Commercial and Business Aviation Advisory Circulars

Storage, Labelling, Handling and Application of De-Icing/ Anti-Icing Fluids

PURPOSE

This Commercial and Business Aviation Advisory Circular (CBAAC) is intended to remind air operators and pilots of their responsibilities with respect to the proper and safe storage, labelling, handling and application of de-icing / anti-icing fluids.

REFERENCES

• Canada Labour Code, Part II, section 124
• Canada Labour Code, Part II, paragraphs 125(1)(q), (s) and (z13)
• Canada Labour Code, Part II, section 125.1
• Canada Labour Code, Part II, paragraphs 126(1)(a), (b), (c), (d),
  (g) and (h)
• Aviation Occupational Safety and Health Regulations, Part V,
  Hazardous Substances
• Transport Canada, Ground Icing Operations Update (TP14052E)

BACKGROUND

The Canada Labour Code (CLC), Part II, is the legislation which ensures that the health and safety of all employees, who are under federal jurisdiction while at work, is protected. The Aviation Occupational Safety and Health (A-OS&H) Regulations, Part V, identifies the prescribed standards that must be adhered to with respect to Hazardous Substances, which includes the de-icing / anti-icing fluids used in conjunction with ground icing operations.

ISSUE

At airports where de-icing / anti-icing is not available from a service provider, the de-icing / anti icing may have to be completed by the pilot. Under these circumstances, pilots either have to carry the required de icing / anti-icing fluid on board their aircraft, or purchase it on-site, so they can apply it to the aircraft themselves before take-off.

When the above situation occurs, it is both the operator’s and pilot’s responsibility to make sure the de-icing / anti icing fluid is properly and safely stored, labelled, handled and applied.

CONCLUSION

Operators and pilots involved in de-icing / anti-icing operations similar to those described in this CBAAC are to familiarize themselves with the above CLC Part II and A-OS&H Regulations references, with particular emphasis placed on those sections dealing specifically with hazardous substances. In addition, the above referenced TP14052E (Transport Canada, Ground Icing Operations Update) should also be reviewed for recent developments and issues pertaining to aircraft ground icing operations.

The prescribed standards referenced in the CLC Part II, are found in Part V of the A OH&S Regulations, and cover everything from the labelling of hazardous substance storage containers (section 5.28), to the requirement that operators must have Material Safety Data Sheets (MSDS) on board their aircraft, for all hazardous substances an employee may handle or be exposed to (section 5.27), which includes de-icing / anti icing fluids.

Paragraph 125.(1)(z13) of the CLC addresses the operator’s responsibility to develop, implement and monitor a program for the provision of personal protective equipment, clothing, devices or materials. The program referred to in this paragraph should include health and safety information for pilots that are handling and applying de-icing / anti icing fluid to aircraft. A primary source of information for inclusion in this program would be the MSDS, which cover a wide range of topics including such things as the type of protective gloves and eyewear that should be worn when handling or applying these fluids.

Operators are also reminded of their requirement to develop and implement an employee education program respecting hazard prevention and control on aircraft, as detailed in section 5.12 of the A OS&H Regulations. The instructions and procedures included in this employee education program must be coordinated with the Work Place Health and Safety Committee, or Health and Safety Representative, to ensure that Workplace Hazardous Materials Information System (WHIMS) training is provided to all employees who work with or near hazardous substances.

For additional information on WHIMS training or anything else contained in this CBAAC, contact your regional Civil Aviation Safety Inspector – Occupational Health and Safety at the following website address: http://www.tc.gc.ca/CivilAviation/commerce/ohs/reach_us/regions.htm.

The Canada Labour Code, Part II, and Aviation Occupational Safety and Health Regulations can be viewed in their entirety at the following website: http://www.tc.gc.ca/CivilAviation/commerce/ohs/.

Michel Gaudreau
Director
Commercial & Business Aviation