Flight Crew Air Transport Pilot (ATP)
Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural Hazardous Material Violation
Company Policy
After 20 years of flying it has come to my attention that we carry Dangerous Goods (DG) on board that is not declared or known to the flight crew! Maybe I'm just slow to learn; but this seems to be a surprise to me and a lot of other crew members! During the DG inspection we learned of Lithium Metal batteries being carried on board in position 4R as part of the known shipper exemption UN 3090 Section II Label but not declared on DG paperwork. For starters; the DG agent we had was kind enough to inform the First Officer (FO) during the DG inspection that we had lithium batteries onboard that were not on the DG manifest because it was part of the UN 3090 Seciton II known shipper exemption. The FO mentioned this to me as I was handed the DG paperwork to sign that it had been inspected and met our requirements. Even as IDG there are loading requirements we need to be aware of! To my knowledge; I had never heard of DG that could be carried onboard without being declared on the manifest; so I further queried the DG agent. He tried to explain it to me; but I couldn't find any reference in the FOM or in the DG Job Aid that referenced us being allowed to carry DG that was not declared. There are inferences made in the DG Aid when you read the section labels (UN 3090 Section II) that say 'DO NOT PUP AS DG' and 'This package MUST be inspected by the origin location Dangerous Goods Specialist' and 'FORBIDDEN IN PASSENGER AIRCRAFT' and 'PRIMARY LITHIUM BATTERIES -- FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT.'After finding no reference in our materials (FOM; PHB; etc); I called the Duty Officer (DO) to see if he could clarify the situation. As far as I could tell; we needed to either have the Li declared on the DG Manifest or unloaded. Unfortunately; the DO was unable to make a determination because the DG Job Aid and FOM didn't have any further clarification and there was no one in the DG department at work at that time of the day.After more querying; more research; and more phone calls; finally the ramp DG Manager came out with copies of their manual to clarify the situation. Basically; the photocopies and clarification she gave said that we have known shippers that ship DG under the known shipper program in approved containers which are inspected at the origin ramp that do not have to be declared on the DG manifest (because they aren't 'PUP'd into the system!)Her explanation was sufficient to convince me (us) that the shipment of undeclared Li Metal was legal; but that certainly didn't make it safe; hence this report! I really appreciate the fact that the original DG agent made the FO aware of the non-manifested Li batteries; and I really appreciate the manager coming out to explain the situation; but it is unsatisfactory from a safety perspective. I definitely don't want the DG agent to be in trouble for letting us know; because we need to know. In fact; I wish MORE agents would make us aware of the situation. This system however is BROKEN and UNSAFE. Ultimately we took a 35 minute delay for clarification of the situation; which could have been avoided by having a better notification system and declaring them on the DG form!WOW. It's shocking that we can carry DG that the flight crew doesn't know about; and further more CFR wouldn't know about in the event of an emergency! If there's a fire on board; it is imperative to know where all the DGs are loaded and what types! If I'm halfway across the ocean and my closest airport is 1000 miles away; type of DG and location goes into my decision making process of ditching the aircraft!I'm sure this has been going on for a long time; and I'm sure it's convenient for the company and for the shippers; but it is definitely NOT in the interest of safety when it comes to the flight crew and potentially CFR in the event of an emergency! It begs the question to wonder how long it has been going on and how much/how often this happens. As flight crew this is very; very scary; and the lack of known information certainly does not contribute to good CRM/decision making in the event of an emergency!Unsafe [company] policy it to blame to this unsafe situation! I'm not sure who benefits from this the most - [company] because of less paperwork of the shipper because of less paperwork (or is it less shipping cost?); but all I know is the flight crew (and possibly CFR) is at risk because of DG being carried aboard in positions we are unaware of! Information is knowledge and in this case lack of knowledge can lead to bad decision making.CHANGE THE POLICY! Obviously this falls under IATA; but I'm sure [company] can be more restrictive; like we seem to do with a lot of FOM policies! Whether a shipper is using UN 3090 II exemption or not; the DG ought to be listed somewhere and the flight crew needs to know where and in what quantities! And in particular for Lithium Batteries!!! This particular exemption can't even be carried on passenger airplanes and yet we as flight crew don't need to know about it?!?!?! We carry a lot of DG and it makes a lot of money for [company]; and that's great. But it needs to be carried SAFELY and the crew needs to know where and in what quantities.
Captain reported that Lithium Metal batteries can be carried onboard the aircraft under IATA shipper exemption UN 3090 Section II but not declared on the Dangerous Goods paperwork. The reporter recommended a change in policy.