NTSB · Safety Recommendation
Safety Recommendation A-99-084
Recommendation
THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: INITIATE ACTION THROUGH THE DANGEROUS GOODS PANEL TO REVISE THE TECHNICAL INSTRUCTIONS FOR THE SAFE TRANSPORTATION OF DANGEROUS GOODS BY AIR TO REQUIRE THAT PACKAGES CONTAINING LITHIUM BATTERIES BE IDENTIFIED AS HAZARDOUS MATERIALS WHEN TRANSPORTED ON AIRCRAFT.
Safety Issue and Context
ON 4/28/99, A FIRE DESTROYED FREIGHT, INCLUDING LITHIUM BATTERIES, ON TWO AIRCRAFT CARGO PALLETS AT THE NORTHWEST AIRLINES CARGO FACILITY AT LOS ANGELES INT'L. AIRPORT. THE PALLETS HAD BEEN TAKEN OFF AN INBOUND PASSENGER-CARRYING FLIGHT FROM OSAKA, JAPAN. THE AIRCRAFT WAS A BOEING 747, OPERATED BY NORTHWEST AIRLINES AS FLIGHT 0026. THE NATIONAL TRANSPORTATION SAFETY BOARD'S INVESTIGATION OF THIS INCIDENT REVEALED THAT LITHIUM BATTERIES LIKELY PRESENT A SERIOUS FIRE HAZARD TO AIR TRANSPORTATION REQUIRING IMMEDIATE ATTENTION.
CURRENTLY, LITHIUM BATTERIES OF THE TYPE INVOLVED IN THE APRIL 28 FIRE CAN BE TRANSPORTED ON BOTH PASSENGER-CARRYING AND CARGO-ONLY AIRCRAFT BUT ARE NOT CLASSIFIED AS A HAZARDOUS MATERIAL REQUIRING APPROPRIATE IDENTIFICATION, MARKING, LABELING, AND TESTING.
Response History
September 26, 2002 · NTSB Correspondence · RSPA
On April 2, 2002, RSPA published a notice of proposed rulemaking (NPRM) titled "Hazardous Materials: Transportation of Lithium Batteries," which proposes changes to test methods for lithium batteries; revisions to exceptions for small batteries, including new marking requirements; elimination of certain exceptions for larger batteries; and other modifications. RSPA reports that it is continuing to reevaluate the hazards posed by lithium batteries in transportation by collecting information from lithium battery manufacturers, shippers, and federal agencies with extensive experience in testing and use of lithium batteries.
The NPRM letter is not directly relevant to Safety Recommendations A-99-83 and -84. However, these recommendations were discussed at the July 18, 2002, meeting on open safety recommendations.
RSPA stated that it has taken the following actions in response to those two recommendations: the publication of a safety advisory in the Federal Register on September 7, 2000, regarding the transportation of lithium batteries; notification of the ICAO Dangerous Goods Panel as specified in both safety recommendations; and revisions to the ICAO Technical Instructions for the Transport of Dangerous Goods by Air that are consistent with the changes proposed in the NPRM (i.e., incorporation of UN testing criteria for packaging for lithium batteries, warning labels and marking for packages of lithium batteries, and emergency instructions to be included with the shipping documents for lithium batteries).
Regarding Safety Recommendation A-99-84, the Safety Board acknowledges that RSPA initiated this proposal to the ICAO Dangerous Goods Panel as recommended. Additionally, RSPA staff provided examples of the warning labels developed by the battery industry and that shippers of lithium batteries will voluntarily place on packages of lithium batteries. The Board believes that the use of these labels in conjunction with recent revisions to UN and ICAO standards to mark packages of lithium batteries and to include emergency instructions with the shipping documents is responsive to the recommendation. Consequently, Safety Recommendation A-99-84 is classified "Closed--Acceptable Action."
June 10, 2002 · Recipient Response · RSPA
Letter Mail Controlled 06/20/2002 3:13:33 PM MC# 2020614 We recently published a Notice of Proposed Rulemaking (NPRM) entitled "Hazardous Materials: Transportation of Lithium Batteries." A copy of the NPRM is enclosed. In the NPRM, we propose changes to test methods for lithium batteries; revisions to exceptions for small batteries, including new marking requirements; elimination of certain exceptions for larger batteries; and other modifications.
