Dangerous Goods

New lithium battery packaging standards and development of a broad dangerous goods reporting system are among the proposals expected to be considered by the International Civil Aviation Organization’s (ICAO’s) Dangerous Goods Panel (DGP) at its scheduled meeting in October in Montreal.1 The DGP also is expected to receive a formal paper from the International Coordinating Council of Aerospace Industries Associations (ICCAIA) and the International Federation of Air Line Pilots’ Associations (IFALPA) recommending that high-density packages of lithium-ion batteries and cells not be transported as cargo on passenger aircraft until safer methods of transport are established and followed. Shipping lithium-metal batteries as cargo on passenger aircraft already has been banned.

The DGP meets periodically to discuss proposed revisions to the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Doc 9284 and its supplement, Doc 9284SU), and also in the event of emergencies relating to the shipment of dangerous goods by air, according to information available on the ICAO website <icao.int>. The DGP takes input from its working groups, deliberates on those inputs in formal panel sessions, and then passes its recommendations to the ICAO Air Navigation Commission for consideration.

There are two primary types of lithium batteries or cells: lithium-metal and lithium-ion. Lithium-metal batteries are single-use (non-rechargeable) and are found in items like watches and pacemakers. Lithium-ion batteries are rechargeable and are used to power consumer electronics, such as laptop computers and mobile phones. Technical and guidance materials also sometimes reference lithium-ion-polymer batteries, which also are rechargeable and found in consumer electronics such as computer tablets and smartphones. They differ from lithium-ion batteries only in their geometry and outer case material.² Lithium-ion and lithium-ion-polymer batteries often are simply referred to as lithium-ion.

The carriage of lithium batteries as cargo in passenger and cargo aircraft is an area of significant concern because of the growth in demand for consumer and industrial products powered by lithium batteries, which in turn is driving increases in the size and frequency of lithium battery air cargo shipments.³ It is estimated that 1 billion lithium batteries per year are transported by air as mail or cargo, or in passenger or crew baggage.⁴

Lithium battery shipments are suspected — but have not been proved — to have been the source of fire in three major commercial aircraft accidents: UPS Flight 1307, a McDonnell Douglas DC-8-71 freighter that was destroyed by fire after landing at Philadelphia on Feb. 7, 2006; UPS Flight 6, a Boeing 747-400 freighter that crashed trying to return to Dubai after a fire broke out on board on Sept 3, 2010, near Dubai; and Asiana Airlines Flight 991, a 747-400 freighter that crashed into international waters on July 28, 2011, while attempting to divert to Jeju International Airport in Korea after fire broke out during a flight from Incheon to Shanghai. In addition, the U.S. Federal Aviation Administration’s (FAA’s) list of air and airport incidents involving batteries carried as cargo or baggage is growing steadily. As of June 30, 2015, the list, which FAA cautions is not a complete list of all such events and which excludes the three major commercial aircraft accidents, contained 158 incidents that have occurred since March 20, 1991. Of the 158 incidents, 82 involved some form of lithium batteries, and the vast majority of the 82 have occurred since 2001.⁵

During the second ICAO International Multidisciplinary Lithium Battery Transport Coordination Meeting in September 2014 in Cologne, Germany, the group developed a problem statement that read: “A fire involving significant quantities of lithium batteries may exceed the fire-suppression capability of the aircraft and could lead to catastrophic failure of the airplane.”⁶

This language was echoed in an electronic bulletin distributed by ICAO in December 2014 outlining an amendment to the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air prohibiting the carriage of lithium-metal batteries as cargo on passenger aircraft except when an exemption is granted in instances of extreme urgency. “The decision to forbid the transport of lithium-metal batteries as cargo on passenger aircraft was based on the knowledge that lithium batteries which are mishandled, damaged, defective, [or] improperly packaged, designed or manufactured are capable of overheating and igniting and that fully compliant lithium-metal batteries can also ignite from the heat of a suppressed fire which had not involved lithium-metal batteries. Current packaging requirements cannot contain a lithium-metal fire, and Halon, the fire-­suppressant agent commonly used in cargo compartments equipped with smoke- or fire-detection systems and built-in fire-suppression systems, is ineffective at controlling a lithium-metal fire. A fire involving large quantities of lithium batteries could therefore lead to a catastrophic failure of the airframe.”⁷

