NTSB · Safety Recommendation
Safety Recommendation A-16-002
Recommendation
TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTATION: Establish maximum loading density requirements that restrict the quantities of Class 3 flammable hazardous materials or Class 9 lithium batteries stowed on a single pallet or ULD, or on a group of pallets or ULDs, within an aircraft such that cargo fires can be effectively managed by on-board fire suppression capabilities.
Safety Issue and Context
On July 28, 2011, about 04:11 Korean standard time, Asiana Airlines Flight 991, a B747 400F airplane on a scheduled cargo flight from Incheon, Republic of Korea, to Shanghai, China, crashed into international waters about 130 km west of Jeju International Airport. The flight crew reported a cargo fire to Shanghai Area Control Center and attempted to divert to Jeju International Airport. The two pilots aboard the flight died. The wreckage of the airplane was distributed on the sea floor at an average depth of 85 meters (m), in an area 3 km by 4 km in a southwest-northeast direction.
The ARAIB determined that the cause of this accident was a fire that developed on or near two pallets containing dangerous goods packages, including hybrid-electric vehicle lithium ion batteries and flammable liquids, but no physical evidence of the cause of the fire was found. The fire rapidly grew large and uncontained, which resulted in a loss of control and some portions of the fuselage separating from the aircraft in midair, thereby resulting in the crash. The ARAIB report cited as a contributing factor the flammable materials and lithium-ion batteries that were loaded together either in the same or adjacent pallets.
Response History
December 10, 2020 · NTSB Correspondence · PHMSA
We note that, on March 6, 2019, you published an interim final rule (IFR), “Hazardous Materials: Enhanced Safety Provisions for Lithium Batteries Transported by Aircraft,” which prohibits transporting lithium-ion cells and batteries as cargo on passenger aircraft; requires lithium ion cells and batteries to be shipped with not more than a 30-percent state of charge aboard cargo-only aircraft when not packed with or contained in equipment; and limits the use of alternative provisions for small lithium cell or battery shipments to one package per consignment.
In addition, as we noted in our response to Safety Recommendation A-16-1, “Hazardous Materials: Harmonization with International Standards” established new requirements to segregate lithium cells and batteries from certain other hazardous materials when offered for transport or transported on aircraft.
We understand that, due to various aircraft designs and markets, it would be difficult to establish the recommended specific maximum loading density requirements. The mitigations you mention are a more viable approach and represent an acceptable alternate solution to this problem. Accordingly, Safety Recommendation A-16-2 is classified CLOSED--ACCEPTABLE ALTERNATE ACTION.
July 10, 2020 · Recipient Response · PHMSA
-From Howard R. Elliott, Administrator: PHMSA is addressing A-16-02 through multiple actions, which serve to adequately address the issues identified by NTSB.
On March 6, 2019, PHMSA published interim final rule (IFR) “Hazardous Materials: Enhanced Safety Provisions for Lithium Batteries Transported by Aircraft (FAA Reauthorization Act of 2018)” (HM-224I; 84 FR 8006). https://www.govinfo.gov/content/pkg/FR-2019-03-06/pdf/2019-03812.pdf The IFR harmonizes with international provisions adopted by the International Civil Aviation Organization (ICAO) Technical Instructions on the Transport of Dangerous Goods effective as of April 1, 2016, and addresses risks imposed by the transport of packaged lithium cells and batteries as cargo by aircraft independent of battery chemistry, cargo compartment characteristics, and loading configurations.