Commercial and Business Aviation Advisory Circular (CBAAC) No. 0184


No. 0184


Stowage and Packaging of Survival Equipment and Emergency Flares


This Commercial and Business Aviation Advisory Circular (CBAAC) informs air operators of the potential hazards associated with the stowage of survival equipment, emergency flares and any life saving appliance in flammable packaging or containers.


  • Transportation Safety Board (TSB) Aviation Investigation Report A99W0061 and Safety Recommendation A00-13.
  • Paragraphs 2.3(i)(iii) and 2.9(2)(b) of the Transportation of Dangerous Goods Regulations (TDGRs).
  • International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TIs).


On April 28, 1999, an Aerospatiale AS 355 F1 Twinstar Helicopter sustained an in-flight fire which resulted in the complete destruction of the aircraft.

The ensuing investigation determined that an improper connection of battery cables initiated the fire and that material used to stow survival equipment and emergency pyrotechnic flares contributed to the rapid propagation of the fire.

The survival and emergency equipment included a five-person survival shelter and a survival kit that contained six emergency flares.

The shelter was packaged in a waxed cardboard box and was housed, along with the survival kit, in flammable nylon bags. Within the survival kit, the emergency flares were packaged in newspaper or rolled in cardboard.

The burning characteristics of the nylon bags did not meet the requirements of any existing flame-resistant textile specifications.

The in-flight fire occurred when the battery cable arced through the battery compartment forward bulkhead and ignited the flammable nylon survival equipment bags in the adjacent baggage compartment. This caused the flares carried in the survival kit to ignite and discharge during the fire.

The TDGRs govern the transport of dangerous goods by all modes of transport in Canada. The Regulations state in part that they do not apply to the transport of dangerous goods which are necessary for the safety of persons if the goods are firmly secured, protected from external damage or form an integral part of the means of transport.

However, it should be noted that dangerous goods in 'Life-saving appliances', transported as air cargo, are subject to the Regulations and must be properly documented, labeled and packaged in accordance with the ICAO TIs.

Notwithstanding the above stipulations, any condition that unnecessarily increases the potential for the ignition or propagation of a fire on board an aircraft is hazardous, putting passengers and crew at risk.


Transport Canada recommends that air operators ensure 'Life-saving appliances' such as survival equipment are stored in compliance with Packing Instruction 905 of the ICAO TIs when required to be carried on board the aircraft in accordance with pertinent airworthiness requirements or operating regulations.

Confirmation of the use of non-flammable packaging and stowage containers for survival and pyrotechnic emergency equipment is essential for air operators carrying such equipment. Where necessary, modification or a change of containers and packaging material may be required to comply with the ICAO TIs and TDGRs.


A Notice of Proposed Amendment reflecting the recommendations contained in this CBAAC will be drafted for presentation to the Canadian Aviation Regulation Advisory Council (CARAC).


Transport Canada recommends that air operators consider the contents of this CBAAC when determining stowage and packaging procedures for all survival equipment carried on board aircraft.


M.R. Preuss
Commercial & Business Aviation

Commercial & Business Aviation Advisory Circulars (CBAAC) are intended to provide information and guidance regarding operational matters. A CBAAC may describe an acceptable, but not the only, means of demonstrating compliance with existing regulations. CBAACs in and of themselves do not change, create any additional, authorize changes in, or permit deviations from regulatory requirements.