Loading chlorine with other cargo and an incomplete NOTOC
At a cargo terminal, a load planner is building a pallet for a freighter flight from Hong Kong to Anchorage. One pallet contains a single cylinder of UN 1017 Chlorine, Class 2.3, with subsidiary risks 5.1 and 8, net 50 kg; the cylinder itself bears a 'Cargo Aircraft Only' label, but the pallet has no label visible from the loading side. A second pallet contains UN 3480 lithium ion batteries, PI 965 Section IA, and a third contains UN 1263 Paint, Class 3, PG II, 40 × 5 L cans. The NOTOC prepared by the load planner reads: 'Chlorine, UN1017, 2.3, 50 kg, position 13.' The pallets are to be loaded adjacent to each other in the main deck. The load planner says: 'Chlorine is a gas, so it does not need segregation from batteries or paint; the NOTOC already gives the class and quantity, which is all the captain needs.' The aircraft is a cargo aircraft and the operator has no relevant variation.
1. Assess the loading arrangement against the segregation and loading requirements for these three consignments.
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The 'gas so no segregation' statement is too casual. The segregation table must be checked for the actual classes: Class 2.3 (with subsidiary 5.1 and 8), Class 9 and Class 3. On the IATA table there is no mandatory separation between Class 2.3 and Class 9, and the Class 2.3/Class 3 combination also does not automatically require separation, so adjacency is not by itself a violation. But that does not make the load acceptable: the chlorine cylinder must be secured against movement, the CAO label must be visible on the pallet, and the operator's loading instructions for toxic gas must be followed. The load planner must verify the table rather than rely on a general statement.
2. Identify the deficiencies in the NOTOC and the pallet labelling, and state the correct NOTOC entries.
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The NOTOC is deficient. It must show, for each entry, the proper shipping name, UN number, class, subsidiary risk(s), number and type of packages, net quantity, and stowage position. For the chlorine it should read, for example: 'UN 1017, Chlorine, 2.3 (5.1, 8), 1 cylinder, 50 kg, position 13.' The lithium batteries and paint also need NOTOC entries. The pallet must carry the 'Cargo Aircraft Only' label visibly; a label only on the cylinder inside the pallet is not sufficient for loading personnel. The NOTOC must be given to the captain before departure.
3. What should the load planner do before the pallets are loaded?
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Before loading, the planner should correct and reissue the NOTOC, make the CAO label visible on the outside of the pallet, secure the cylinder, and confirm the segregation check against the table. The loading supervisor should verify the pallet positions and the NOTOC against the actual packages. If any label, entry or securing point cannot be corrected, the pallet should be held. The planner should also confirm that the cargo aircraft is the intended aircraft and that no operator variation restricts the toxic gas.