A number of mitigation recommendations came out of the Cologne meeting in September and were discussed at the DGP Working Group Meeting (DGP-WG/15) in Montreal on April 27–May 1, during which the Multidisciplinary Meeting’s problem statement was affirmed. During the working group meeting, concerns were raised by ICCAIA and IFALPA about cargo compartment fire protection in relation to the carriage of high-density packages of lithium batteries as cargo. ICCAIA recommended, with IFALPA endorsement, that appropriate packaging and shipping requirements be established to more safely ship lithium-ion batteries as cargo on passenger aircraft; that high-density packages of lithium-ion batteries and cells not be transported as cargo on passenger aircraft until safer methods of transport are established and implemented; and that appropriate packaging and shipping requirements be established to more safely ship lithium-metal and lithium-ion batteries as cargo on freighters.⁸ In a separate working paper, IFALPA recommended extending to cargo aircraft the proposed restriction on the transportation of high-density packages of lithium-ion batteries.

Following a discussion of the merits of the ICCAIA and IFALPA proposals, the DGP decided to form a working group to develop a performance-based packaging standard, but did not take action related to the shipment of high-density packages. “The working group fully supported the need to develop performance-based standards based on the principle that hazardous effects from the batteries would be contained within the package.”⁹

According to the terms of reference developed for the new working group, called the DGP Working Group on Performance-Based Standards for the Safe Transport of Lithium Batteries, the main objectives are to consider performance-based standards to address three specific recommendations that came out of the Multidisciplinary Meeting: that a performance-based provision be developed that would limit the probability of propagation of thermal runaway between cells to an acceptable risk level; that all lithium-ion cells for shipment be limited to a state of charge of no more than 30 percent as an interim means to reduce the probability of propagation of thermal runaway between cells; and that further research and testing be completed as soon as possible on packaging for lithium batteries — packaging that may include the use of cooling agents, such as gel packs, as a means to provide additional protective layers to mitigate the risks associated with the carriage of lithium batteries. The other main objectives are to define the scope and application of the standard, to review the effects of the specified performance and the ability of aircraft systems and equipment to mitigate the resultant effects, and to submit the findings to the DGP.¹⁰

Shortly after the DGP meeting adjourned, IFALPA released a statement praising the DGP “for committing to develop packaging standards for lithium battery shipments on aircraft in order to protect the aircraft and all on board from the effect of a lithium battery fire. Recognizing that packaging is an important piece in a multi-layered approach to the safe transport of lithium batteries, IFALPA will continue to work with all stakeholders to ensure the packaging standard is fully developed and implemented. We continue to support the recommendation that high-­density shipments of lithium-ion batteries not be carried until these standards are in place.”

A few days later, PRBA–The Rechargeable Battery Association said that it is ready to work with the panel on new performance-based standards. “PRBA welcomes the opportunity to play a role in this regulatory initiative that will have far-reaching implications on the lithium battery industry and thousands of entities involved in the shipping, handling and transportation of lithium batteries,” PRBA Executive Director George Kercher said in a press release. In information presented during the DGP meeting, PRBA outlined technical concerns its members had raised in relation to the Multidisciplinary Meeting’s recommendation to limit the state of charge for lithium-ion batteries in shipment to 30 percent. Similar concerns were outlined at a DGP meeting in 2014, at which a PRBA representative suggested a cell leaving a factory at a 30 percent state of charge could be faced with an over-discharge condition if it were exposed to elevated temperatures for an extended period of time. Also, cells and batteries typically are shipped multiple times, which means they could be shipped safely by air, put in storage at elevated temperatures, which may result in over-discharge conditions, and then transported by air again.¹¹

On July 17, Boeing issued a multi-operator message (MOM-MOM-15-0469-01B) to its airline customers, providing guidance on the carriage of lithium-ion batteries in passenger aircraft cargo holds. “We have been working with the ICCAIA and agree with them that operators of passenger airplanes should not carry those batteries in the cargo hold until safer methods of packaging and transport are established and implemented. We formally relayed that message to the airlines,” a Boeing spokesman said in an e-mail to AeroSafety World. An IFALPA Dangerous Goods Briefing Leaflet dated Aug. 7, 2015, with a link on the ICCAIA website <iccaia.org>, said that Boeing “agrees with the ICCAIA recommendation that appropriate packaging be developed and shipping regulations established to more safely ship lithium-metal and lithium-ion batteries as cargo on freighter airplanes. Boeing recommended that operators choosing to carry lithium-ion batteries as cargo, either on passenger or cargo-only airplanes, conduct a safety assessment.”

