EMB-505 flight crew reported they transported prohibited Hazmat cargo. Reportedly; misinterpretation of their manuals contributed to the incident.
Synopsis
EMB-505 flight crew reported they transported prohibited Hazmat cargo. Reportedly; misinterpretation of their manuals contributed to the incident.
Narrative
Our assigned trip was to transport one passenger from ZZZ to ZZZ1 under part 91K. While waiting for the passenger; FBO at ZZZ advised that the passenger's acquaintance was the owner of their own Cirrus Vision Jet stationed at ZZZ. The acquaintance had requested their line service go into his hanger and retrieve a small aviation life raft with associated life jackets to be transported with the passenger on the trip to ZZZ1 in preparation for a future trip in their own [aircraft]. FBO's line service delivered the raft and jackets to our aircraft before the passenger arrived.Initially we thought of the potential HAZMAT issue that having the raft aboard our aircraft might create. We looked in the company HAZMAT manual for some guidance but did not find any specific prohibition regarding a life raft. We did find listed in the Appendix X of the HAZMAT manual an exception for the self inflating life jackets being among the items that are permitted so we had no concerns about the jackets. We placed a call into the Chief Pilot on duty to clarify or confirm that the life raft would or would not be permitted; but the Chief Pilot was busy with other demands and did not respond to us before departure time.We made the decision to carry the raft as requested based on the logic that -It was approved for use in the owner's aircraft (the Cirrus Vision Jet) and it was very similar to; and much smaller than the rafts we carry aboard the Phenom for the same purpose. Appendix X of the HAZMAT manual allows certain exceptions of other devices that use or contain compressed gas of various kinds and we figured this raft is no different in that respect. Lastly; the company HAZMAT manual it is mentioned that the exceptions listed in Appendix D of the HAZMAT manual is not all encompassing and the company reserves the right to modify the list within the limits of the hazardous materials regulations. I assumed that had we successfully contacted the Chief Pilot that the end result would be the approval to carry the raft based on the above reasoning. That section is quoted here.DG/HM Exceptions - Certain materials which are normally regulated as dangerous goods are excepted from the HMR (Hazardous Material Regulations). They are set forth in Appendix X; DG/HM Exceptions of this manual and 49 CFR 175.10. Appendix X does not cover all DG/HM Exceptions as listed in the HMR. While the listing in Appendix X covers exceptions that the Company typically may encounter; the Company reserves the right to use any exceptions allowed in the HMR.'After the flight was completed the Chief Pilot did contact me and clarified that the raft should not have been transported due to the cylinder of compressed gas used to inflate the boat. This event was caused by the unexpected request to carry a life raft; and our incorrect interpretation of the HAZMAT manual details. Obviously we pilots could use a more thorough understanding of HAZMAT exceptions and the associated details regarding transporting items items that are very similar to typical and approved aircraft equipment. This event to us seemed like a very reasonable; logical; and acceptable action. Of course we know now that our assumption was incorrect."
Second reporter narrative
Flight crew departed with items of HAZMAT that belonged in owner's private aircraft. Specifically; 4 life jackets and one small 4-person raft. Upon arrival at destination crew retrieved and unloaded life rafts about the same time a voice mail was received informing us the items are prohibited. While waiting for owner's spouse; FBO line crew approached the aircraft and told crew that the owner who owns his own plane had forgotten the life raft and life jackets that belonged in his aircraft; and requested crew carry them on board to deliver at destination where plane was parked. Crew checked the FOM and the HAZMAT manual and did not see where they were explicitly prohibited. Crew called and relayed the situation to Chief Pilot who offered to call back with information. In the meantime the items were strapped in the cabin to the aft seat. Passenger arrived late and crew did revisit the HAZMAT discussion and did not call Chief Pilot back to further press for an answer.Crew took an unnecessary risk by not confirming whether the items were HAZMAT or not. A few extra minutes of greater persistence reaching someone with an answer would probably not have caused the perceived delays to subsequent revenue flights. Just because something is not specifically prohibited does not mean it's therefore permitted. Anything that appears to be HAZMAT probably is and requires a quality effort to receive further approval from the company. Slow down; take a delay if necessary to mitigate the risk of serious injury to personnel; passengers; or the aircraft.
Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.