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July 30, 1996

Captain Larry Farris
Chairman IFALPA Dangerous Goods Committee
International Federation of AirLine Pilots' Associations
Interpilot House, Gogmore Lane
Chertsey, Surrey
KT16 9AP England

Dear Captain Farris:

We are writing in response to your letter of July 11, concerning the International Atomic Energy Agency's new revision of guidelines for the transport of radioactive materials ("Safety Series 6"). The IAEA Board of Governors is expected to vote on a recommendation to adopt the new guidelines at its September meeting.

Given IFALPA's commitment to "improving the levels of safety in aviation," as your letter states, I am sure you will agree that the new guidelines should not be approved until all outstanding safety issues are resolved. Especially in the wake of the recent ValuJet and TWA crashes, the proper order of business is surely to resolve the safety issues before adopting the guidelines.

Nonetheless, the IAEA's Board of Governors is expected to approve the guidelines in September, and then there is to be an IAEA meeting in October to review the outstanding technical safety issues. It is clear the IAEA is placing the cart before the horse by seeking immediate adoption of Safety Series 6 before outstanding safety issues are resolved. These unresolved issues are central to the question of whether it is safe to transport radioactive materials by air under the revised guidelines.

We urge IFALPA and the other international aviation organizations publicly to oppose adoption of the amended guidelines at this time and to communicate their opposition promptly to the IAEA Board of Governors.

IFALPA's objections to the revised guidelines are a part of the review record of SAGSTRAM (now TRANSAC), which shows that IFALPA has consistently urged that containers for air-transport of radioactive material be crash-resistant. IFALPA has been critical of the impact speed specified by the IAEA's impact test as unrealistically low and not representative of actual aircraft accident conditions.

IFALPA's position on this critical point is supported by an analysis presented to an ICAO Dangerous Goods Panel working group in 1995. The ICAO analysis found that the IAEA specifications for a crash-resistant cask compared unfavorably with international standards for the "black box" flight and data recorders. The analysis found that the input energy per unit mass associated with the IAEA impact test (that is, the measure of the mechanical insult delivered to a test package) was only 43% of the input energy associated with the flight recorder specification. The flight recorder specification corresponds to an impact speed of 138 meters/second (309 mph).

The revised IAEA guidelines call for a Type C air-transport container that can withstand an impact of only 90 meters/second (201 mph) into an unyielding surface. The U.S. domestic standard is 129 meters/second (289 mph), which corresponds to the international flight-recorder specification. For overflights of U.S. territory, an even more stringent impact speed of 282 meters/second (631 mph) is required. In October 1992, when an El Al cargo plane crashed into an apartment complex near Amsterdam, the impact speed was estimated to be 150 meters/second (335 mph).

It has been argued that the revised guidelines would represent an incremental improvement over current transport safety standards and therefore merit adoption. We reject the notion of "safer" air shipments of radioactive material in casks that cannot withstand a high-velocity crash. If radioactive material is to be flown, it must be flown safely, in casks certified as crashworthy---or it should not be flown at all. The public should not be expected to assume the involuntary risk of radioactive contamination as a consequence of uncrashworthy containers. The El Al, ValuJet and TWA tragedies are vivid reminders that the risk of a catastrophic crash is not zero and that they do occur from time to time.

Given these facts, we urge IFALPA not to acquiesce in the IAEA's determination to adopt this new regulation, even on an interim basis, since such acquiescence will serve to legitimate air transport of plutonium in casks that could not withstand a high velocity crash. To make matters worse, the IAEA proposes to allow an exemption from the new Type C cask for MOX fuel on the premise that it is low-dispersible material---a position that we have shown (in our technical note to IAEA Director General Hans Blix) is without merit and without supporting evidence.

It would be regrettable if IFALPA, in the interest of collegiality with another international organization, were to acquiesce in a safety rule that it knows to be inadequate.

Given the immediacy of the pending approval of the new air-shipment standard in early September, we would appreciate a prompt response to this letter.


Paul Leventhal

Dr. Edwin Lyman
Scientific Director

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