Incident/Accident Reporting

Also on the agenda for the DGP meeting in Montreal are continuing discussions on the development of a global framework for the sharing of dangerous goods incident and accident information. At the 38th ICAO Assembly in 2013, Brazil, on behalf of the Latin American Safety Oversight Cooperation System (SRVSOP)¹² and with support from the Latin American Civil Aviation Commission (LACAC),¹³ presented a paper asking the assembly to call on ICAO to develop a global dangerous goods reporting system tool.

“The growth of the transport of dangerous goods by air combined with the constant development of technology makes it necessary to create new tools that work in favour of safety,” reads the working paper.¹⁴ “A centralized global reporting system would enable fast and reliable occurrence reporting and data sharing among states and between them and ICAO, and would also allow those states that do not have adequate resources to develop local reporting tools to have equal access to this critical safety information and the same reporting capability as any other state. Eventually, this proactive prevention method will allow for earlier hazard identification and risk management.”¹⁵

According to the report from the DGP Working Group meeting in April, the subject of dangerous goods reporting and the sharing of dangerous goods incident and accident information had been discussed at several DGP meetings, but little progress had been made. “The creation of a DGP working group on reporting was therefore proposed. There was a strong support for the creation of such a group, recognizing that attempts to progress the work through correspondence had proven to be difficult.”¹⁶

“The general goal of the working group will be to develop a framework for a global reporting system and to develop guidance material for states to use in developing their own dangerous goods reporting systems,” says Anthony Philbin, chief of communications at ICAO. The group’s working paper will be presented to the DGP at its October meeting, he said.

Reportable dangerous goods-related occurrences include accidents and incidents.

The Technical Instructions for the Safe Transport of Dangerous Goods by Air and its supplement define dangerous goods accidents as occurrences “associated with and related to the transport of dangerous goods by air which result in fatal or serious injury to a person or major property or environmental damage.” The technical instructions further define dangerous goods incidents as occurrences, other than dangerous goods accidents, “associated with and related to the transport of dangerous goods by air, not necessarily occurring on board an aircraft, which results in injury to a person, property or environmental damage; fire; breakage; spillage; leakage of fluid or radiation; or other evidence that the integrity of the packaging has not been maintained. Any occurrence relating to the transport of dangerous goods which seriously jeopardizes the aircraft or its occupants is also deemed to constitute a dangerous goods incident.”

Operators are required to report dangerous goods accidents and incidents, as well as any occasion when undeclared or incorrectly declared dangerous goods are discovered in cargo, to the authorities of their states and to those of the states where accidents or incidents occur. Operators must also report any occasion when prohibited dangerous goods are discovered in passengers’ baggage.¹⁷

In addition to establishing and following procedures for investigating dangerous goods accidents and incidents, states in which a dangerous goods accident occurs are required to forward a notification of the accident with a minimum of delay and by the most suitable and quickest means available to the involved aircraft state of origin, to the aircraft state of registry and to the state of the operator.¹⁸

Proponents of the global dangerous goods reporting system maintain that other occurrences that should be reported include those caused by noncompliance in loading, segregation, separation or accommodation, or the absence of necessary information about dangerous goods to the pilot-in-command.¹⁹

The implementation of dangerous goods reporting and sharing tools is inconsistent among ICAO member states. “Some of the ICAO member states have well developed systems for reporting dangerous goods accidents and incidents, and thus are able to provide and exchange information on such occurrences in an agile and efficient manner, a fact that brings a great benefit for the safe transport of dangerous goods in their territory.”²⁰

Also, most ICAO member states “do not have such an effective reporting system, nor are they able to benefit from other states’ safety lessons due to a lack of a common and standardized system for sharing information. This gap hinders the prevention of reoccurrence of certain safety events that could be avoidable through data-based proactive measures.”²¹

According to Stephanie Meyer, a dangerous goods consultant and trainer, the focus of the development of a global dangerous goods reporting system should be the intention to share valuable information in a rational way. With regard to confidentiality issues, she says that “it has to be strictly taken into account, that no person, no organization, state or company is blamed by a report. In this way, we will increase safety and give others the chance to benefit and learn from own experiences and to identify potential gaps and hazards as early as possible.”

