Review of the IAEA/IMO/ICAO Database Radioactive Material shipment denials in the Air mode
By Capt. Andrew Tisdall (rtd) April 2011
Distribution List
(tbd)
Background
The problem of radioactive shipment denial has existed since commercial movement of RAM began, however in the last decade with the rapid growth in the use of radiopharmaceuticals the issue has become much more acute. The IAEA’s general conference of 2003 called for an action plan which in turn led to a discussion forum between the IAEA, IMO, ICAO, IFALPA, WCO, shippers and national regulators which met in London 2004. Amongst the many action plan items was a call to set up a communication channel to resolve specific instances of denials and set up a database of supplementary rules for international RAM transport. Although the secretariat at the time was compiling lists of airlines, ports, routes and shippers that were posing problems the response at this stage to most denials was still somewhat ad hoc.
In 2006 TRANSSC recommended that the IAEA convene a Steering Committee to assist the IAEA in determining effective actions. A limited number of concerned organizations and countries would be invited to participate. In 2007 this committee resolved that one database with one reporting form would be developed by UN agencies in cooperation for the purpose of:-
• Recording denials
• Identifying underlying issues or patterns
• Noting solutions and successes
• Identifying responsible persons
• Setting target dates for dealing with issues
Furthermore the IMO resolved to compile and analyse the reports received to establish a classification system to allow effective database development.
General Comments
This report is a first attempt to analyse the data presented in Air mode database.
The data comprises of 51 reports of incidents occurring between 18 February 2007 and 22 January 2011.
The geographic area covered is relatively small and represents only 8% of global revenue. It is somewhat atypical in terms of transport infrastructure, but the reports do highlight many issues which could arise globally.
Review of the IAEA/IMO/ICAO Database Radioactive Material shipment denials in the Air mode
General Comments
Only three reports involved the complete denial of carriage of the shipment.
The rest of the reports involved delays ranging from 30 mins to 48 hours.
The delays below an hour may seem insignificant given the area’s well known weather problems, but deliveries of Fluorodeoxyglucose (FDG) with a half life of only 2 hours were seriously affected. Scheduled airline transport is probably not a viable delivery method for such short half lived substances.
The longer delays also significantly impacted Molybdenum 99 and Iodine 131 shipments with half lives of 3 and 8 days respectively. This was mainly due to supply chain issues rather than loss of function i.e. planned procedures were just delayed.
Some shipments of Iodine 123 with a half life of 13 hours suffered 24 hour delays.
Several shipments were offloaded due to weight restrictions. This is probably because time critical cargo is usually loaded last to facilitate a rapid offload upon arrival.
Take off weight calculations usually only take place within an hour of departure and can change radically with evolving weather conditions.
A few shipments were delayed by a computer dispatch system producing incorrect airwaybills and labels which were picked up later by acceptance personnel at the airport.
Incorrectly applied or non visible hazard labels caused some delays.
Shipments were delayed by up to 24 hours when misdirected by the airline or when inadvertently combined with a similar package with different destination.
Five of the reports offered no reason or even duration for the delay so were considered incomplete.
Three reports were duplicates with the same airwaybill number and city pair.
I could not detect any underlying causal trends or pattern behind the denials or delays. This may be due to sparsity of the data and its lack of geographic extent.
There were some notable successes in the face of adversity summed up well by a paraphrased comment: “Direct contact with the Airline’s Dangerous Goods Manager may significantly facilitate some shipments”
Review of the IAEA/IMO/ICAO Database Radioactive Material shipment denials in the Air mode
Action Items
Many of the actions required to avoid a repetition of a denial have already occurred locally, as documented in the comments area at the bottom of the report form. This localised problem solving should be encouraged and facilitated by the agency. The publication and dissemination of multilingual explanatory leaflets would help combat denials at a local level.
Most airlines, even the large carriers, are still unaware of the time critical nature of radiopharmaceuticals. This will be an ongoing problem as turnover of frontline cargo acceptance staff remains high and the training in the area of Class 7 is still considered complex and costly. The agency’s efforts to train the trainers must continue as one of its highest priority tasks.
Company variations which affect RAM transport appear to be on the increase. Rather than trying to prevent them, it may be easier to approach these airlines and ask them alter their variation to allow shipment of medical use RAM. Viz: Company variation MK-01.
The data input form itself is quite detailed and contains a lot of sensitive commercial information; perhaps a shorter de-identified version would generate more responses. Denial reports are almost by definition adversarial, so the report maker must be assured that there will be no consequences to him from any individual report. It may be worthwhile to study whistle-blowers charters to incorporate some of their assurances.
Given that there were only 3 outright denials in the 3 years of data collection it is difficult to see if this particular method of identifying “bottlenecks” is working. The access to the database could be improved if there were links to it on IAEA, IATA and ICAO websites. More data should be urgently sought, because as it stands the database is too small to make meaningful recommendations.
Summary of Action Items
¶ Multilingual explanatory leaflets would help combat denials at a local level.
¶ The agency’s efforts to train the trainers must continue as one of its highest priority tasks.
¶ Approach airlines with variations and ask them to allow shipment of medical use RAM.
¶ More data should be urgently sought.
3