Air Transport Association of America, Inc.
Barbara Vaiter, Managing Director, Cargo Services, ATA, email dated 2/23/09: Thank you very much for your patience in this matter. As you noted, A-97-82 (copies attached) recommends development of programs to educate U.S. Postal Service (USPS) customers about the dangers of transporting undeclared hazardous materials on aircraft. As you can imagine, many things are much different today in the air cargo world than ten years ago. Below I have attempted to outline the major areas where improvements and programs by USPS and other government agencies, in collaboration with air carriers, have addressed concerns raised by NTSB.
First, I would like to offer a clarification. All U.S. Mail transported in the bellies of passenger aircraft is tendered by USPS. U.S. postal customers do not directly tender mail to the airlines as baggage or air cargo. This reduces the points of acceptance and has enabled government and industry to be more focused in communicating with the general public using mail services to ship potentially hazardous items.
Secondly, subsequent to the terror attacks of 9/11/2001, TSA air cargo security measures were mandated which implemented screening of mail transported on passenger aircraft. As a result, USPS adopted the following Aviation Mail Security Program:
Due to heightened security, all mailpieces weighing over 13 ounces bearing only postage stamps as postage must be presented to an employee at a retail service counter at a Post Office. Mailpieces weighing over 13 ounces bearing only postage stamps as postage deposited in collection boxes, lobby drops, or left on counters, in lobbies, or on postal docks will be returned to the sender. Mailpieces weighing over 13 ounces bearing only postage stamps as postage that are left in customer mailboxes will not be picked up by the carrier. Instead, the carrier will return the mailpiece to the customer's mailbox.
The additional security measures implemented as a result of heightened aviation security concerns have had the unintended effect of an increased level of scrutiny and awareness of hazardous materials by requiring a personal hand-off from the least sophisticated shippers to the USPS.
Third, as a result of the requirement to tender mail at a retail service counter, the shipper will be faced with the attached Notice #107 Let’s Keep the Mail Safe regarding hazardous materials which the Postal Service displays at all retail stores. In addition, Poster 138 found at most mail acceptance locations, is a guide for shipping common hazardous, restricted and perishable materials.
Fourth, USPS has addressed the hazmat education issue in greater depth by leveraging the use of their public website. Those persons shipping or planning to ship by air using the postal system can visit the USPS Security & HazMat webpage to basic information What is a Hazardous Material such as pasted below, to more detailed and technical Resources to Help Determine Mailability and the Hazardous Materials Program section which warns the public that Mailers are responsible for Ensuring no hazardous material is mailed unless it is permitted under Postal Service mailing standards described in the Domestic Mail Manual 601.10
What is a Hazardous Material?
Hazardous materials come in a wide variety of forms and can be chemical, biological, radioactive, or a combination thereof. If a material or substance can cause harm to someone or something, it can be considered a hazardous material.
The Postal Service’s definition of a hazardous material includes many common household and consumer products. These items may not be hazardous during normal use or storage in your home but can present a significant hazard when placed in the mail due to vibration, temperature changes, and variations in atmospheric pressure.
Some examples of commonly-used items restricted or considered hazardous under USPS regulations include:
Flea collars or flea sprays
Fuels or gasoline
Items previously containing fuel
Other items, such as alcoholic beverages (beer, wine, liquor), are not considered hazardous but are prohibited and boxes displaying such markings are also prohibited.
If you are unsure whether a material is considered hazardous or is prohibited, please contact 1-800-ASK-USPS or your local Business Mail Entry Unit.
I don’t believe that most, if not all of these resources and procedures existed for mail transported by air back in 1997. The value of the Pipeline and Hazardous Materials Administration’s (PHMSA) SafeTravel website for passengers packing potentially hazardous materials in their baggage, and the educational and awareness campaigns implemented by the Postal Service directed to the mailing public, have contributed to improving awareness and compliance with hazardous materials regulations.
Barbara Vaiter, Managing Director, Cargo Services, ATA, email dated 3/16/09 Thanks for the feedback. I guess I chose to read the last highlighted sentence to mean that the programs would focus on the various items (baggage, cargo and mail) that might be offered by USPS customers. The way I had interpreted the documents you provided, undeclared passenger hazmat was not determined to be a probable cause of the ValueJet incident. Consequently, I had some difficulty wrapping my head around the broad scope of recommendation A-97-82. Nonetheless, I will attempt to outline some of the major steps taken by industry and government over the past decade. Hopefully this will show why the 1997 NTSB statement: the ValueJet accident and the incidents that have occurred since clearly demonstrate that the shipment of undeclared hazardous materials in air transportation is a serious problem that has not been adequately addressed may not be the case today. Below are just a few of the ways that the issue has been addressed; the FAA’s Office of Hazardous Materials could likely provide many more examples:
1.Through regulation, post-911 requirements for acceptance of checked luggage require the TSA to screen all baggage for the presence of explosives or other items that could pose a security threat. During the course of TSA baggage searches, screeners have been trained to identify common hazmat and prohibited items and coordinate with air carrier personnel for removal from baggage. These procedures were not in place in 1997 and subsequent to their implementation, the number of undeclared hazardous items removed from passenger baggage has increased exponentially.
2.FAA implemented comprehensive passenger notification processes through regulation, requiring airlines to provide passenger addresses when undeclared hazardous goods are removed from luggage by TSA. It is our understanding that as a result of these requirements, FAA has issued a substantial number of letters to passengers involved in these incidents, in an effort to educate them and prevent potential violations during future travel.
3. PHMSA’s http://safetravel.dot.gov website outreaches directly to the air traveling public on a wide variety of common, but prohibited, dangerous materials that passengers typically travel with. While initially developed to address the emerging threat of lithium batteries in laptop computers and personal electronics carried on board by passengers and packed in their luggage, the website continues to expand to provide public education on many types of undeclared hazmat such as aerosols, ammunitions, and self-defense spray.
4.Air carriers, as well as TSA, have embedded links to the SafeTravel site from the travel pages of their websites. Several airlines have additionally added tips and links during on-line check-in as an integral step in boarding pass creation.
5.A significant number of carriers have incorporated dangerous goods awareness tips into their inflight magazines. In the past few years, dangerous goods information has become as common as, and delivered in conjunction with, prohibited items lists related to security.
6.Some of the nation’s largest all-cargo carriers have developed robust, detailed programs to educate customers and pre-qualify shippers of potentially hazardous goods. One program that comes to mind includes educational brochures, and even an on-line training program for shippers (see http://fedex.prosperitylms.com/req/fedex_student/index.cfm )
I hope the above will assist in rounding out the ATA response to include passenger baggage and air cargo shipments. As you are undoubtedly aware, people, their bags, and cargo transported on passenger aircraft are routinely screened for potential explosives and other dangerous items that could pose a security threat. An unintended consequence of this has been increased public awareness and an opportunity for industry to leverage security-related screening and educational communication to improve safety awareness and mitigate potential for the introduction of dangerous goods in aviation.