Air carrier flight crew reported that a Hazmat documentation error revealed that different departments interpret the Hazmat document procedures differently; which resulted in two identical NOTAC's signed by different personnel.

Date: 2023-08 · Aircraft: Commercial Fixed Wing · Phase: ground

Anomalies: deviation-discrepancy-procedural-far|deviation-discrepancy-procedural-hazardous-material-violation|deviation-discrepancy-procedural-published-material-policy|no-specific-anomaly-occurred-unwanted-situation

Synopsis

Air carrier flight crew reported that a Hazmat documentation error revealed that different departments interpret the Hazmat document procedures differently; which resulted in two identical NOTAC's signed by different personnel.

Narrative

Prior to arriving at aircraft Release 2 was created and displayed on Application; etc.; with remark to the effect that REL-2 due to HAZMAT on board so I knew already that a NOTAC would be a part of the preflight paperwork package. Arriving at the gate approximately 40 minutes prior to push there was a Customer Service Agent (CSA); but no Operations Agents present. Operations Agent(s) arrived just before -30 with one in Company uniform and one in civilian clothes doing apparent training. Trainee seemed to be doing Operations Agent duties with oversight. No paperwork for flight was prepared or available beyond Release on our iPad via Application. Crew boarded; briefed; and began preflight without paperwork but referencing Application Release" for necessary information. A person in civilian clothes entered the flight deck with a big hello and 6 pieces of HAZMAT paperwork including four NOTACs (two sets of the duplicate copies). First Officer (FO) and I were told we had two batteries onboard properly boxed; loaded; etc. After figuring out that this person was possibly a Contract Ground Agent; or possibly some sort of Supervisor; I began to look at the HAZMAT paperwork. This individual heard that we had NO actual flight paperwork and left to go get that at the top of the jetway. I began to look at the six documents and determined that there were two different HAZMAT documents I had never seen and two sets of NOTACs listing two entries (one entry for each battery on each of the four pieces of NOTAC paperwork). It appeared we had double NOTAC sets. Same WAYBILL numbers; same exact entries for items; weights; descriptions; loading position; etc. The ONLY difference was one set had one individual with proper NAME; SIGNATURE; and EMPLOYEE NUMBER filled into the lower left block and the other set had a DIFFERENT NAME; SIGNATURE; and EMPLOYEE NUMBER filled into the lower left block. Each NOTAC was exactly the same EXCEPT the entry for WHO signed "I have inspected this shipment and certify that it has not been damaged and is not leaking." Effectively I had double paperwork with differing signatures OR correct paperwork IF separate individual people handled the batteries separately but both batteries were on each set of paperwork. In one way it could appear that I had four batteries onboard and another way it could appear I had paperwork where one of the two could not be correct. I gave the two other HAZMAT documents to the individual who brought them; and she commented "Oh yes; those aren't for you." I explained the problem and asked if there was any good explanation; she said she would call her Supervisor and return. I called our Dispatch Desk; and we began to discuss. He phone-patched to Safety and we explained and discussed. Safety ultimately said essentially "Ramp has their procedures and if they are good to go; we can be too; even with duplicate paperwork.' The Ramp Supervisor was now present as well in the flight deck and he said two different people must have loaded one battery each so they both had a NOTAC to sign and have me carry to ZZZ1. Dispatcher then transferred us over to Ground Operations (at the Company Operations Center?) and we explained/discussed. Ground Operations Agent said that having two sets of two was NOT correct and that somewhere on the ZZZ Contractor/ramp-side; something was likely in error. We ultimately came to the conclusion that Ground Operations would contact ZZZ to discuss and that we would sign and carry both sets (4 total) and we would carry one each to ZZZ1 and leave one each at the ZZZ Station. Dispatch ACARS'd ZZZ1 Operations en route and I called ZZZ1 Operations when in range. A ZZZ1 Ramp Supervisor met us at the gate; and I explained all and ensured him that there were ONLY 2 batteries onboard for them to get.Event Summary: confusion with non-standard NOTAC(s) delayed departureSuggest: Clarification with either ZZZ Ops or further explanation of NOTAC info (of which we seem to have plentyof already.) Seemed like a simple resolution but with differing opinions reasons etc.; from Safety; Ground Ops and Station the Dispatcher. We found ourselves in a situation where neither of us had been in before AND it was difficult to discern who had the final say on what was "correct"."

Second reporter narrative

Shortly after releasing this flight; ZZZ Operations called to get the HAZMAT Onboard Refer to NOTAC" note added to a new Release. I sent the new Release with this note. Prior to push; the Captain called with a question regarding his NOTAC and airway bill. He had two sets of airway bills that were identical and had identical information/numbers as well as two sets of NOTACs that were all identical except for the signature and employee number of the 'Loading Agent'. The Captain was unsure if he should sign both NOTACs; since that may mean he was signing for four batteries instead of the two that were onboard. We first talked to (Person A) in Safety and Security who said we could sign both sets of NOTACs and leave the Station copies and carry both NOTACs onboard; as long as the airway bill reflected what was actually loaded and the NOTAC loading information was correct and the Weight & Balance were correct all showing 2 batteries at 220 pounds total. I also wanted to follow up with the Company Operations Center Maintenance Controller to ensure this would be ok; prior to leaving. I connected the Captain and Maintenance Controller Person A. The Maintenance Controller said the same and said this could be an issue because this was a Contract Station that does not do many HAZMAT shipments and that one Agent might be the Freight Agent and one may have been the actual Ramp Loading Agent and that ZZZ Ground Operations may have been being overly cautious by having both groups filling out the paperwork. Again; we were told; as long as we knew for sure the pieces and weight were correct; we'd be ok to sign both sets of the documentation. I heard the Captain verify once again in the background of the phone with the Ramp Agents that there were in fact only two batteries onboard. With the confirmation from both Ground Operations; local Ramp; and Safety and Security; the Captain and I were comfortable following their guidance and signing both sets of paperwork."

Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.