An old hand in the air cargo business, Radharamanan Panicker, has seen it all, done it all. One of the country’s well-known air freight specialists, he managed Cargo Service Center India (CSC) for around 20 years. In his time, the company grew from a single station set-up into a multi-airline handling company with stations in Mumbai, Chennai and Delhi. The company also got the contract for construction and management of the Perishable Cargo Terminal in Mumbai and the Second Integrated Cargo Terminal in Delhi. In 2014, Panicker decided to go out on his own and formed his own company: Dangerous Goods Management (DGM) India. DGM India is a fully recognized dangerous goods training entity in the Indian air cargo market and Panicker is possibly one of the few experts in dangerous goods in the country. No wonder, it is difficult to pin him down – at least 15-20 days in a month, Panicker is somewhere in the country training people in how to handle Dangerous Goods.

Danger Zone & No Panic Panicker

     ACNFT met Panicker to find out how the pandemic had treated the Dangerous Goods business. “Dangerous goods movement by air is very limited. This is also because many do not carry dangerous goods for the fear that the shipper is not competently doing the job of making the transport of dangerous goods safe. They fear the proper declaration of the DG cargo in terms of their proper shipping and classification including packing group (this indicates degree of danger). So, the cost of transporting DG goes up much higher as compared to general cargo, whereas there is no extra or special service provided by the airlines.”
     Panicker said that the lack of sufficiently and efficiently trained staff was missing from the airline and their GHS. “To make matters worse, airlines have different standards on acceptance of DG by the airlines—often at variation with what is stated in the regulation. X Airlines accepting DG at Mumbai and Ahmedabad or Delhi, will have different methods or procedure for acceptance of DG cargo.
     “Finally, the big challenge is the way DG packages are examined in India.”

     Dangerous Goods handling then was a business, necessitating know how and strict controls. From packaging and labelling to compliance and infrastructure, the smallest of errors can result in the biggest of catastrophes. Panicker agreed: “The fundamental idea behind safe transportation of dangerous good, whether by air, ocean or other surface mode, is that the Regulation is strictly followed. This involves correct identification of the substance by their proper shipping name and UN number, proper hazard classification of the substance, packing them in accordance with the requirement given in the regulation, communicating the hazard contained in the package through marking and labelling of packages on one hand and placarding of tanks and containers, trucks and rail wagon on the other hand and finally documenting these substances. In essence all these are the responsibility of the shipper.”
     The critical area in understanding is the classification and identification of the dangerous goods. While some substances are known because they are already identified by the UN Committee of Expert, the nodal body of experts, there are many others (derivatives, solutions or mixtures) which needs to be classified first before arriving at their identification by UN number and proper shipping name. This is a critical function, which is often neglected.
     “Obviously, it all means that everyone involved in the transportation of such goods must be thoroughly trained in the regulation. The level of training depends on the function the person is carrying out or likely to carry out,” said Panicker.
     Another important aspect is packaging. Appropriate packaging here means that every package that is to be used for packing and transporting dangerous goods must be made using the material and quality in accordance with the requirements given in the regulations. Once that is done, these packages need to be tested and certified for use in packing dangerous goods substances or article. And therein lies the biggest challenge. The trade cuts corners to save a few rupees here and there, but that means risking not only the supply chain but also the life of people.
     For safety, then, could technology help? The DG expert commented “the role of technology has not yet been fully explored or used. However, there are information systems available and being used for processing of dangerous goods documentation and communicating electronically with the logistics participants such as shipping lines and airlines. But it is not actively implemented.”
     Another area where technology could be used, especially internet of things, is in the manufacturing of packages for shipping dangerous goods and its testing by certified and authorized labs.
     Some time ago, a leading air cargo DG expert described the threat to air cargo from unidentified and unlabelled hazardous materials in shipments resulting from online auction sales and retail sites. He described that as “the Wild West of Dangerous Goods”. Despite outreach from bodies like IATA, there have been breaches. With fines being small, change has been slow in coming. Panicker said that the “biggest danger or risk to an airline is from what we call hidden dangerous goods or undeclared dangerous. Many exporters are generally traders and they don’t understand the technicalities of the chemical or such product which may be inherently dangerous. They fail to recognize them. Sometimes there are some unscrupulous freight forwarders, who also advise their customers incorrectly and motivate them to take chances.”
     He pointed out: “What is also not known is that India has a Regulation called Aircraft (Carriage of Dangerous Goods) Rules 2003, which besides enabling the implementation of ICAO Technical Instruction for Safe Transport of Dangerous Goods in India, lays down the requirement for shippers and others to follow, including the need for training.” Whether the aviation sector has enough enforcement resources or not is something that the Directorate General of Civil Aviation (DGCA) has to evaluate. “But, yes there is a need for surveillance audit of all entity involved in the transport of DG by air in order to bring a certain discipline.”
     He said that the fines for violation of the dangerous goods regulation were not small as far as air transport was concerned. Last year, for example, the Government of India increased the fine from INR100 million to INR1000 million and also possibly imprisonment extending up to two years, under Section10 of the Aircraft Act 1934.
     “The question that needs answering is how many have been penalized for violating the Regulation?” Panicker asked.
Tirthankar Ghosh