Safety Advisory Notice SAN19970149

Safety Advisory Notice issued to: Civil Aviation Safety Authority

Recommendation details
Output No: SAN19970149
Date issued: 18 November 1997
Safety action status: Closed



There is evidence to suggest that dangerous goods are being carried on aircraft engaged in passenger carrying operations, with cargo compartments which do not meet the appropriate certification requirements.


Some attendees at a recent Dangerous Goods refresher course voiced concerns to Bureau of Air Safety Investigators about the simultaneous carriage of passengers and dangerous goods. Their specific concerns related to:

(1) such operations in Fairchild Metro 23 aircraft. The reporters believed that the main deck cargo compartment in Metro 23 aircraft does not meet any of the International Civil Aviation Organisation (ICAO) standards for the carriage of dangerous goods during passenger-carrying operations; and

(2) the discretionary powers of the pilot in command. The reporters felt that, under the current legislation, operators may place pressure on flight crew to carry dangerous goods on aircraft without appropriate cargo compartments.


The legislative requirements

The Civil Aviation Regulations (CARs) state that an aircraft is permitted to carry dangerous goods only in accordance with the Technical Instructions.

The document Technical Instructions for the Safe Transport of Dangerous Goods by Air is approved and published by ICAO, and states that:

"dangerous goods may be carried on the main deck cargo or baggage compartment of a passenger aircraft provided that compartment meets the certification requirements for a Class B aircraft cargo compartment."

A Class B cargo or baggage compartment, as described in the ICAO document, Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods, is one in which:

"a) there is sufficient access in flight to enable a crew member to effectively reach any part of the compartment with the contents of a hand fire extinguisher;

b) when the access provisions are being used, no hazardous quantity of smoke, flames or extinguishing agent will enter any compartment occupied by the crew or passengers; and

c) there is a separate approved smoke detector or fire detector system to give warning at the pilot or flight engineer station".

This description of a Class B cargo compartment clearly indicates that Metro 23 aircraft are unsuitable for the carriage of dangerous goods whilst passengers are on board. This may also be the case for other aircraft types used for passenger transport.

Current situation

Discussions with a number of operators who utilise Metro 23 aircraft, and similar types, revealed that dangerous goods are being carried in passenger-carrying operations. Some operators appear to be unaware of the requirements for the carriage of dangerous goods in these types of aircraft. For example, one operator felt that relevant information was not readily accessible from the Technical Instructions. This operator considered that it might be pertinent to contain such information within the text of the CARs, and that it be a mandatory part of Dangerous Goods Awareness Training Courses.

Dangerous Goods Manuals

The contents of company Dangerous Goods manuals appear to vary considerably. Some manuals contain largely generic information with no reference to aircraft types. Other manuals contain very prescriptive information in which specific aircraft types are referred to, with statements as to whether the aircraft type may carry dangerous goods, and in what circumstances.

Discussions with CASA Dangerous Goods personnel revealed a view that operators of smaller companies, such as regional airlines, may be confused about what constitutes a Class B cargo compartment. It is also evident that there may be differing views, both within the industry and CASA, on whether the cargo areas of such aircraft as the Metro 23 are part of the main deck or an external locker and therefore have different requirements for the carriage of dangerous goods. It was suggested that the inconsistent understanding of the requirements is due, in part, to the fact that the Technical Instructions are largely directed toward large international aircraft.


The Bureau was also informed by CASA that the classification of an aircraft cargo or baggage compartment is determined during the type certification process. The basis of certification for the Metro 23 and other similar aircraft types, is Federal Aviation Regulation 23 (FAR 23). FAR 23.855 refers to cargo and baggage compartment fire protection. Whilst these requirements are similar to those mentioned in the Technical Instructions , the specifications which must be met for a Class B cargo or baggage compartment appear to be more comprehensive.

Seventeen Metro 23 aircraft which are certified in accordance with FAR 23 are currently on the Australian aircraft register. There are also a large number of commuter and charter aircraft, including a further 15 earlier model Metro's, which are certificated to less stringent standards. They are therefore unlikely to meet the requirements for the carriage of dangerous goods on main deck cargo compartments during passenger-carrying operations. The degree of uncertainty within the aviation industry, and inconsistent application of standards in relation to practices and procedures for the carriage of dangerous goods, increases the potential for an incident or accident.


The results of a major dangerous-goods related accident in the United States, "Valujet Airlines Flight 592", support the need for a vigilant and consistent approach by both CASA and operators. The uncertainty and misinterpretation of the regulations need to be addressed to ensure that all operators have a clear understanding of the requirements. Dangerous Goods manuals need to be standardised, with specific reference to aircraft types. The content of Dangerous Goods training courses needs to be reviewed so those people who are responsible for the acceptance of dangerous goods on aircraft, particularly flight crew, are made aware of these matters.

By addressing these issues through a process of education and standardisation, it is less likely that operators will place pressure on flight crew to carry dangerous goods on aircraft without appropriate cargo compartments.


Civil Aviation Regulations
Federal Aviation Regulations
ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air
ICAO Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (1997-1998 Edition)
IATA Dangerous Goods Regulations (38th Edition, 1997)

Output text

The Civil Aviation Safety Authority should note the safety deficiency identified in this document and take appropriate action.

Initial response
Date issued:
Response from: Civil Aviation Safety Authority
Action status: Not Required
Response text:
Last update 01 April 2011