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
