SUBJ: HAZARDOUS MATERIALS QUESTIONS/ANSWERS (99-4)
1. THE FOLLOWING PROVIDES GUIDANCE TO AMC TRANSPORTATION FUNCTIONS.NON-AMC UNITS SHOULD CONTACT SERVICE/COMMAND FOCAL POINT LISTED IN AFJMAN 24-204 OR COMMAND DIRECTIVES FOR GUIDANCE.
2. QUESTIONS/ANSWERS:
A. QUESTION: WE RECEIVED A MISSILE SHIPMENT CERTIFIED AS "ROCKETS,LIQUID FUELED". AFJMAN 24-204, PARAGRAPH A5.11 STATES THE HANDLING INSTRUCTIONS FROM A.5.74 FOR ROCKET MOTORS WITH HYPERGOLIC FUEL MUST ALSO BE COMPLIED WITH. THE SHIPPER DID NOT INCLUDE HANDLING
ISTRUCTIONS IN KEY 19 OF THE SHIPPER'S DECLARATION. IS THE HANDLING INSTRUCTION ENTRY REQUIRED?
ANSWER: THE SPECIFIC MISSILES IN QUESTION USE JP-8, A FLAMMABLE LIQUID, WHICH IS NOT A HYPERGOLIC OR CORROSIVE/TOXIC FUEL. THE HANDLING INSTRUCTION WOULD NOT BE ANNOTATED IN KEY 19 SINCE NO SPECIAL PRECAUTIONS OR SAFETY REQUIREMENTS MUST BE FOLLOWED FOR JP-8.
B. QUESTION: WE ARE SHIPPING A DOT EXEMPTED CYLINDER DURING A MOBILITY EXERCISE. THE EXEMPTION IDENTIFIES THE ITEM AS "CARGO AIRCRAFT ONLY"; HOWEVER, IN AFJMAN 24-204, TABLE A4.1, THE PSN IS LISTED AS A "P5" (PASSENGER ACCEPTABLE). HOW DO WE COMPLETE KEY 7 OF THE SHIPPER'S DECLARATION AND LABEL THE CYLINDER?
ANSWER: THE "P" CODES IN AFJMAN 24-204 FOR COMPRESSED GASES ARE BASED ON THE USE OF DOT SPECIFICATION CYLINDERS. WHEN THE DEPARTMENT OF TRANSPORTATION AUTHORIZES THE USE OF AN ALTERNATE CYLINDER BY APPROVING AN EXEMPTION, THE EXEMPTION BECOMES THE CERTIFICATION
REFERENCE IAW AFJMAN 24-204, FIGURE A17.1, KEY 17. ALL PROVISIONS OF THE EXEMPTION MUST BE FOLLOWED. THEREFORE, KEY 7 MUST REFLECT THE SHIPMENT AS "CARGO AIRCRAFT ONLY" AND A "CARGO AIRCRAFT ONLY" LABEL APPLIED TO THE CYLINDER (OR OUTER CONTAINER). THIS LABEL MAY BE OMITTED DURING TACTICAL, CONTINGENCY, OR EMERGENCY OPERATIONS OR EXERCISES SIMULATING THESE OPERATIONS IAW PARAGRAPH A15.3.
C. QUESTION: WE RECEIVED A SHIPMENT OF CYLINDERS FOR INSPECTION WHICH ARE CERTIFIED TO A DOT EXEMPTION. THE EXEMPTION INCLUDES A GREAT DEAL OF INFORMATION TO DESIGN CRITERIA. WHAT SHOULD WE BE CHECKING ON THE EXEMPTION?
ANSWER: THE SHIPPER IS ULTIMATELY RESPONSIBLE FOR IMPROPER PREPARATION OF THE HAZARDOUS MATERIALS AND COMPLIANCE WITH THE DOT EXEMPTION. "INSPECTORS" WILL CHECK THE EXEMPTION FOR CURRENCY, ANY MODAL RESTRICTIONS, MARKING AND PACKAGING REQUIREMENTS. DESIGN SPECIFICATIONS, COMPLIANCE WITH CYLINDER RE-TESTING, ETC., WOULD NOT NORMALLY BE CHECKED DURING THE INSPECTION. ALSO, THERE IS NO REQUIREMENT FOR THE INSPECTION FUNCTION TO RE-COMPUTE THE QUANTITY OF HAZARDOUS MATERIAL ANNOTATED IN KEY 16 OF THE SHIPPER'S DECLARATION USING ATTACHMENT 26.
