Containing a hazard

Additional rules for air transport of lithium battery shipments landing soon.    Four years ago last September, UPS pilots flying from Dubai International Airport to Germany crashed their plane less than an hour into the flight. A fire had started in back of the plane among containers loaded with goods and the crew was overwhelmed by smoke that seeped into the cockpit. 
   In September 2013, an investigation by the United Arab Emirates pinpointed the culprit: a plane full of lithium 
batteries. The highly flammable batteries caught fire, and that fire spread throughout the plane. These batteries have also been implicated in the inflight cargo fire of an Asiana Boeing 747 in July 2011 and a cargo fire aboard a UPS DC-8 freighter in 2006.
   In the ensuing years, the Federal Aviation Administration had already issued a safety alert regarding the transportation of lithium batteries and restricted the carriage of battery cargoes over a certain weight. In January, a full ban on the shipment of lithium batteries in the belly of passenger planes will take effect.  
   As part of its investigations into the fires, U.S. regulators and those overseas recommended the installation of fire-suppression components and fire-detection systems, implementing in-flight cargo fire checklists for crews, and develop new standards for fire-resistant containers. The recommendations also include hindering the ability for smoke to penetrate into a plane’s cockpit, increasing the fire protection on systems that are critical in the landing of planes, and educating crews on cargo fires.
   Since the crash, agencies worldwide have been looking at the air transport of lithium batteries and asking how shippers can safely transport this flammable cargo on freighters. The International Civil Aviation Organization and other world bodies have been issuing global rules regulating lithium battery transport, and on Aug. 6, the U.S. Transportation Department’s Pipeline and Hazardous Materials Safety Administration took a step to apply those global rules to the United States. The agency worked in conjunction with the FAA to harmonize battery transportation with the United Nations’ Model Regulations and those laid out by ICAO. The changes will take effect Feb. 6. 
   The ruling imposed separate shipping descriptions for lithium ion and lithium metal batteries, and adopted provisions for transporting batteries to be recycled and the transportation of damaged batteries, among other regulations.
   “Domestic air and vessel transport of lithium batteries is the final remaining segment likely to be impacted by the amendments in this final rule,” the rulemaking stated. “Commenters representing air carriers indicated that international operators and most U.S. operators conform to the provisions of the ICAO Technical Instructions because of the desire to have a single set of operational practices and training standards.”

Freighter Focus.   But banning lithium battery transportation on cargo planes is a different matter. Doug Brittin, secretary general of the International Air Cargo Association and former air cargo division director at the Transportation Security Administration, said cargo rules likely won’t come as quickly as they did for the passenger side. ICAO has a method for passing regulations, and then the FAA has to go through the rulemaking process.
   “It does take some time, but it does ensure that all aspects are looked at in depth and thoroughly,” he said. “Certainly, the safety of all of our air crews, aircraft — whether it’s an all-cargo or a passenger aircraft — that’s paramount to make sure that cargo does move safely and securely throughout the entire supply chain.”
   Though the safe transportation of lithium batteries has been a subject of debate for years, Brittin said all that has transpired in regards to cargo planes is discussion. 
   “We have not seen… a concrete proposal,” he said. “That doesn’t mean it might not be forthcoming, but we just haven’t seen anything or any language around those issues yet. 
   “The concern is certainly immediate,” Brittin added, “but I don’t think we’ve seen enough yet to say that there is the dire need… for something on a more immediate basis then the normal process would entail.” 
   For shippers, this means there’s time to plan and make sure their processes and procedures are correct. New packaging requirements would increase costs to shippers and an outright ban would cause them to find alternate transport for their cargo. For now, Brittin recommended shippers concentrate on obeying the current transport regulations for lithium batteries.