These proposed changes are intended to enhance the safe transportation of lithium batteries and harmonize our domestic requirements with changes recently made to international transportation standards in the United Nations Recommendations on the Transport of Dangerous Goods. We are continuing to reevaluate the hazards posed by lithium batteries in transportation. We are collecting information from lithium battery manufacturers, shippers, and Federal agencies with extensive experience in testing and use of lithium batteries. When we complete our evaluation, we will initiate any additional actions necessary to assure that lithium batteries are transported safely.
We will keep you informed of our progress. If you have any questions, please contact me or Suzanne TeBeau, Associate Administrator for Policy and Congressional Affairs, at (202) 366-4831
June 13, 2001 · NTSB Correspondence · RSPA
The Safety Board notes that although publishing the Advisory Notice is a commendable activity, it does not address the intent of these recommendations. . In its March 29, 2000, letter, RSPA informed the Board that in coordination with the FAA, it is re-evaluating the hazards posed by lithium batteries in air transport and the safety measures necessary to protect an aircraft and its occupants, including an evaluation of the current testing requirements of the United Nations' Transport of Dangerous Goods Manual of Tests and Criteria and current regulatory requirements.
Pending revision by the Dangerous Goods Panel to the Technical Instructions for the Safe Transportation of Dangerous Goods by Air to require that packages containing lithium batteries be identified as hazardous materials when transported on aircraft, Safety Recommendation A-99-84 remains classified "Open-Acceptable Response."
October 24, 2000 · Recipient Response · RSPA
Letter Mail Controlled 10/30/2000 1:38:06 PM MC# 2001605 On September 7, 2000 RSPA published an Advisory Notice, a copy of which is enclosed for your information, that: (1) Informed persons of the incident and the potential hazards that shipments of lithium batteries may present while in transportation, (2) Recommended actions to offerors and transporters to ensure the safety of such shipments, (3) Provided information concerning the current requirements for the transportation of lithium batteries,
(4) Informed persons of recommendations that we received from the National Transportation Safety Board (NTSB) on the transportation of lithium batteries and our response to those recommendations, (5) Informed persons of the actions we have taken to date and plan to take in the future to address the hazards of these batteries, and (6) Provided information concerning initiatives being taken by members of the battery manufacturing and distribution industry to address concerns these batteries. relating to transportation of these batteries.
June 27, 2000 · NTSB Correspondence · RSPA
THE SAFETY BOARD IS PLEASED THAT RSPA IS TAKING THE ACTIONS RECOMMENDED. PENDING REVISION TO THE UN RECOMMENDATIONS SO THAT ALL LITHIUM BATTERIES ARE SUBJECT TO THE UN TEST MANUAL AND SO THAT SMALL LITHIUM BATTERIES ARE REGULATED AS HAZARDOUS MATERIALS, AND PENDING NOTIFICATION OF THE ICAO DANGEROUS GOODS PANEL ABOUT THE LAX INCIDENT, A-99-83 AND -84 ARE CLASSIFIED "OPEN--ACCEPTABLE RESPONSE."
March 29, 2000 · Recipient Response · RSPA
Letter Mail Controlled 04/06/2000 3:33:05 PM MC# 2000498 IN A UNITED NATIONS WORKING GROUP MEETING THAT WAS HELD MARCH 13-15, 2000 IN OTTAWA, CANADA, RSPA RECOMMENDED THAT THE UNITED NATIONS RECOMMENDATIONS ON THE TRANSPORT OF DANGEROUS GOODS (LTN RECOMMENDATIONS) BE REVISED SO THAT ALL LITHIUM BATTERIES BE SUBJECT TO THE UN TEST MANUAL AND THAT SMALL LITHIUM BATTERIES BE REGULATED AS HAZARDOUS MATERIALS. A COPY OF THE RECOMMENDED PROPOSAL IS ATTACHED FOR YOUR INFORMATION. RSPA IS ALSO TAKING STEPS TO NOTIFY THE INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) DANGEROUS GOODS PANEL OF THE LAX INCIDENT. RSPA ANTICIPATES TRANSMITTING THE NOTIFICATION WITHIN THE NEXT COUPLE OF WEEKS.
RSPA WILL INITIATE ANY ADDITIONAL PROPOSALS TO AMEND THE INTERNATIONAL REQUIREMENTS FOR THE TRANSPORTATION OF LITHIUM BATTERIES, INCLUDING THE ICAO TECHNICAL INSTRUCTIONS ON THE SAFE TRANSPORT OF DANGEROUS GOODS BY AIR, CONSISTENT WITH ANY AMENDMENTS TO THE HAZARDOUS MATERIALS REGULATIONS.