D. QUESTION: I AM INSTRUCTING A "TECHNICAL SPECIALIST" CLASS. A STUDENT ASKED WHAT RARE GASES WOULD BE INCLUDED AS PART OF THE PSN, "RARE GASES AND OXYGEN MIXTURES" UN1980. AFJMAN 24-204 DOES NOT PROVIDE A DEFINITION. I ALSO LOOKED IN 49CFR. DO YOU HAVE AN ANSWER?
ANSWER: LOOK EITHER IN THE ICAO, TECHNICAL INSTRUCTION, TABLE 2-14 OR THE IATA, DANGEROUS GOODS REGULATIONS, SECTION 4, UNDER "RARE GASES MIXTURE, COMPRESSED" UN1979. RARE GASES INCLUDE: ARGON, HELIUM, KYPTON, NEON, XENON, ETC. DEFINITIONS FOUND IN 49CFR, IATA, OR ICAO MAY ALSO BE USED WHEN CONSISTENT WITH REQUIREMENTS OF AFJMAN 24-204 FOR MILITARY AIRLIFT.
E. QUESTION: WE RECEIVED A SHIPMENT OF EXPLOSIVES NOT LISTED IN T.O. 11A-1-46. WE CAN DETERMINE FROM THE SHIPPER'S DECLARATION THAT THE CORRECT FIRE SYMBOL FOR THE STORAGE LOCATION BASED ON THE HAZARD CLASSIFICATION SHOWN IN KEY 12. HOWEVER, HOW WOULD WE KNOW IF A CHEMICAL HAZARD SYMBOL IS REQUIRED?
ANSWER: THE JOINT HAZARD CLASSIFICATION SYSTEM (JHCS) NOW INCLUDES, AS PART OF THE DATA BASE, THE "HAZARD SYMBOL CODE" (WHEN REQUIRED) FOR EACH NATIONAL STOCK NUMBER. IF AN ITEM IS NOT LISTED IN THE JHCS, SUCH AS AN ITEM SHIPPED UNDER AN INTERIM CLASSIFICATION, AFJMAN 91-201, EXPLOSIVES SAFETY STANDARDS (DTD 1 MAY 99), TABLE 2.3 CAN B USED TO ASSIST IN DETERMINING NEED FOR A CHEMICAL HAZARD SYMBOL AND/OR IN THE SELECTION OF THE CORRECT SYMBOL. THE JHCS CAN BE ACCSSED AT: http://www.dac.army.mil/es/est/hc.asp.
F. QUESTION: WE NEED TO SHIP AIRCRAFT FIRE BOTTLES MARKED "DOT-4DS". THE AGENT IS BROMOTRIFLUOROMETHANE. HOWEVER, WE CANNOT FIND THIS DOT SPECIFICATION CYLINDER LISTED IN AFJMAN 24-204, PARAGRAPH A6.8. HOW DO WE CERTIFY THIS ITEM?
ANSWER: THIS CYLINDER IS PART OF AN AIRCRAFT FIRE EXTINGUISHING SYSTEM AND IS NOT ACTUALLY A FIRE EXTINGUISHER AS DESCRIBED IN A6.8. THIS ITEM IS BETTER DESCRIBED BY THE PSN, "COMPRESSED GASES, N.O.S. (BROMOTRIFLUOROMETHANE) UN1956.
F. QUESTION: WE HAVE A CYLINDER MANUFACTURED IAW A DOT EXEMPTION. THE COPY OF THE EXEMPTION HAS EXPIRED, BUT WE UNDERSTAND A RENEWAL HAS BEEN APPLIED FOR, BUT NOT YET APPROVED. WE NEED TO SHIP THIS CYLINDER IN THE NEXT FEW DAYS. THE AERIAL PORT WILL NOT ACCEPT THE EXPIRED EXEMPTION. WHAT DO WE DO?
