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  SUBJ: HAZARDOUS MATERIALS QUESTIONS/ANSWERS (99-5)
 
HQ AMC/DONC Message Number 081942Z Jun 99


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.

A. QUESTION: WE ARE ATTEMPTING TO MOVE PASSENGERS ON A CONTINGENCY MISSION. THE CARGO INCLUDES A WHEELED GENERATOR, WHICH IS ONE-HALF FULL, AND A VEHICLE AT THREE-QUARTER FULL. DO THESE ITEMS BECOME "CARGO AIRCRAFT ONLY" WHICH WOULD REQUIRE A PASSENGER DEVIATION?

ANSWER: THE USE OF FUEL LEVELS AUTHORIZED BY AFJMAN 24-204, CHAPTER 3, ASSUMES THERE IS AN OPREATIONAL NEED FOR THE INCREASED QUANTITIES AS DETERMINED BY PARAGRAPH 1.8. AS STATED IN PARAGRAPH 3.2, THE USE OF CHAPTER 3 PROVISIONS IMPOSES AN INCREASED RISK. THIS IS WHY PARAGRAPH 3.5 LIMITS PERSONNEL MOVEMENT TO "PARTICIPANTS" DURING TACTICAL, CONTINGENCY, OR EMERGENCY OPERATIONS. THE VEHICLE AND SUPPORT EQUIPMENT DESCRIBED DO NOT HAVE TO BE IDENTIFIED AS "CARGO AIRCRAFT ONLY." HOWEVER, THE MOVEMENT OF NON-MISSION RELATED/ NONPARTICIPANT INDIVIDUALS IS NOT AUTHORIZED AND A PASSENGER DEVIATION CANNOT BE ISSUED. NONPARTICIPANT COULD MOVE ON A TACTICAL/ CONTINGENCY VALIDATED MISSION WITHOUT NEED FOR A PASSENGER DEVIATION IF THE CARGO MET FUEL LIMITS WHICH WOULD ALLOW NORMAL MOVEMENT ON A "CHANNEL" MISSION (VEHICLES WITH NO MORE THAN ONE-HALF TANK FULL AND SUPPORT EQUIPMENT DRAINED).

B. QUESTION: WE RECEIVED A SHIPMENT OF BATTERIES WITHOUT A SHIPPER'S DECLARATION. THE SHIPPER SAID THE BATTERIES WERE NOT REGULATED BUT THE BOXES WERE MARKED "NONSPILLABLE BATTERIES" WHICH IS FOUND AS A PSN IN AFJMAN 24-204, TABLE A4.1. WE ARE TRYING TO DETERMINE IF THESE ITEMS ARE REGULATED OR NOT.

ANSWER: THE SHIPPER IS RESPONSIBLE FOR DETERMINING PROPER IDENTIFICATION AND PACKAGING OF MATERIAL BEING OFFERED FOR SHIPMENT. A REVIEW OF THE MANUFACTURE SUPPLIED MSDS REVEALED THE BATTERIES WERE DESIGNED TO MEET REQUIRED DOT VIBRATION AND PRESSURE DIFFERENTIAL TESTS AND WILL NOT LEAK ELECTROLYTE SHOULD THE CASE CRACK OR RUPTURE. BASED ON THIS INFORMATION, THE BATTERIES WOULD NOT BE REGULATED IAW AFJMAN 24-204, PARAGRAPH A12.5.2, AND SPECIAL PROVISION 67 OF TABLE A4.2. THE MARKING "NONSPILLABLE BATTERIES" COMES FROM 49CFR, 173.159(D). HOWEVER THE IDENTIFICATION NUMBER "UN2800" SHOULD NOT BE USED IN ASSOCIATION WITH THE MARKING. THE SHIPPER SHOULD HAVE ALSO ANNOTATED DD FORM 1387, MILITARY SHIPPING LABEL, WITH "NONHAZARDOUS" IAW PARAGRAPH 1.10.3.

C. QUESTION: WE HAVE CYLINDERS MARKED WITH A DOT EXEMPTION. WHEN LOOKING THE EXEMPTION UP ON THE DOT WEB SITE, THE EXEMPTION EXPIRED 31 JAN 99. HOW DO WE SHIP THESE CYLINDERS?

ANSWER: THE DOT WEB SITE, WHICH INCLUDES DOT EXEMPTIONS, MAY BE USED AS A "TOOL" BUT IS NOT ALWAYS CURRENT. AFTER RESEARCH, THE EXEMPTION WAS FOUND TO HAVE BEEN RENEWED ON 11 FEB 99. WHEN AN EXEMPTION HAS EXPIRED, FIRST CONTACT YOUR SERVICE/MAJCOM FOCAL POINT TO DETERMINE IF A RENEWAL HAS BEEN APPLIED FOR (SEE Q/A 99-4, PARA 2F) OR IF A RENEWAL HAS BEEN ACCOMPLISHED. BESIDES NOT ALWAYS BEING CURRENT, EXEMPTIONS FOUND ON THE DOT WEB SITE CANNOT BE USED BECAUSE THEY ARE INFORMATION ONLY COPIES WITH NO APPROVAL SIGNATURE.

D. QUESTION: WHILE PERFORMING A JOINT INSPECTION DURING A UNIT MOVE, WE ASKED FOR A COPY OF THE HAZMAT CERTIFYING OFFICIAL'S COMMANDER AUTHORIZATION LETTER. THE INDIVIDUAL DID NOT HAVE ONE WITH HER. IS THIS A REASON TO FRUSTRATE THE SHIPMENT?

ANSWER: THE SHIPPER IS RESPONSIBLE TO PROPERLY PREPARE/PACKAGE HAZARDOUS MATERIALS FOR MILITARY AIRLIFT. THEY MUST ALSO ENSURE A QUALIFIED PERSON CERTIFIES THE CARGO. THE UNIT COMMANDER IS RESPONSIBLE FOR DESIGNATING IN WRITING THOSE TECHNICAL SPECIALIST, BASED ON TRAINING, QUALIFIED TO SIGN THE SHIPPER'S DECLARATION IAW AFJMAN 24-204, PARA A25.3.2. HOWEVER, UNLESS REQUIRED BY LOCAL DIRECTIVES, THE CERTIFYING OFFICIAL DOES NOT HAVE TO PRESENT A COPY OF THE COMMANDER'S APPROVAL DURING THE INSPECTION PROCESS.

E. QUESTION: WE INSPECTED A SHIPMENT CERTIFIED AS "LITHIUM BATTERIES PACKED WITH EQUIPMENT" DURING A MOBILITY EXERCISE? THE BATTERIES WERE NEW BUT PACKED LOOSE IN THE SAME BOX WITH THE RADIO EQUIPMENT. DOES THE OUTSDE BOX REQUIRE POP TESTING?

ANSWER: THE LITHIUM BATTERIES MUST BE IN AN APPROVED POP-TESTED CONTAINER LISTED IN PC POP III OR COMMERCIAL EQUIVALENT. THE OUTSIDE BOX CONTAINING THE BATTERIES AND EQUIPMENT DOES NOT REQUIRE POP TESTING.

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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