Minimum Impact.   Brittin said the ban on lithium battery shipments onboard passenger planes won’t have much impact on the movement of batteries globally because there are numerous transport alternatives available. He noted while some modal shift will occur depending on the final rule for cargo planes, there won’t be a significant impact to transportation flows. 
   “Any time that a product is banned outright that is carried in our part of the supply chain, that is something we want to keep an eye on closely,” he said. “But it’s not like there are hundreds of millions of pounds of lithium batteries flying around the globe.”
   The ICAO Dangerous Goods Panel last met in Rio de Janeiro on Oct. 20 to discuss, among other things, the transportation of lithium batteries. A month earlier, ICAO chaired the second International Multidiscplinary Lithium Battery Transport Coordination Meeting, where attendees pressed for better packaging of lithium batteries. 
   The goal, according to an ICAO report, was to “discuss the risks/hazards associated with the shipment of lithium metal and lithium ion batteries in both passenger and all-cargo aircraft cargo compartments. Also, to develop mitigation strategies, as needed, to provide the international aviation community with an acceptable risk for lithium battery shipment and afford the battery industry the least possible burden in implementation and cost.”
   During the first meeting in February, the group had recommended a possible ban on lithium metal batteries on passenger planes, a “multidisciplinary approach involving all stakeholders be taken as an essential step to advancing the issue of cargo safety,” and further discussion and testing regarding the air transport of these batteries. The panel pointed out the ICAO Council, on its own, decided to go ahead with the passenger ban.
   At a September ICAO Dangerous Goods meeting in Germany, Paul Rohrbach, a systems engineer at Airbus, called for an integrated lithium battery transport policy for the entire industry covering both lithium metal and lithium ion batteries; agreed-upon “mitigation strategies” for safe air transport; and a process to manage future battery-related issues. This holistic approach would require input from regulators, battery manufacturers, shippers, carriers, aircraft manufacturers and consumers.
   Rohrbach noted that stakeholders have a responsibility to develop new plans, but these plans must consider the limitations of each aircraft. 
   According to a FedEx presentation at the meeting, the integrator mitigates potential issues by first suppressing fires in containers and also developing packaging to prevent the spread of fire from one battery to the next within the same box. Through extensive testing, FedEx officials found that a lithium cell fire might not be prevented, but the spread of the fire can. A fire from a single battery, it found, will not endanger the crew or plane. FedEx also presented its tests to stop fires by cooling batteries instead of isolating them. 
   When the ICAO panel next met it issued more suggestions. Among its 14 recommendations, the ICAO group said lithium batteries should be carried in the “cargo compartment with the most appropriate fire mitigation capability” and manufacturers look into fire suppression techniques and how ULDs (unit load devices) and pallets hinder suppression efforts.
   Two recommendations addressed the planes themselves, asking manufacturers to “consider mitigating strategies for the carriage of lithium batteries in designing new aircraft types” and disclose how tolerant the cargo holds on their aircraft are to heat.  
   Recommendation 8 dealt directly with packaging. The panel suggested additional testing be done on packaging, which could include “the use of cooling agents such as gel packs as a means to add additional protective layers to mitigate the risks associated with the carriage of lithium batteries.”

Enforcing Rules.   But safety regulations are only effective if they are followed to the letter of the law. Some organizations worry shippers may try to circumvent ICAO’s evolving regulations. 
   On Aug. 8, George Kerchner of the Rechargeable Battery Association (PBRA) wrote to ICAO that his members have witnessed three instances in March and April of manufacturers based in Hong Kong skirting the rules. In the letter, he said his members spend lots of money and effort to comply with international battery shipment requirements, which include testing, training, paying additional handling fees and buying more packaging. 
   PBRA members, Kerchner said, produce 70 percent of the lithium ion cells in the world, accounting for billions of dollars in sales.
   “Our members also have a substantial interest in assuring that air transportation of their products remains a viable option,” he said. “It is therefore extremely troubling when we become aware of ongoing, non-compliant shipping practices by battery manufacturers and distributors in the Hong Kong and southern China regions.”
   Kerchner noted the number of companies involved in the lithium battery industry has ballooned in the past 15 years and there needs to be strict adherence to protocols because of the increased risk this popularity brings.
   “Without an aggressive enforcement effort, the chance of an incident greatly increases,” he wrote. “This is an unacceptable situation — and one that can be avoided if regulatory authorities enforce their dangerous goods regulations.” 
   Brittin said the lithium battery ban came to the passenger side of air transport quickly partly because of public reliability. Rules regarding pilot fatigue were introduced first on the passenger side, and he said security regulations after the Sept. 11, 2001 terrorist attacks were more immediate when passenger flights were involved. 
   “The risk and the threat of something happening to a passenger plane with all those lives on it as opposed to three or four… just seems to carry more significant weight in the legislature and the public’s eyes,” he said.    
   Recently, the Wall Street Journal reported ICAO is also considering limiting the electric charge of batteries being flown to 30 percent and redesigning cargo compartment liners. Packaging changes appear to be a more realistic goal than an outright ban on the air transportation of lithium batteries, Brittin said.  
   “Until we really see what’s coming with the potential changes to things, it’s something that we want to keep a close eye on. It certainly can have an impact if they’re banned outright, but we don’t know if that will be the outcome. It could be just some further restrictions on packaging or volumes per flight or anything along those lines. 
   “From an awareness and concern, from a safety standpoint,” he continued, “we all want to make sure that it is done properly. It’s following the right path along those lines.”

This article was published in the December 2014 issue of American Shipper.