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FYI I also don’t agree with the HACs suggestions for change in the discussion paper. To me it doesn’t help the situation at all. 
When it comes to the TDGRs, they are written by people who have no idea what helicopter operations entail in Canada. The HAC has been trying to explain to them why helicopter pilots need to carry a variety of consumer commodities in their spares (to maintain their aircraft daily) for years. Do you do a NOTOC and TDG records every time you transport your spares (for your WD-40, window cleaner and contact cleaner etc.)?  The whole idea of me writing a notification to pilot in command FORM , to give to myself is absurd, but it is required to Transport “Consumer Commodities” under TDGR.

In this era of risk based approach to regulation development, how is it any less safe to carry propane to a backcountry hut, than a forestry operation? Both could literally be at the same location.

 Most pilots don’t even know the requirements, and who can blame them? I bet most who read my post found their eyes rolling back in their head about halfway through.

All of this is nothing more than a distraction for pilots, who should be concentrating on FLYING THE AIRCRAFT.  You know, Distraction, as identified in your CRM training as being a major contributor to many accidents.

I guess they figure you’re just twiddling your thumbs while clients load DGs on board with the aircraft running. Lots of time to check DG paperwork etc.

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I should also mention, that you are correct, the TDGRs do not make a distinction between internal or external loads. Whether it is internal or external, you are still transporting dangerous goods, so the TDGRs do apply.

it sounds like you’ve done your homework, just apply for the propane EC and be done with it. They hand those things out like they are going out of style. Just search someone else’s on the TC website and copy and paste into the online application. Turnaround in my region has been surprisingly efficient (before COVID anyway).

Dont forget you still need to complete and retain a daily DG record ( most companies have a checkbox on the flight report that says “Dangerous Goods Transported” that needs to be checked) to be compliant under 12.9 limited access.

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I wonder if it's worth applying for an EC allowing transport to limited access areas via external load, in a manner that doesn't comply with TDGR. Namely the quantity limits of various DG. 

Or if TC would go for that at all.

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From what I recall on one of the Solocks exams was that as soon as something goes on the hook, all quantity restrictions etc went out the window.  
 

There are of course exceptions if you’re hauling explosives but fuel, propane etc, as long as you had it in your COM and EC paperwork, you’re good to go. 

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On 4/10/2021 at 10:35 AM, Bif said:

I wonder if it's worth applying for an EC allowing transport to limited access areas via external load, in a manner that doesn't comply with TDGR. Namely the quantity limits of various DG. 

Or if TC would go for that at all.

This just showed up in the inbox. Haven't had a chance to review fully, but lots of relevant changes to limited access and aerial work. Apparently, many of the proposed changes will eliminate the need for Equivalency Certificates we are discussing. Also relevant an amendment to TDGR 12 to "Provide an exemption for dangerous goods that are required for the safety and operation of the aircraft and that are not already exempt under the ICAO TI. The intent of the exemption would be to capture dangerous goods, such a portable fuel pumps and spares kits".

Notice to CARAC members,  

Please find attached a working document which includes the draft provisions envisioned for the update of the air-related provisions to the Transportation of Dangerous Goods Regulations (TDGR). These updates propose a series of clarifications, as well as updated exemptions to the ICAO Technical Instructions, namely for the transportation of dangerous goods to remote locations. They also reflect the comments received during past consultations.

CONSULTATION_DOCUMENT_PART_12_-_DOCUMENT_CONSULTATION_PARTIE_12_BIL.doc

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  • 3 weeks later...

@Freewheel I'm interested in your take on the above, but the only section I can see which pertains to the question of Propane is that they are adjusting the max cylinder volume 

"The maximum capacity per means of containment for these otherwise forbidden gases would be increased from 100 L to 110 L cylinders, as this represents the typical capacity required to hold 100 lb. of gas. Increasing the limit would accommodate these cylinders.

The total capacity of all cylinders on a passenger plane would be increased from 120 L to 132 L, as this represents the capacity of one 100 lb. cylinder plus one 20 lb. cylinder (which has a capacity of 21.5 L). This would address the intent of the current limits."

Which doesn't solve the 420lbs tank issue, only legitimizes the 100lbs tanks.

 

Otherwise, it seems like there's some decent stuff about bear spray and bangers and Peace Officers, etc which would I suppose render the HAC certificate obsolete.

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On 5/3/2021 at 6:25 PM, Bif said:

@Freewheel I'm interested in your take on the above, but the only section I can see which pertains to the question of Propane is that they are adjusting the max cylinder volume 

"The maximum capacity per means of containment for these otherwise forbidden gases would be increased from 100 L to 110 L cylinders, as this represents the typical capacity required to hold 100 lb. of gas. Increasing the limit would accommodate these cylinders.

The total capacity of all cylinders on a passenger plane would be increased from 120 L to 132 L, as this represents the capacity of one 100 lb. cylinder plus one 20 lb. cylinder (which has a capacity of 21.5 L). This would address the intent of the current limits."

Which doesn't solve the 420lbs tank issue, only legitimizes the 100lbs tanks.

 

Otherwise, it seems like there's some decent stuff about bear spray and bangers and Peace Officers, etc which would I suppose render the HAC certificate obsolete.

I have not had the time to review the proposed amendment thoroughly, however, I do agree that under limited access, the size of the cylinders are still limited to prevent you from transporting larger cylinder. With that being said the changes  to aerial work could be relevant.
“The scope of aerial work would align with the scope of application in the 
Canadian Aviation Regulations (CARs)”. They are removing the “activities listed in the aerial work section and replacing with aerial work activities listed in CARs. Aerial work also only limits you to small means of containment (which is less than 450 L).  Depending on interpretation, you could argue that any external load is “aerial work”. Regardless of who you are transporting it to, whether it be an aerial work site or a personal cabin; By simply conducting external load ops, it becomes an aerial work activity/ site.

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48 minutes ago, Freewheel said:

I have not had the time to review the proposed amendment thoroughly, however, I do agree that under limited access, the size of the cylinders are still limited to prevent you from transporting larger cylinder. With that being said the changes  to aerial work could be relevant.
“The scope of aerial work would align with the scope of application in the 
Canadian Aviation Regulations (CARs)”. They are removing the “activities listed in the aerial work section and replacing with aerial work activities listed in CARs. Aerial work also only limits you to small means of containment (which is less than 450 L).  Depending on interpretation, you could argue that any external load is “aerial work”. Regardless of who you are transporting it to, whether it be an aerial work site or a personal cabin; By simply conducting external load ops, it becomes an aerial work activity/ site.

My mistake, a 420 lbs propane cylinder has a water capacity of 454 litres which disqualifies it as a “small means of containment”. Looks like, you may be correct, and  there will still be a need for the Equivalency Certificate.  Under that premise,  an EC would be required under Aerial Work 12.12 also

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I started the EC application process for that last week, I'll let you know how it turns out. 

 

Frustrating that they are amending the volume limit for gases to accommodate 100lbs cylinders, but aren't doing the same to include 425lbs.

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