Papercut Finder and a Hazmat: Hand Gel on Airplanes
- Advanced Aircrew Academy
There are two things to remember when using hand sanitizer in the business aviation world. First, it will find every cut and nick in your skin. Second, it is considered a Hazardous Material (Hazmat). Pilots have a responsibility for not accepting improper materials, so it might help you remember by knowing there is a $75,000 potential fine for improperly carrying Hazmat.
In a race to slow COVID-19, hand sanitizer is being ordered and used in bulk quantities. Some flight departments are mandating the use for crew and passengers, so the TSA has flexed the hand sanitizer limitation by allowing one 12 ounces container (up from 3.4 ounces) per passenger in a carry-on bag.
Medicinal and toiletry articles that are intended for personal use by passengers or crew can be carried, but the maximum amount of all items may not exceed 70 ounces total per person and the contents of each container may not exceed 18 ounces by mass or 17 fluid ounces. In other words, Costco or Sam's Club gallon sized hand gel—not allowed.
While the use of anti-bacterial gel can be lifesaving during a pandemic, it's important to also remember that hand sanitizer (liquid and gel), is flammable and can easily be ignited with a lighter. Not only is it a fire hazard, it is also a terrorism concern. Hand sanitizer can irritate or damage eyes, has a strong odor, and gel is difficult to get off the skin. Imagine that gel on fire on a person or aircraft and you can understand the concern.
Semantics is often played in the aviation regulation interpretation game, so let's also clear up who must abide by the Hazardous Materials Regulations (HMRs).
- If an aircraft owner pays any pilot to operate it, then the HMRs apply. Even though you're not for hire, the flight crew is being paid so you are operating "in commerce".
- If you own and fly an airplane and put your employees onboard to fly to a corporate function, the HMRs apply.
- If you own and fly an airplane yourself for personal use only, the HMRs do not apply.
- Any employee who prepares and offers Hazmat for shipment via any mode (Part 91/135) must be fully trained as a Hazmat shipper.
Part 135 – Will-Carry or Will-Not-Carry
What is the difference between a Will-Carry and Will-Not-Carry operator? Will-Carry operators can accept properly packaged Hazmat with certain limitations. Some items that may be carried on cargo-only aircraft are prohibited on passenger aircraft, even for Will Carry operators.
Will Not Carry operators cannot accept Hazmat for carriage, but there are a number of exceptions. Your Operations Specifications determine what you are authorized to carry. The majority of Part 135 flight departments are Will-Not-Carry operators and they are responsible for training staff to recognize dangerous materials, which include the following hazard classes:
- Compressed gases
- Flammable liquids and solids
- Infectious substances
- Radioactive materials
- Corrosive materials
Just like any aircraft emergency or anomaly, while focusing on the emergency, it can be easy to forget the normal checklist. Increasing the quantity of hand sanitizer onboard is a logical solution to help slow COVID-19; just don't forget the potential peripheral damage it could cause.
For Part 135 departments, Advanced Aircrew Academy's eLearning module for Will-Not-Carry Hazmat Operators helps flight crews recognize hazardous materials and know what exceptions they are allowed to have onboard. The Hazmat training module focuses on common hazardous materials that passengers may bring onboard. It also includes analysis of National Aeronautics and Space Administration (NASA) Aviation Safety Reporting System (ASRS) reports of Hazmat incidents with other business aircraft crews. The module complies with the training requirements of both the U.S. Department of Transportation and International Air Transport Association Dangerous Goods Regulations (DGR).
If you are operating under Part 91, transportation of hazardous materials aboard your aircraft is subject to the Hazardous Material Regulations. Our module creates awareness of the HMRs applicable to a Will-Not-Carry flight department. This module complies with the IS-BAO training requirement for dangerous goods defined in Chapter 8. The standard is for flight crewmembers to complete the training during initial training and every two years thereafter. The Business Aviation Safety Consortium also requires Dangerous Goods training.
Links to more information on hand sanitizer: