Safety Recommendation A-07-099

The FAA indicated that the benefits of Halon compartment fire suppression systems, or alternative systems, do not justify the cost of installing such systems in the main deck cargo compartments of cargo aircraft of any weight category. The NTSB is disappointed that, although the FAA requires passenger aircraft to have fire suppression systems installed in their cargo compartments, it has not instituted a similar requirement for cargo airplanes. Because the FAA has indicated that it has completed its actions in response to this recommendation, however, Safety Recommendation A-07-99 is classified CLOSED – UNACCEPTABLE ACTION.

CC# 201000359: - From J. Randolph Babbitt, Administrator: The FAA arranged for a cost-benefit analysis for the installation of on-board fire detection and extinguishment systems in all-cargo airplanes. In April 2009, we published results of the analysis in report DOT/FAAIAR-09/17, A Cost-Benefit Analysis for the Installation of Fire Suppression Systems in Cargo Compartments of Cargo Airplanes (enclosure 2).

The results show that benefits of Halon (a bromotrifluorocarbon fire suppressant manufactured by DuPont) compartment flooding fire suppression systems, or alternative compartment flooding systems likely to be developed for below-floor cargo compartments, do not justify the cost for the main deck cargo compartments of cargo aircraft of any weight category. After careful consideration of this analysis, we have decided not to pursue additional rulemaking at this time. However, the FAA continues to support efforts to improve fire protection on all-cargo airplanes.

For example, we continue to work with industry and other government agencies in evaluating the use of new, non-Halon fire extinguishing agents; directed fire suppression systems that apply agent to individual cargo containers or specific cargo compartment zones; new fire inerting systems utilizing nitrogen or water mist; and advanced cargo containers that incorporate smoke detection, fire containment, and fire suppression systems. Should research produce a viable option, we will consider further action.

Notation 7772F: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking (NPRM), “Hazardous Materials: Transportation of Lithium Batteries,” that was published at 75 Federal Register 1302 on January 11, 2010. The NPRM requests comments on revisions to the requirements for the transportation of lithium batteries in the Hazardous Materials Regulations (HMRs). The primary purpose of the NPRM is to enhance the safe transportation of primary (non-rechargeable) and secondary (rechargeable) lithium batteries when transported as cargo in all modes, with an emphasis on aviation.

The NTSB believes that PHMSA has proposed requirements that should improve the level of safety for transporting lithium battery cargoes, particularly on aircraft. However, the NTSB offers the following comments to strengthen and clarify the proposed rule. Overview The NPRM proposes new requirements that address Safety Recommendations A-07-104, A-07-105, and A-07-107 through -109 that were issued as a result of the NTSB’s 2006 investigation of an in-flight cargo fire on a cargo airplane at Philadelphia International Airport in Philadelphia, Pennsylvania.

The NPRM specifically addresses these safety recommendations through proposed requirements concerning the stowage of lithium batteries, the reporting and analysis of lithium battery failures, and the elimination of regulatory exceptions for small lithium batteries. The NTSB has included detailed comments about each of these areas in subsequent sections of this letter. The NTSB notes that PHMSA also proposes other requirements, and those are addressed as well. The NPRM does not address Safety Recommendations A-08-1 and -2, which were issued separately from the Philadelphia accident report but also pertain to the transportation of lithium batteries.

Safety Recommendations A-08-1 and -2 concern the implementation and evaluation of public awareness programs for air passengers and crews who carry portable electronic devices containing lithium batteries or pack spare lithium batteries in their baggage or carry-on items. The NTSB notes that PHMSA plans to address these two recommendations under a separate rulemaking. However, because of the proliferation of personal electronic devices carried by the traveling public, the NTSB urges PHMSA to expedite its rulemaking regarding these recommendations. Stowage of Lithium Batteries

Cargo shipments of primary lithium batteries have been prohibited on passenger aircraft for more than 10 years, but they are still permitted on cargo-only aircraft. Cargo shipments of secondary lithium batteries are permitted on both passenger and cargo-only aircraft. The transportation of primary lithium batteries is potentially dangerous, particularly on board aircraft, because there is currently no known fire suppression system capable of extinguishing fires involving these types of batteries. Fires involving secondary lithium batteries are extinguishable by fire suppression systems approved by the Federal Aviation Administration (FAA).

The FAA stated that it would review the guidance on Class E cargo-compartment fire protection and operators’ procedures for cargo-compartment fire containment to determine the effectiveness of the fire protection systems. The FAA will also review the service history of Class E cargo compartments and evaluate requiring the installation of fire suppression systems in Class E compartments.

The Safety Board recognizes that the actions described are the first steps that the FAA needs to take to implement the recommended regulatory change. Pending the establishment of a requirement that all cargo compartments of all cargo aircraft be equipped with fire suppression systems, Safety Recommendation A-97-99 is classified OPEN -- ACCEPTABLE RESPONSE.

Letter Mail Controlled 9/18/2008 12:11:57 PM MC# 2080573: - From Robert A. Sturgell, Acting Administrator: We understand this recommendation refers to installation of fire suppression systems in previously approved Class E cargo compartments. We will review the guidance on Class E cargo compartment fire protection and operators’ cargo compartment fire containment procedures to determine the effectiveness of the fire protection relative to compartments which require fire suppression systems. In addition, we will review the service history of Class E cargo compartments and evaluate the safety benefits, costs, and operational impact of requiring the installation of fire suppression systems.

I will provide a status update by January 2009. I will keep the Board informed of the FAA’s progress on this safety recommendation.