“The focus in reporting a dangerous goods incident should be to provide as much detail as possible as to the circumstances around the incident, including identification of potential causal factors. A detailed, clear and comprehensive incident report will assist the airline or regulatory authority to be able to identify cause, and, where possible, to then develop and implement mitigating actions to prevent recurrence,” says Dave Brennan, assistant director, cargo safety and standards, for the International Air Transport Association (IATA).

“If you use it in a professional way, a global reporting system could be a big step toward the development of a successful safety system. Every opportunity and possibility to learn from each other and to exchange safety information in the aviation industry is a big chance to eliminate potential hazards. I think that this kind of dangerous goods reporting system is a very good way to identify hazards, to take measures and as well to increase awareness,” says Meyer.

Notes

1. The agenda is available online at the ICAO website..
2. FAA William J. Hughes Technical Center, Aviation Research Division. Extinguishment of Lithium-Ion and Lithium-Metal Battery Fires. January 2014.
3. Noe, Darrin. “Safe Transport of Lithium Batteries as Cargo.” Aero Issue 52 (Q4 2013): 13–19.
4.  IATA. Lithium Batteries Risk Mitigation Guidance for Operators, Effective 1 January–31 December 2015. Montreal, Canada, 2014.
5. The list is available at on the FAA website.
6. ICAO. “International Multidisciplinary Lithium Battery Transport Coordination Meeting, Report of the Second Meeting.” Cologne, Germany. Sept. 9-11, 2014.
7. ICAO. “Amendment to the Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284) Relating to the Transport of Lithium Metal Batteries on Passenger Aircraft.” Dec. 10, 2014.
8. ICAO. “Dangerous Goods Panel (DGP) Working Group Meeting (DGP-WG/15), Report of the Meeting.” DGP–WG/15–WP/38. Montreal, Canada. April 27–May 1, 2015.
9. Ibid.
10. ICAO. “Appendix D, Terms of Reference, Dangerous Goods Panel (DGP) Working Group on Performance Based Standards for the Safe Air Transport of Lithium Batteries.” (DGP–WG/15–WP/38). Montreal, Canada. April 27–May 1, 2015.
11. ICAO. “Dangerous Goods Panel (DGP) Meeting of the Working Group of the Whole, Report of the Meeting of the Working Group of the Whole.” DGP–WG/14–WP/32. Rio de Janeiro. Oct. 20–24, 2014.
12. The member states of the SRVSOP are: Argentina, Bolivia, Brazil, Chile, Colombia, Cuba, Ecuador, Panama, Paraguay, Peru, Uruguay and Venezuela.
13. LACAC member states are: Argentina, Aruba, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Cuba, Ecuador, El Salvador, Guatemala, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Dominican Republic, Uruguay and Venezuela.
14. ICAO. Assembly, 38th Session, Technical Commission. Agenda Item 29: Aviation Safety — Monitoring and Analysis. Dangerous Goods Reporting System, A38-WP/147, TE/56 22/8/2013.
15. Ibid.
16. ICAO. “Dangerous Goods Panel (DGP) Working Group Meeting (DGP-WG/15), Report of the Meeting.” DGP–WG/15–WP/38. Montreal, Canada. April 27–May 1, 2015.
17. ICAO. Technical Instructions for the Safe Transport of Dangerous Goods by Air, Doc 9284, 2013-2014 Edition.
18. ICAO. Supplement to the Technical Instructions for the Safe Transport of Dangerous Goods by Air, Doc 9284SU, 2013-2014 Edition.
19.  ICAO Assembly. 38th Session Technical Commission.
20. ICAO. “Dangerous Goods Panel (DGP) Working Group Meeting (DGP–WG/15), The Creation of a Working Group on Reporting of Occurrences (WP/37).” Montreal, Canada. April 27–May 1.
21. Ibid.

Featured image: © Janaka Dharmasena | iStockphoto
Batteries: © Eugenp | Dreamstime.com
Burned laptop: U.S. National Transportation Safety Board
Banned cargo icon: U.S. Federal Aviation Administration