The use of hand sanitizers to help prevent the spread of COVID-19 has led to questions on restrictions that may apply when carried on board aircraft by passengers and crew. Alcohol-based hand sanitizers, also known as alcohol-based hand rubs, are dangerous goods subject to Annex 18 — The Safe Transport of Dangerous Goods by Air. Annex 18 excepts articles and substances carried by passengers or crew from its provisions to the extent specified in the Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284, “Technical Instructions”). The Technical Instructions restrict dangerous goods carried by passengers and crew in carry-on baggage, checked baggage or on one’s person to those for personal use permitted in accordance with Table 8-1. The entry in Table 8-1 that most appropriately describes alcohol-based hand sanitizers/alcoholbased hand rubs is “Non-radioactive medicinal articles (including aerosols), toiletry articles (including aerosols) and aerosols in Division 2.2 with no subsidiary hazard”.
The total net quantity of all articles in this entry carried by a passenger or crew member must not exceed 2 kg or 2 L and the net quantity of each single article must not exceed 0.5 kg or 0.5 L. Where passengers or crew wish to carry alcohol-based hand sanitizers in their carry-on baggage, they may be restricted to a net quantity limit per container of 100 mL or additional restrictions imposed by States in the interests of aviation security Additional information on security restrictions can be found in the ICAO Guidelines for Aviation Security Contingency Measures during the COVID-19 Pandemic. For more information, please contact
Annex 18, Chapter 10 requires that "initial and recurrent dangerous goods training programmes shall be established and maintained in accordance with the Technical Instructions". The Technical Instructions require that "recurrent training must be provided within 24 months of previous training to ensure knowledge is current."
Difficulties in obtaining or providing recurrent training during the COVID outbreak has led many States to issue temporary extensions to the period of validity for dangerous goods training. The Secretary General has encouraged States to be flexible in their approaches to facilitating safe operations during these difficult times while at the same time adhering to their obligations under the Convention on International Civil Aviation (Doc 7300, Chicago Convention). States should therefore have a solid rationale for granting extensions and should ensure appropriate mitigation measures are in place. Alleviations should be established using the Safety Risk Management approach. CLICK HERE for more information.
In considering their obligations under Annex 18, States should keep in mind the objective of dangerous goods training, which is to ensure personnel are competent to perform their dangerous goods functions prior to performing them. The type of training provided to achieve this objective is not prescribed in Annex 18 or the Technical Instructions. While physical distancing practices or closure of work spaces may make classroom training prohibitive, other means of training or combination of training methods can be used to achieve the training objective. Examples include online courses, webinars, virtual classrooms, and on-the-job training.
CLICK HERE for a quick reference guide on alleviations related to recurrent dangerous goods training developed by ICAO with the support of dangerous goods, operations and other relevant subject matter experts.
Some States have provided ICAO with information regarding measures taken to address difficulties in obtaining or providing recurrent training during the COVID outbreak. CLICK HERE for links to websites where this information can be found. If you wish to have a link to your State's dangerous goods/COVID-19 related websites, please send the name of your entity and links to CSS@icao.int.
PERSONS ON BOARD A CARGO-ONLY AIRCRAFT CARRYING DANGEROUS GOODS NOT PERMITTED ON A PASSENGER-CARRYING AIRCRAFT
The COVID outbreak has led to an unprecedented reduction in the number of passenger carrying flights, with almost all passenger operations being suspended, and an increase in the need to transport critical and often life-saving cargo, including dangerous goods, quickly all over the world. States are taking various actions to enable service providers and personnel to move this cargo, despite the challenges.
Operators have reported difficulties in positioning their aircraft crew due to the lack of passenger flights and are increasingly using all-cargo flights to do so.
ICAO has been made aware that some States are restricting certain people on board cargo-only aircraft transporting dangerous goods not permitted on passenger-carrying aircraft. These restrictions have been based on their interpretation of definitions for passenger and cargo aircraft contained in Annex 18 and the Technical Instructions. There are concerns that the restrictions will further impede the ability of operators to position crew.
Annex 18 should not be interpreted to prohibit or limit positioning of crew on an operator's cargo aircraft carrying dangerous goods not permitted on passenger aircraft. This includes personnel that may not be assigned operational duties on the specific flight, such as repositioning flight and cabin crew, loadmasters and maintenance personnel.
The definitions for passenger and cargo aircraft are included in Annex 18 and the Technical Instructions for the purpose of distinguishing between the types and quantities of dangerous goods permitted on a cargo versus a passenger-carrying aircraft. The carriage of passengers on an aircraft is governed by the Standards in Annex 6.
DANGEROUS GOODS ON AIRCRAFT WITH PASSENGER CABINS THAT HAVE BEEN REPURPOSED FOR TRANSPORT OF CARGO
Some operators are repurposing underutilized passenger aircraft in order to increase their cargo capacity. In doing so, airworthiness and operational considerations must be taken into account. CLICK HERE for guidance.
LINKS TO CAA WEBSITES CONTAINING DANGEROUS GOODS/COVID-RELATED INFORMATION THAT HAVE BEEN PROVIDED TO ICAO