ANSWER: IF YOU HAVE ACTUAL KNOWLEDGE OF THE RENEWAL APPLICATION, THEN YOU MAY ANNOTATE THE COPY OF THE EXEMPTION ACCOMPANYING THE SHIPMENT, "RENEWAL REQUESTED, CURRENT EXEMPTION STILL VALID." REFER TO AFMC-LSO/LOP MESSAGE 181340Z AUG 98, SUBJ: USE OF DEPARTMENT OF TRANSPORTATION (DOT) EXEMPTIONS.
G. QUESTION: AFJM 13-210, JOINT AIRDROP INSPECTION RECORDS, MALFUNCTION INVESTIGATIONS, AND ACTIVITY, PARAGRAPH 2-2A(2)(A) REQUIRES THE AIR FORCE JOINT AIRDROP INSPECTOR TO CHECK HAZARDOUS MATERIALS CERTIFICATION. IS THERE A REQUIREMENT TO INSPECT EXPLOSIVES AND OTHER HAZARDOUS MATERIALS AFTER THEY ARE "RIGGED" FOR AIRDROP?
ANSWER: AFJMAN 24-204, PARAGRAPH 1.14 STATES THAT HAZARDOUS MATERIALS PREPARED FOR AIRDROP WILL BE "ACCEPTED" THE SAME AS AIR LANDED CARGO. THE PROVISION IN AFJ 13-210 PROVIDES FOR AIRDROP INSPECTORS TO ENSURE THE LOAD IS PROPERLY RIGGED AND THAT THE HAZARDOUS MATERIALS
CERTIFICATION (SHIPPER'S DECLARATION) ACCOMPANIES THE SHIPMENT. THE HAZARDOUS MATERIALS AND DOCUMENTATION WILL BE INSPECTED BY AN INDIVIDUAL QUALIFIED AS AN "INSPECTOR" IAW AFJMAN 24-204, PARAGRAPH A25.2. IF HAZARDOUS MATERIALS CANNOT BE ADEQUATELY INSPECTED AFTER RIGGING, THEN LOCAL PROCEDURES SHOULD BE ESTABLISHED FOR PERFORMING THE INSPECTION BEFORE RIGGING. AMC FORM 1015, HAZMAT INSPECTION AND ACCEPTANCE CHECKLIST, CAN BE USED FOR THIS PURPOSE. AMC INSPECTORS WILL ANNOTE KEY 6 OF THE SHIPPER'S DECLARTION, "RECEIVED AND INSPECTED BY............" IAW AMCI 24-101, VOL 11, PARAGRAPH 39.5.2.
3. MESSAGES WHICH SHOULD BE A PART OF THE AMC HAZARDOUS MATERIALS INFORMATION FILE (HMIF):
A. HMIF 97-1: HAZARDOUS MATERIALS (HAZMAT) INSPECTION
B. HMIF 97-2: AIRLIFT OF BOATS
C. HMIF 97-3: INSPECTION OF RADIOACTIVE MATERIAL AND ETIOLOGIC AGENTS
D. HMIF 98-1: SUPPORT EQUIPMENT IDENTIFIED AS LEAKERS
4. POC IS MR. DEL HAMILTON, HQ AMC/DONCO, DSN 576-3967. QUESTIONS MAY ALSO BE SENT BY FAX (DSN: 576-3854, COMM: 618-256-3854) OR EMAIL:delbert.hamilton@scott.af.mil. Q/A MESSAGES MAY BE ACCESSED BY THE INTERNET: http://amc.scott.af.mil/do/don/hazmat.htm (You must be on a military computer to access this site). There is a lot of good information located here if you have the capability to access it.
Q/A MESSAGES PRIOR TO MARCH 97 WILL SOON BE REMOVED FROM THIS SITE. THIS MESSAGE HAS BEEN COORDINATED WITH AFMC-LSO/LOP.
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