Presentation by Northwest Air Company
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North West Company – Presentation
Transportation of Dangerous Goods- Air
Good Morning – My name is Doug Moore and I am the Director of Transportation for The North West Company.
The North West Company is a leading retailer and distributor of everyday consumer goods and services to remote communities, rural towns and urban neighborhoods.
The key issues that The North West Company deals with regarding the Transportation of Dangerous Goods are:
- Internal combustion engines – the majority of our customers are First Nations and Inuit and depend on the natural resources in their area to feed and clothe themselves and to provide fuel for warmth. This means that items such as ATV's, snowmobiles, outboard motors, ice augers and chain saws are a necessity of life and deemed to be very important to maintaining a culture and a way of life. Many air carriers charge “extra” for handling Dangerous Goods, this extra charge only serves to increase the cost of these necessity items. This Dangerous Goods fee is levied by the carrier to offset the administration and manpower cost associated with handling Dangerous Goods. In some cases these items are delayed in shipping while the air carrier ensures that “ALL” the documentation has been completed correctly and to scrutinize the shipment itself to ensure that everything is in order. In these cases where the goods are NEW we do not see what purpose the Dangerous Goods Regulations serves or who it benefits.
- Consumer Commodities – as a retailer we provide a wide assortment of goods into some of Canada's most remote communities and as such air transportation is a very important part of our supply chain. The current Dangerous Goods Regulations make the transportation of some everyday products very time consuming and expensive especially when one considers that these same commodities are readily accessible with a minimal amount of challenge in the “South” – a few examples would be – flints, hair spray, air freshener, aerosol whipped topping, oven cleaner, paint, WD40, turpentine, glue etc. As mentioned earlier the Dangerous Goods Fee can add considerable cost to these everyday items – a Dangerous Goods fee of $55.00 on a shipment can add $4.60 to the value of a can of air freshener. It should also be noted that due to the size of the communities we serve the shipments of Dangerous Goods tend to be very small. Another example due to the remote nature of many of the communities we serve and the long flight times it is necessary to pack ice cream in insulated boxes with dry ice to ensure it arrives in saleable condition – due to the packaging required and the Dangerous Goods Regulations – the regulations in effect make ice cream Dangerous Goods.
- Technicalities of the regulations – it seems that the air carriers are well informed in regard the regulations and are very concerned about Transport Canada's inspection of their documentation and acceptance of Dangerous Goods Shipments. This concern it seems is due to the perceived zealous nature of some of the Transport Canada inspectors and the potential for fines. Therefore the air carriers tend to scrutinize most shipments and a simple spelling error or typographical error can result in the delay a shipment for a considerable length of time – due to the process required to replace the required documentation. We do not believe this to be the intent of the regulations, but it is a reality.
It seems that the intent of the regulations was to ensure air carriers were aware of what they were carrying and in what quantity to hopefully avoid potentially dangerous situations – which is understandable if you are dealing with 747's and other larger aircraft, where the whole operation of assembling loads, loading aircraft and unloading aircraft tends to have a larger number of people involved and a potentially large variety of commodities and shippers – that go unseen by many of the people involved in the loading and operation of the aircraft. We feel that the remote communities and air carriers that operate into the remote communities should be recognized as having special requirements. Many of the aircraft that serve the remote communities are relatively small that is Cessna Caravans, Hawker Siddley 748s, ATR42s, DC 3s, DC4s, Single Otters, C46s and Twin Otters. In most of these cases the assembling of a load, the loading of the aircraft and the unloading of the aircraft is a very hands on operation – the carriers and their employees are very aware of the commodities when it comes to cargo into remote locations and in our estimation well informed as to the goods they are carrying – that is goods you would find in your local store.
It is our feeling that the regulations need to be reviewed and that the review takes into consideration the uniqueness of the north and its unique requirements.
The North West Company
Doug L. Moore
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