NTSB · Safety Recommendation
Safety Recommendation A-97-072
Recommendation
TO THE FEDERAL AVIATION ADMINISTRATION: Issue guidance to air carriers on procedures for transporting hazardous aircraft components consistent with RSPA requirement for the transportation of air carrier company materials; then require principal operations inspectors to review and amend, as necessary, air carrier manuals to ensure that air carrier procedures are consistent with this guidance.
Safety Issue and Context
On 5/11/96, about 1415 eastern daylight time, a McDonnell Douglas DC-9-32 crashed into the everglades swamp shortly after takeoff from Miami International Airport, Miami Florida, the airplane, N904VJ, was operated by ValuJet Airlines, Inc., as ValuJet flight 592. Both pilots, the three flight attendants, and all 105 passengers were killed. Before the accident, the flightcrew reported to air traffic control that it was experiencing smoke in the cabin and cockpit. Visual meteorological conditions existed in the Miami area at the time of the takeoff. The destination of the flight was Hartsfield International Airport, Atlanta, Georgia.
Flight 592 was on an instrument flight rules flight plan.
Response History
July 23, 1999 · NTSB Correspondence · FAA
(NOTE: This letter is a reply to the FAA letter dated 29 June 1998. It was delayed in leaving the NTSB and the close-out letter dated July 13, 1999 went to the FAA before this one. Safety Recommendation A-97-072 is "Closed--Acceptable Action" by letter to the FAA dated July 13, 1999) ALTHOUGH THE SAFETY BOARD ACKNOWLEDGES THE FAA'S SUBSTANTIAL EFFORTS THUS FAR, THE BOARD REQUESTS THAT THE FAA ALSO PROVIDE THE RESULTS OF ITS REVIEW OF THE COMAT PROVISIONS IN AIR CARRIER MANUALS, SPECIFICALLY WITH RESPECT TO THE HANDLING OF HAZARDOUS MATERIALS. PENDING THE RECEIPT OF THIS INFORMATION, THE SAFETY BOARD CLASSIFIES A-97-72 "OPEN--ACCEPTABLE RESPONSE."
July 13, 1999 · NTSB Correspondence · FAA
BECAUSE THE FAA'S COMBINED ACTIONS MEET THE INTENT OF A-97-72, IT IS CLASSIFIED "CLOSED--ACCEPTABLE ACTION."
February 19, 1999 · Recipient Response · FAA
Letter Mail Controlled 2/26/99 2:32:14 PM MC# 990179 THE FAA HAS COMPLETED SEVERAL ACTIONS THAT ADDRESS THE FULL INTENT OF THIS RECOMMENDATION. IN EARLY 1998, THE FAA AND THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION (RSPA) PUBLISHED AND DISTRIBUTED A SAFETY ALERT TO MANUFACTURERS, AIR CARRIERS, AND OTHER USERS OF PORTABLE BREATHING EQUIPMENT CONTAINING CHEMICAL OXYGEN GENERATORS. THE ALERT OUTLINED THE APPLICABLE HAZARDOUS MATERIAL (HAZMAT) REQUIREMENTS AND LIMITATIONS CONTAINED IN 49 CFR PARTS 171 THROUGH 180, HAZARDOUS MATERIALS REGULATIONS, FOR THE PACKAGING AND TRANSPORT OF THESE DEVICES.
ALONG WITH THE ALERT, THE FAA DISTRIBUTED A ONE-PAGE FACT SHEET IN A QUESTION-AND-ANSWER FORMAT ENTITLED "COMAT FACTS," WHICH EXPLAINS THE HAZMAT REGULATIONS THAT APPLY TO THE OFFERING AND TRANSPORT OF COMPANY MATERIALS (COMAT). THE FAA HAS ALSO DEVELOPED AND DISTRIBUTED A BROCHURE THAT PROVIDES MORE SPECIFIC INFORMATION ON THE INDENTIFICATION OF DANGEROUS COMAT, AND PROCEDURES TO TRANSPORT SUCH MATERIAL SAFELY. ONE HUNDRED THOUSAND COPIES OF THE BROCHURE WERE PROVIDED TO THE FAA'S REGIONAL OFFICES, THE AIR TRANSPORT ASSOCIATION, THE REGIONAL AIRLINE ASSOCIATION, AND THE AERONAUTICAL REPAIR STATION ASSOCIATION.
