IATA Agents Association of India (IAAI) has requested the Ministry of Civil Aviation (MoCA) and the Directorate General of Civil Aviation (DGCA) to take immediate measures to publicize the new rules and regulations for carriage of "Alcohol-based Hand Sanitizer" on board of the aircraft. IAAI further requested MoCA and DGCA to issue appropriate directives to respective airlines and ground handling companies for complying with Regulatory requirements to avoid procedural lapses as it will affect the safety and security of passengers and aircraft, especially at this restarting of domestic flights operation after a lockdown period over 50 days.
Welcoming the decisions of the Govt for opening the domestic flight operations, Biji Eapen, President, IAAI and also one among the Chief Instructor for DGR in India, requested MoCA and DGCA to instruct all Aviation stakeholders in India to take adequate measures with utmost care while handling Coronavirus Covid-19 Specimens which are Infectious Substances ( Class 6.2 of Dangerous Goods Regulations) permitted for transportation under UN3373-Biological substances-Category B and COVID -19 patient Cultures for Laboratory Research & Treatment Diagnosing (UN2814-Category A).
1) ICAO and IATA presently allow Passengers and Airline Crew to carry "Alcohol-based liquid sanitizer" up to 100 ml only in carry-on baggage or in person under the provision of DGR 184.108.40.206 Whereas, Bureau of Civil Aviation Security – Govt. of India, through an addendum dated 13th, May 2020, allows Passengers to carry Alcohol-based liquid Hand Sanitizers up to 350 ml in their carry-on baggage or person, for travel from and within India.
2) Sanitizers contain ethanol (UN 1170) or isopropyl alcohol (UN 1219) are flammable or combustible liquid which can be easily ignited in the air at ambient temperatures and classified under DGR Class-3, Flammable Liquid, wherein, chemical combination and percentage of volume determine the vulnerability of the product.
3) Since ICAO & IATA allows Airlines to add Alcohol-based Hand Sanitizer into the Operators Property as per DGR 2.5, ICAO Technical Instructions Part 1:2.2, upon approval from the Regulator. If any airline had opted this, concerned ground handling staff should be intimated accordingly.
4) The flashpoint of a flammable liquid may be altered by the presence of an impurity. The recent media reports point out that, several manufacturers and vendors in India are selling Hand Sanitizers containing Ethanol or Isopropyl Alcohol as a basic ingredient due to regulatory uncertainties.
5) Inclusion of alcohol-based liquid sanitizer under Medicinal or Toiletry articles (DGR 220.127.116.11) in the list of Goods acceptable without the Operators approval, has been omitted in the Guidelines issued on 21st May 2020 for Air Passenger's and hence both the Passengers and concerned Airport Employees are unaware of this additional eligibility.
As per the Regulatory procedures, any significant changes, or amendments in dangerous goods regulations, the employer is responsible (Airlines & Ground Handling Companies) to mandatorily update and train their staff according to the job responsibilities.
The Guidelines and SOP’s issued on 21st May 2020 have omitted to mention about the rules and regulations regarding carriage of "Alcohol-based Hand Sanitizer" on board, and hence both Passengers and concerned Airport Employees are unaware of the new entitlement approved by ICAO and IATA which allow Passengers and Airline Crew to carry "Alcohol-based Hand Sanitizer" up to 100 ml in carry-on baggage or in person along with their medicinal or toiletry articles. Whereas, Bureau of Civil Aviation Security – Govt. of India allows 350 ml. In this context IAAI requested MoCA & DGCA to take immediate measures to publicize the new rules and regulations for carriage of "Alcohol-based Hand Sanitizer" on board of the Aircraft.