of Chicago Department of Aviation failed to ensure that the Fire Department maintained required training records.

Note: this FAA press release was issued before the formal response from the City of Chicago Department of Aviation, so they may have defenses to the allegations that are not reflected in the FAA’s notice document.  The Chicago Tribune reported that the City of Chicago Department of Aviation released a statement on this issue:

“Upon learning of these serious allegations, CDA immediately began working with the FAA and CFD to initiate a series of actions, including leadership changes and the retraining of ARFF personnel to ensure all firefighters have the proper training and certifications to operate at the airports,” the department said. “Additionally, CFD training methods and recordkeeping practices have been overhauled to ensure those qualifications are tracked properly. This was all completed in 2019.”

[this statement was not on the City of Chicago Department of Aviation press release listing as of this morning]

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