THE FAA HAS RECEIVED NUMEROUS REQUESTS FROM BOTH DOMESTIC AND FOREIGN AIR CARRIERS FOR ADDITIONAL COPIES AND PERMISSION TO REPRINT THE BROCHURE. I HAVE ENCLOSED A COPY OF THE BROCHURE FOR THE BOARD'S INFORMATION. THE FAA HAS ALSO DEVELOPED AND DISTRIBUTED A STANDARDIZED HAZARDOUS MATERIAL PROCEDURES MANUAL WITH TRAINING GUIDELINES FOR "WILL NOT CARRY" CERTIFICATE HOLDERS AND A CORRESPONDING MANUAL FOR "WILL CARRY" CERTIFICATE HOLDERS. THE MANUALS PROVIDE GUIDANCE AND ESTABLISH A MODEL PROGRAM TO ENSURE THAT THOSE CERTIFICATE HOLDERS WHO ADOPT THE PROGRAM ARE IN COMPLIANCE WITH 49 CFR PARTS 171 THROUGH 180.
BOTH MANUALS ARE ADVISORY IN NATURE AND CONTAIN GUIDANCE TO ASSIST AIR CARRIERS IN TRAINING PERSONNEL IN THE RECOGNITION OF DANGEROUS GOODS. I HAVE ENCLOSED COPIES OF THE MANUALS FOR THE BOARD'S INFORMATION.
June 29, 1998 · Recipient Response · FAA
Letter received MC#980825: In early 1998, the Federal Aviation Administration (FAA) and the Research and Special Programs Administration (RSPA) published and distributed a safety alert to manufacturers, air carriers, and other users of portable breathing equipment containing chemical oxygen generators. The alert outlines the applicable hazardous material (hazmat) requirements and limitations contained in 49 CFR Parts 171 through 185, Hazardous Materials Regulations, for the packaging and transport of these devices.
Along with the alert, the FAA distributed a one-page fact sheet in a question-and-answer format entitled "COMAT FACTS," which explains the hazmat regulations that apply to the offering and transport of company materials (COMAT).
The FAA developed a brochure that provides more specific information on the identification of dangerous COMAT, and procedures to transport such material safely. Distribution of the brochure is scheduled for July 2, 1998. I have enclosed a copy of the brochure for the Board's information.
In addition, the FAA is developing a standardized hazmat procedures manual for "will not carry" certificate holders and a corresponding manual for "will carry" certificate holders. The procedures set forth in these manuals are consistent with the RSPA requirements contained in the hazmat regulations and publicized in the publications discussed above. These procedures manuals will also include hazmat training curricula applicable to each air carrier employee, agent, and contractor.
I will keep the Board informed of the FAA's progress on this safety recommendation.
November 17, 1997 · NTSB Correspondence · FAA
The FAA agrees with this safety recommendation. On November 13-14, 1996, the FAA assisted ATA in sponsoring a HAZMAT/COMAT conference in Washington, DC. Representatives from air carriers, the Air Line Pilots Association, the National Transportation Safety Board, suppliers, contractors, and shippers attended the conference. I have enclosed a copy of the attendee list for the Board's information. The conference focused on key management issues, including a review of hazardous materials regulations regarding shipping, packaging, and handling of air carrier company hazardous materials.
As a result of this conference, new attention is focused on the transportation of hazardous aircraft parts and supplies. New relationships were forged between large and small airline corporate entities including airline stores, material, and maintenance personnel. Participation in industry cargo meetings and other activities have noticeably increased. On December 13, 1996, RSPA published "Advisory Notice: Transportation of COMAT by Aircraft" in the Federal Register. This notice provided guidance on the extent and application of exceptions from the hazardous materials regulations applicable to the transportation of an air carrier's company materials.
This advisory notice was redistributed in May 1997 to 5,000 certificated repair stations. Also, in February 1997 RSPA published a Safety Alert, "Advisory Guidance: Offering, Accepting, and Transporting Hazardous Materials." This guidance highlights the basic requirement and common-sense reminders necessary for complying with the hazardous materials regulations. I have enclosed a copy of the notice and a copy of the safety alert for the Board's information.
To provide further guidance to air carriers, the FAA is developing a brochure outlining the requirements air carriers must follow when transporting company materials. The brochure will focus on what materials are considered company materials and who may ship them. The brochure will be distributed to air carriers, aircraft repair stations, and aircraft parts suppliers and distributors.
The FAA will direct its principal operations inspectors, in coordination with regional dangerous goods coordinators, to ensure that procedures incorporated in air carrier manuals include guidance on transporting air carrier company materials. During routine inspections, FAA's dangerous goods inspectors will confirm that the air carrier manuals have been updated to reflect the latest guidance.
I will keep the Board informed of the FAA's progress on this safety recommendation.