The outbreak of Covid-19 is creating many questions and concerns from airlines in several areas, which include alcohol-based hand sanitisers in the aircraft for use by crew members as operator equipment; and alcohol-based hand sanitisers carried by passengers and crew members in checked and carry-on baggage. IATA recently released a guidance document to clarify any confusion.
The South African Civil Aviation Authority (SACAA) in its Communique and Guidance material has highlighted the process to be followed to allow Airlines and other Operators to be legally compliant in many aspects including requesting authorisation for the addition of alcohol-based hand sanitisers as aircraft equipment.
Addition of Alcohol-Based Hand Sanitiser as Aircraft Equipment
The use of alcohol-based hand sanitiser as an adjunct to washing hands with soap and water is one of the recommendations from the WHO to prevent the spread of Covid-19. To ensure that the risk of infection of crew members is minimised, many airlines are looking to add into the items carried in the galley or installed in aircraft lavatories alcohol-based hand sanitisers.
However, alcohol-based hand sanitisers are classified as dangerous goods and are not specifically permitted by the IATA Dangerous Goods Regulations and ICAO Technical Instructions for the Safe Transport of Dangerous goods by Air (Technical Instructions).
South African Airlines that wish to add alcohol-based hand sanitisers to the items carried in galleys or installed in lavatories will need to request authorisation from the SACAA. This should be done in accordance with the provision that is set out in the ICAO Technical Instructions, which reads as follows:
2.2 EXCEPTIONS FOR DANGEROUS GOODS OF THE OPERATOR
2.2.1 The provisions of these Instructions do not apply to the following:
a) articles and substances which would otherwise be classified as dangerous goods but which are required to be aboard the aircraft in accordance with the pertinent airworthiness requirements and operating regulations or that are authorised by the State of the Operator to meet special requirements;
The request to SACAA for authorisation to carry alcohol based hand sanitisers should address the following:
▪ the classification and UN number of the hand sanitiser;
▪ the quantity of hand sanitiser in each container and the number of containers to be carried on the aircraft;
▪ what steps will be taken to ensure that the hand sanitiser is kept away from sources of heat or ignition;
▪ provision of information to crew members on the carriage of the hand sanitiser.
Carriage of Alcohol-Based Hand Sanitiser in Passenger and Crew Baggage
IATA Dangerous Goods Regulations sets out the allowances for passengers and crew to have in their checked or carry-on baggage medicinal or toiletry articles. This may include articles containing alcohol as follows:
Alcohol-based hand sanitiser is acceptable where passengers or crew wish to have the hand sanitizer in their carry-on baggage. The limit of 100 mL or equivalent per item for liquids and gels in accordance with the aviation security provisions applies.
The full guidance document published by IATA can be found at the link below.
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