FlyingTypers Logo
#INTHEAIREVERYWHERE
FlyingTypers Ad
   Vol. 14  No. 53
Monday June 29, 2015

ICAO DGP Advances Lithium Question

ICAO DGP Advances Lithium Question

The Working Group of the ICAO Dangerous Goods Panel (DGP), which convened in Montreal, Canada, earlier this year, bears some closer examination, as the agenda included working papers and recommendations due for implementation into the 2017-2018 version of ICAOs “Technical Instructions for the Safe Transport of Dangerous Goods by Air.”
     When implemented, this document will be the internationally binding legal basis for the air transport of dangerous goods.


Risks of Lithium

     The heart of the action is a working paper submitted by the International Coordination Council for Aerospace Industry Association (ICCAIA), endorsed and supported by the International Federation of Air Line Pilots Associations (IFALPA) addressing the risks of transporting lithium ion batteries as cargo.
Both ICCAIA and IFALPA feel that the transport of Lithium batteries, at least in large quantities, cannot be undertaken by aircraft in a safe manner, at least not with todays technology with respect to aircraft fire fighting capabilities and current packaging technologies utilized for lithium batteries.
     ICCAIA and IFALPA base their suggestions on the tests undertaken by the FAA’s William J. Hughes Test Center in 2013 and consolidated in their much-discussed January 2014 report.
     The revelations of the tests undertaken by the FAA were such that aircraft manufacturers and pilots alike were represented through their associations’ commodities.


Their Own Words

     The ICAO DGP report states that “it was noted that the intent of Section II was to allow for the average person to ship very small quantities of lithium batteries without being subject to full regulation, but that the unforeseen consequence was that some shippers had been taking advantage of the Section II provisions to facilitate the shipment of such items in bulk.”
     ICCAIA reiterated “the fire protection capabilities and certification of original equipment manufacturers’ (OEMs) airframes and systems were developed considering the carriage of general cargo and not the unique hazards associated with the carriage of dangerous goods, including lithium batteries. Test data was cited which identified that existing cargo compartment fire protection systems certified to European and American regulations were unable to suppress or extinguish a fire involving significant quantities of lithium batteries, resulting in reduced time for safe flight and landing of an aircraft to a diversion airport.”
     Based on the safety risk model provided in the ICAO Safety Management Manual (SMM) (Doc 9859), ICCAIA and IFALPA “determine that immediate action to mitigate the unacceptable risks posed by lithium batteries was necessary.”
     On this basis, their joint recommendation as brought forward by the working paper presented to the ICAO DGP was:
          a)   That appropriate packaging and shipping requirements be established to more safely ship lithium ion batteries as cargo on passenger aircraft;
          b)   That high density packages of lithium ion batteries and cells (UN 3480) not be transported as cargo on passenger aircraft until such time as safer methods of transport were established and followed; and
          c)   That appropriate packaging and shipping requirements be established to more safely ship lithium metal and lithium ion batteries as cargo on freighter aircraft.
     Furthermore, a separate paper presented by IFALPA recommended extending the restrictions proposed for the carriage of “high density packages” of Lithium–Ion batteries to all-cargo aircraft. It was stated “while lithium ion batteries were carried as cargo on both passenger and cargo aircraft, the majority of large shipments were transported on cargo aircraft. This, combined with the fact that cargo aircraft were not required to be outfitted with cargo compartments having an active fire suppression system makes the risk to cargo aircraft even greater than to passenger aircraft.”
     IFALPA also recommended that since the principles in the Safety Management Manual do not distinguish between passenger and cargo aircraft, the current prohibition on UN 3090—Lithium metal batteries from transport on passenger aircraft—be extended to all-cargo aircraft.


What’s Next

     Because of the serious ramifications for the battery industry, the manufacturers, and distributors of electronic and electrical devices as well as the consumers, the proposals brought forward by ICCAIA and IFALPA were as controversial as discussions can be at such a stage.
     The validity of the paper’s findings was challenged, although the contributors pointed out that the likelihood of a cargo fire involving lithium batteries was classified “occasional” not solely on a lithium battery causing a fire; it was based on the potential for a lithium battery to be involved in a fire.
     Another point made against the paper was that “a ban on lithium batteries would have the unintended consequence of more undeclared shipments of lithium batteries and therefore result in an increased risk.” After some disagreement was expressed “with the notion that a large number of people or organizations would break the law and continue to ship batteries if they were banned;” such disagreement based on “data from their States indicating that the percentage of deliberate noncompliance was low,” the Secretary had to resort to a rather unusual measure to remind the working group of the need for data, emphasizing that “the Air Navigation Commission (ANC) and the (ICAO) Council had become increasingly concerned when arguments were made without data to substantiate them.”
     The working group was unified in their opinion that undeclared and misdeclared batteries were a considerable risk, but divided in their opinion about the risks associated with the carriage of compliant batteries and cells.
     One part of the working group supported a call for immediate action, saying that allowing unrestricted quantities of even compliant lithium batteries in cargo compartments while knowing that a fire could exceed the capabilities of the fire protection system is an unacceptable risk. It was emphasized that the goal was not to ban the transport of lithium batteries altogether on a permanent basis, but rather to find a way to transport them safely.
     Although the working group as a whole disagreed on the level of risk posed by fully-compliant shipments of lithium batteries, the problem statement developed by the Multidisciplinary Meeting affirming that a fire involving significant quantities of lithium batteries (UN 3090 and UN 3480) could exceed the fire suppression capability of the aircraft and could lead to a catastrophic failure of the air frame was accepted in an uniform manner.
     When the working group was asked by the Secretary to indicate whether they supported or rejected the paper put forward by ICCAIA and IFALPA, a considerable number expressed general agreement but noted that they were unable to support it on the basis that it had not been identified as a formal proposal in accordance with standard DGP procedures, and that subsequently there had been insufficient time to conduct the necessary consultation with relevant experts within their States.
     Those who opposed the paper reiterated the argument that a prohibition would only increase the number of undeclared shipments and centered on the absence of a clear definition for the term “high density packages,” although the IFALPA/ICCAIA representatives repeated that “it was impossible to determine a quantitative limit for high density that would apply to every situation because of the number of variables involved, exacerbated by the fact that there was no way to control the number of packages of Section II batteries loaded on the aircraft.”
     IFALPA and ICCAIA thus announced that will come forward with a formal proposal meeting DGP standard procedures for the 25th meeting of the ICAO DGP, which will take place in Autumn 2015, while a working group tasked with performance-based packaging standards for the safe transport of lithium batteries by air will develop suitable standards to mitigate the risks associated with transported Lithium batteries of the various types, involving the participation of the ICAO FLTOPSP (Flight Operations Panel) and AIRP (Airworthiness Panel).
     A paper brought forward by PRBA proposing exempting small lithium metal button when installed in “life-saving medical devices” was rejected.
Jens

If You Missed Any Of The Previous 3 Issues Of FlyingTypers
Access complete issue by clicking on issue icon or
Access specific articles by clicking on article title


Vol. 14 No. 50
Up Close & Personal With Prince Edwards
Avec Moi à Paris
SV June To Delhi
Chuckles For June 18, 2015
ULDs Get No Respect
Export Seko Logistics No Limit

FT062315
Vol. 14 No. 51
Bhat Atop SWISS WorldCargo
June Is Bustin' Out For Finnair Cargo
Chuckles For June 23, 2015
Jerry Trimboli-Slugger Without Bat
A Little Travelin' Music