Cargo Manifest Discrepancy on a Combined Passenger/Freight Sector
An RBAC 135 operator flies a mixed sector carrying 14 passengers and a belly cargo load. The load sheet lists three items: two fibreboard boxes declared as 'aircraft spare parts, not restricted' and one steel drum declared as 'paint, non-flammable, UN 1263, Class 3, PG III, 18 L'. The drum has no dangerous goods transport document attached, no shipper's declaration, and the package shows no Class 3 label. The loading supervisor says the shipper 'always sends it like this' and that the drum has travelled this route for two years. The captain is asked to sign the acceptance and depart. The aircraft is a pressurized turboprop with a cargo compartment accessible in flight. The sector is 1 hour 20 minutes.
1. Assess the acceptance decision for the steel drum against dangerous goods requirements, and state what must happen before it can be loaded.
Read the worked answer
The drum cannot be loaded as presented. Several independent deficiencies exist, and each one alone is disqualifying.
- Classification and documentation. UN 1263, Paint, Class 3, PG III is dangerous goods. It requires a completed dangerous goods transport document (shipper's declaration) signed by a trained shipper, stating proper shipping name, UN number, class, packing group, quantity, and packing instruction.
- Packaging. A steel drum is acceptable only if it is a UN-specification packaging marked with the UN symbol, the packing instruction code, and the correct performance marking for PG III liquids. The absence of any marking means compliance cannot be established.
- Marking and labelling. The package must bear the Class 3 flammable liquid label and the proper shipping name and UN number. Neither is present.
- Acceptance check. The operator's ground staff must perform and record an acceptance check against the seven-point list before the package is loaded. That check cannot be completed without the documents and markings.
- Stowage. Class 3 liquids must be stowed per the loading restrictions for the aircraft, and the cargo compartment is accessible in flight, which imposes additional stowage requirements.
The correct action is to refuse the drum, hold it, and notify the shipper. The fact that it has travelled this way for two years is evidence of a systemic failure, not a justification - it should trigger a report through the safety management system and a review of all shippers on the route.
2. The two fibreboard boxes are declared 'not restricted'. What verification is required, and what is the risk if the declaration is accepted at face value?
Read the worked answer
A declaration of 'not restricted' is a claim, not a fact, and the operator remains responsible for acceptance. Verification should include:
- Shipper's declaration for non-dangerous goods. The operator's procedures should require a signed statement identifying the contents sufficiently to allow a classification judgement, not merely a generic 'spare parts'.
- Physical inspection. Open or examine the packages where practicable. Aircraft spare parts frequently contain items that are dangerous goods in their own right - magnetized material, lithium batteries, fuel system components retaining fuel, fire extinguishers, aerosols, or pressure vessels.
- Hidden dangerous goods awareness. The acceptance agent must be trained to recognize the categories of goods that commonly conceal dangerous goods.
The risk of accepting the declaration at face value is that undeclared dangerous goods enter the cargo compartment. In a pressurized aircraft with an accessible compartment, a leaking or venting package can expose the crew and passengers to fumes, and a fire in the belly is not accessible to extinguishing in the same way as a compartment fire. It also breaches the operator's obligations and can invalidate insurance and the operating certificate's conditions.
Given that the same shipper has been mis-declaring a Class 3 drum for two years, the 'not restricted' declaration on the same shipment deserves heightened scrutiny, not less.
3. What should the captain do about the flight, and what follow-up actions are required after the decision?
Read the worked answer
The captain should not sign the acceptance as presented. The correct sequence is:
- Refuse the drum and require either compliant documentation and packaging or offloading.
- Verify the two boxes before they are loaded; if they cannot be verified, offload them as well.
- Recompute the load sheet after offloading, and confirm the aircraft remains within mass and balance limits for the sector.
- Depart on schedule if the remaining load is compliant - there is no reason to delay the passenger operation for a non-compliant cargo item.
Post-flight follow-up is mandatory and should include:
- Occurrence report through the SMS describing the undeclared dangerous goods, the missing documentation, and the packaging deficiencies.
- Notification to the shipper in writing, with a requirement for corrective action before future shipments are accepted.
- Internal review of why the drum was presented for loading at all, and whether the acceptance check was being performed or merely signed.
- Training review for the loading and acceptance staff, since the supervisor's response indicates a normalized deviation.
- Retention of records of the refusal and the report.
The captain's authority to refuse the load is not discretionary in the sense of preference; it is an obligation. The normalized practice is precisely the hazard the SMS exists to surface.