Lithium batteries are clearly the bêtes-noires de nos jours. Geoff Leach’s extensive report in last month’s issue (see page 63) summarised the results of the October 2015 meeting of the International Civil Aviation Organisation (ICAO) Dangerous Goods Panel (DGP) but, since then, discussions on the subject of the transport of lithium batteries by air have moved on apace.
One direction those discussions were to take was highlighted by a ‘stop press’ panel in that story, where we reported that ICAO’s Air Navigation Commission, at the request of a number of states, had agreed that there should be a complete ban on the transport of lithium ion batteries as cargo on passenger aircraft. DGP had debated that same proposal but had resisted it, largely on the basis of practicality, and had come up with a compromise solution involving “state of charge” – i.e. requiring that such batteries are shipped at a charge of 30 per cent or less – at least until a permanent solution could be found to make their carriage safer.
It is worth looking at Gene Sanders’ comments on that decision in his View from the Porch Swing on page 6 of this issue, where he makes it clear that there is no direct method of verifying the state of charge and that, therefore, such a requirement is unenforceable in practice.
The ICAO Governing Council was evidently of a like mind and, at its meeting last month, agreed with the Air Navigation Commission that a ban on the carriage of UN 3480 lithium ion batteries is currently justified. It agreed that the ban should be imposed as from 1 April 2016 as an interim measure until such time as a new lithium battery packaging performance standard can be developed. Work on this is expected to continue until 2018.
Speaking after the decision, Dr Olumuyiwa Benard Aliu, ICAO Council President, said: “Safety is always our most fundamental priority in international civil aviation.” ICAO notes that a prohibition on the transport of lithium ion batteries as cargo on passenger aircraft has been eagerly awaited by aircraft manufacturer and pilots’ associations, which have been the most vocal advocates for the new safety measure.
To be clear, the ban does not apply to lithium ion batteries packed with or contained in equipment, and only to those shipped under Packing Instruction 965.
Prior to that decision, the air regulators had been drawn into action on the carriage of battery-powered vehicles, an issue that had been highlighted by 2015’s Christmas present of the year, the hoverboard. A number of voices had raised concerns that these items were being shipped with batteries of dubious quality and represented an urgent hazard in air transport.
In December 2015 the International Air Transport Association (IATA) issued updated guidance on the carriage of “small vehicles” powered by lithium batteries in passenger and crew baggage. The new guidance responded to reports that articles such as hoverboards, mini-Segways, airwheels and solowheels are increasingly being sold at airports, particularly in Asia.
IATA noted that ICAO’s DGP had determined that such articles are not “mobility aids” but should be regarded as “portable electronic equipment”. It also reminded operators that if the lithium ion battery used to power such equipment exceeds 160 Wh then the device is forbidden for carriage in either carry-on or checked baggage.
ICAO addressed the same issue in January, saying that a number of air carriers had banned them because of safety concerns. ICAO said that states are “encouraged” to recommend to operators that passengers should be allowed to bring such devices into the cabin as carry-on luggage, while highlighting the 100 Wh and 160 Wh limits.
Also in January, ICAO issued a third addendum to the 2015-2016 edition of the Technical Instructions. The addendum introduces those new provisions adopted by DGP at its October 2015 meeting that were deemed too safety-critical to hold back until the next edition, and are applicable immediately.
The changes include the assignment of special provision A210 (forbidden for carriage by air) against catecholborane and 1,3,2-benzodioxaborole, further changes to the restrictions on the carriage of lithium batteries, and a clarification on lithium batteries in overpacks.
IATA issued a similar addendum, which included some new and revised carrier and state variations.
In related news, the US National Transportation Safety Board last month issued two recommendations to the US Pipeline and Hazardous Materials Safety Administration (PHMSA) on cargo segregation and loading density requirements for air cargo operations. The recommendations stem from NTSB’s part in the investigation of the in-flight fire aboard Asiana Airlines Flight 991 and its crash into the sea west of Jeju International Airport, South Korea in July 2011.
NTSB is asking PHMSA to put in place rules to ensure the physical separation of lithium batteries from other flammable hazardous materials stowed on cargo aircraft and to establish maximum loading density requirements that restrict the quantities of lithium batteries and flammable hazardous materials.
“NTSB urges PHMSA to take action on these safety recommendations to reduce the likelihood and severity of potential cargo fires and to provide additional time for the crew to safely land a cargo aircraft in the event a fire is detected,” says Christopher A Hart, NTSB chairman.
NTSB is aware that PHMSA will not generally put in place rules that are more restrictive than international regulations; however, Congress has given PHMSA authority to do so if it finds credible evidence of a deficiency in the international regulations that has substantially contributed to the start or spread of an on-board fire.
The NTSB strongly believes the circumstances and findings in the Asiana Flight 991 accident show the need for new cargo segregation and loading density requirements.
Meanwhile, the US Occupational Safety and Health Administration (OSHA) has issued a letter of interpretation regarding the status of non-consumer lithium batteries as regards the Hazard Communication Standard, HazComm 2012. OSHA categorically states that lithium batteries not used in consumer applications are not articles within the meaning of the 2012 standard.
Articles are excluded from the scope of HazComm so the interpretation means that a manufacturer or importer of lithium ion batteries or products which contain lithium ion batteries that are not consumer products must develop and make available safety data sheets. This interpretation could open the way for other “similarly configured” items that contain some type of hazardous material that could conceivably spill to be regarded as not being articles and therefore in scope of HazComm requirements.[post_title] => Plugged in [post_excerpt] =>
Keeping up with the changes to the lithium battery regulations is becoming a full-time job. ICAO and IATA have been at it again
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