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:
1. 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.
2. 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.
3. 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.
Thank you.
The North West Company
Doug L. Moore
Director, Transportation