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Updated
August 7, 2007 TSA PERMITS CO2 CYLINDERS
Effective August 4, 2007, the TSA again permits the CO2 cylinders with
an Inflatable PFD through
their security checkpoints. The permission process this time went
through the White House and Congress. It is expected that this approval
will stay in place much longer due to a much broader approval process.
TSA Screeners across the United States have been trained already and are
prepared to let these through. Look under "Disabling Chemicals
& Other Dangerous Items" for specifics: http://www.tsa.gov/travelers/airtravel/prohibited/permitted-prohibited-items.shtm
Remember though, it is still each airlines choice whether to allow these
on their airplanes and each sets their own policies (roughly 1/2 allow
them and 1/2 don't). Check with your airline (and connecting or return
flights) or their websites to make sure they allow them before you
travel.
WHAT ALTERNATE METHODS OF SHIPPING YOUR CO2
CYLINDERS DO YOU HAVE?
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Preferred - Ship your CO2 cylinders via an air package company to your sailing
destination. They normally accept these devices, though you
must declare them as a Hazardous Material/Dangerous Good. Then
when done sailing, return your CO2 cylinders via the air package
company to your home.
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Leave your CO2 cylinders at home, check ahead that local
chandleries at your sailing destination carry your type of CO2
cartridge, buy replacements at your sailing destination, then
dispose of them before returning home, then re-install your original
CO2 cylinders at home.
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If you attempt to carry the CO2 cylinders with you on a commercial
aircraft, either
as carry on, or checked baggage, without declaring
the hazardous material, be prepared to face federal charges.
Carrying Inflatable Personal
Flotation Devices (PFD) with you on Commercial Aircraft can be a
distressing event. It is best that you plan in advance before going to
the airport.
WHAT IS THE PROBLEM?
The charged carbon dioxide (CO2) cartridge on the inflatable is a
Hazardous Material as defined by the United States Department of
Transportation (USDOT) Hazardous Material Regulation (49CFR175)
and also a Dangerous Good as defined by the International Air
Transportation Association (IATA). These same rules apply whether you
take your inflatable as carry-on or check it through. The
Regulation requires that you declare the hazardous material prior to
boarding the aircraft. There is a 49CFR175.10,
Exception 25 in the USDOT Regulation that allows the carriage
of a charged inflatable PFD (one PFD per passenger and one spare
cartridge), but leaves the final decision to the Individual Air Carriers
whether or not to accept them on the airplanes they own. IATA has
almost identical wording. If the airline forbids the
carriage, do not take the CO2 cylinders with. If the airline
accepts the carriage, follow the airlines rules.
WHAT ALTERNATE
METHODS OF SHIPPING YOUR CO2 CYLINDERS
DO YOU HAVE?
If you get rejected at the gate even with this
documentation, some people have turned their PFD's
into the lost baggage counter at baggage claim, and upon return to
their home airport, picked up their PFD.
In the spring of 2006, we contacted the top 10 air
carriers in the U.S. to learn what their policy was concerning the
carriage of CO2 cylinders. 6 of them clearly had their policy on
their websites accepting them on their aircraft. 1 policy was
unclear, we called them and learned that their policy is that if the FAA
says it is ok, it is ok with them. We said that the policy was
unclear to their clients, and it would be helpful if they state their
policy clearly. They said they wouldn't do that, and would prefer
that we do not advise sailors to call their management to get a clear
reading on their policy. 1 clearly wrote on their website that
they were not allowed, and our request that they change their policy was
not effective. 2 made it clear that they did not allow them on
their airplanes. We requested that both change their policies, 1
elected to change, the other elected to maintain their policy to keep
the CO2 cylinders off of their airplanes. Approximately 7 hours of
volunteer time went into this research. We explain the
previous paragraph to show that the airlines policies are fluid, that
maintaining a list of those who accept and those who won't is
futile. Imagine how much time it would take to cover all domestic,
international, national, and regional air carriers to not only learn
what their policy is, but to spend time with those that don't and
convince them that they could make more money by serving the
sailors!
LET US KNOW YOUR EXPERIENCE
If you have comments or experiences with this matter, please send them
to us (we share these stories with the U.S. Coast Guard to promote their
involvement in asking the USDOT to change their Regulations):
HOW CAN A PERMANENT SOLUTION BE MADE TO THIS
PROBLEM?
Pretend for one moment that the
wording in the USDOT (domestic) Regulations and the IATA
(international) Regulations strengthens the wording that makes it
permissible for airlines to accept these devices on board.
The outcome is that the individual
airlines will always have the final decision to accept or deny
hazardous materials on board their planes. Why? Think
of the plane that carried the hazardous material called
"oxygen generators" (hazardous material/dangerous good) in their cargo hold, that caught
fire and crashed in the Florida Everglades. All air carriers
have the decision to accept the permitted hazardous materials, or
not, which is a risk decision for their management alone.
After a long involved process of changing the regulations, the result will remain the same, the air
carriers will always get to decide if the hazardous material will or will not board their
planes.
WHAT WOULD IT TAKE TO CHANGE THE CURRENT WORDING, EVEN THOUGH THE
BOTTOM LINE WOULD REMAIN THE SAME AS TODAY?
| STEPS
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| 1. |
Write the United States Department of Transportation describing
the loss of personal safety and possibly financial loss, by the
USDOT and air carriers current policies. This effort may
change the Regulation for domestic air carriers only.
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| 2. |
To change
the Regulation for international air carriers, the first step
is to have the USDOT carry the issue to the United Nations'
"Subcommittee of Experts on the Transport of Dangerous
Goods". What
countries vote?
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| 3. |
The U.N.
only makes a recommendation and forwards it to the International
Civil Aviation Organization (ICAO) who then debates the
merit of a changed policy for international air carriers.
What countries vote?
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| 4. |
The International
Air Transportation Association (IATA), an airline trade
association, takes ICAO's regulations, prints them in a tabbed
and illustrated booklet and distributes them to all international air carriers.
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5. |
If USDOT
did not revise their Regulation in step one, they will revise their
regulation at this point, incorporating
ICAO language.
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| 6. |
Air
carriers still will have the ability to deny the carriage of
hazardous materials.
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NOTES |
| A cylinder manufacturer reports that the
cylinders, used in other applications, are filled with gases
such as Oxygen or Propane. It is their recommendation
that CO2 cylinders not be allowed in carry-on baggage,
because training security personnel at airports to know and
identify the differences would not be cost effective. Accidentally
or intentionally having Oxygen or Propane (both?) in the
passenger compartment is too dangerous. |
| ISAF's International Regulations Committee
reports that all European air carriers refuse CO2 cylinders either as
check-through or carry-on baggage (9/17/01). |
| The United States Department of
Transportation explains that the cylinders have a potential
for rocketing if the pressure is released in an uncontrolled
manner. They may also have the potential of throwing fragments if they rupture in a
situation such as a fire injuring crew, passengers and rescue
personnel. An inflatable PFD may also cause damage if inadvertently activated in
a confined space (overhead bin), or harm a baggage handler
(causing luggage to shift around). The fact that they may be required on an
aircraft installed on the PFD's found under each seat under FAA airworthiness regulations
(which requires inspection by the FAA in order to have them on
board), does not mean
that they should be considered as not hazardous when carried
as cargo or passenger baggage (where your cylinders are not
inspected by the FAA inspectors). The USDOT cannot require
an air carrier to allow hazardous materials on board as
baggage or cargo, they can only allow a few hazardous
materials to be permissible to carry at each airlines risk
tolerance level. |
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