Pilots Union Seeks Ban on Lithium Battery Shipments

Fri, Aug 28, 2009 — David Evans


Three recent fires involving shipments of lithium-ion batteries aboard cargo airplanes have exhausted the pilots union’s patience regarding action on these hazardous shipments. The Air Line Pilots Association (ALPA) has called for a prohibition on lithium battery shipments until rules are in place that designates the batteries as hazardous cargo.

The shipments are not presently designated as hazardous cargo, although they are presently banned from being transported in the belly holds of passenger airliners. However, the battery shipments are perfectly okay on all-cargo aircraft where, as indicated in a 14 August incident on a Federal Express MD-11 at Minneapolis-St. Paul, they constitute a continuing fire hazard.

Without tighter controls, sooner or later a shipment of lithium-ion or lithium-metal batteries is going to cause a crash. For one thing, Halon fire-extinguishing agent has no effect on the intensity of a lithium battery fire.

As Mark Rogers, director of ALPA’s Dangerous Goods Programs said, “The evidence of a clear and present danger is mounting [and] we need an immediate ban on these dangerous goods to protect airline passengers, crews and cargo.”

Actually, passengers already are protected, as bulk shipments of lithium batteries have been prohibited on passenger airliners since 2007, but the danger to cargo airplane crews remains extreme. It is also clear that the Pipeline and Hazardous Materials Safety Administration (PHMSA), which regulates dangerous goods shipments, has been acting in a very slow, deliberate manner to come to grips with the hazard. Meanwhile, shipments continue to fly on cargo jets, and spontaneous ignition of batteries continues to occur. The clock on a major disaster is ticking.

The problem of bulk lithium battery fires in air shipments goes back some 20 years. In November 1987 a South African Airways B747 combi (a hybrid freighter with a partition separating cargo from passengers on the main deck), with 159 passengers aboard, disappeared into the Indian Ocean off Mauritius. Its cargo included a consignment of lithium watch batteries. A wreckage survey by robot cameras determined that the lithium batteries were located in the same area that was established as the seat of the fire.

Not conclusive evidence of flammable batteries, but the general description of the fire that doomed the plane certainly points to the extreme danger posed by lithium batteries if they catch fire.

In April 1999 a pallet of lithium batteries was inadvertently dropped on the tarmac at Los Angeles International Airport. A lithium battery fire resulted, despite there being no ignition source.

As a result of this incident, the FAA Technical Center at Atlantic City, NJ, embarked on lithium battery fire tests, using a steel chamber simulating a cargo hold and involving tests of groups of up to 128 batteries packed in cardboard boxes. The findings were fearful. To summarize:

— The heat from a single battery afire was sufficient to ignite adjacent batteries.

— The outer plastic coating on the batteries easily melted, fusing the batteries together, adding to the intensity of the fire.

— The chain reaction continued until all batteries were consumed.

— The molten lithium burned explosively, spraying white-hot lithium to a radius of several feet.

— The fire was hotter than the melting point of aluminum, indicating that a runaway lithium battery conflagration could burn its way through the fuselage skin.

— Halon fire-suppressing agent proved totally ineffective, even when introduced just after the first battery caught fire. Nor did Halon have any effect on the peak temperature. The fire continued as if Halon were not present.

Remains of an exploded lithium-ion battery.

Remains of an exploded lithium-ion battery.

In short, when shipped in bulk as cargo, lithium batteries may represent the ultimate hazardous material. For this reason, they were banned from transport in the cargo holds of passenger airliners. Only aircrews of cargo planes were exposed to the risk.

Then in February 2006 a UPS DC-8 freighter conducted an emergency landing at its destination, Philadelphia International Airport, with a cargo fire warning in the cockpit. The three man crew evacuated safely, but the aircraft was consumed by fire.

The charred remains of the UPS DC-8 freighter.

The charred remains of the UPS DC-8 freighter.

In its letter of December 2007 to PHMSA, the National Transportation Board (NTSB) said:

“PHMSA’s August 2007 final rule regarding the transportation of lithium batteries did not establish sufficient levels of safety for air transportation of small secondary [rechargeable] lithium batteries … Therefore, the Safety Board believes that PHMSA should eliminate regulatory exemptions for the packaging, marking, and labeling of cargo shipments of small secondary lithium batteries …”

To this end, the NTSB issued Safety Recommendation A-07-109, calling for elimination of the exemptions. That was more than two and a half years ago. According to NTSB records, PHMSA responded that it would undertake a cost/benefit study on the effect of eliminating the exemptions. The NTSB classified its recommendation “OPEN – Acceptable Response.”

That is the status today. No PHMSA action. But we do have a page of small print from PHMSA to the NTSB, explaining at length why progress is difficult. Here is an example of the PHMSA’s vacuous promissory note of 28 March 2998, the last time the NTSB heard from the agency:

“We plan to complete a formal assessment of the costs and benefits associated with eliminating the regulatory exemptions for small lithium batteries and will identify regulatory and other approaches based on that assessment. For example, we will consider whether requiring small lithium batteries to be regulated as Class 9 materials and subject to the full range of packaging and hazardous communication requirements applicable to Class 9 materials will be effective in reducing their risk in transportation, whether the measures taken to date are sufficient and whether other alternative solutions can be equally effective in reducing risk.”

Note that this sort of bureaucratic “bafflegarb” was not put forward when the decision was made to remove such shipments from the cargo holds of passenger carrying aircraft. Note, too, that this obfuscating language has been served up in the face of a fire hazard impervious to Halon fire suppressing chemical.

There is no acknowledgement on the PHMSA website that ALPA’s 20 August letter (see below) has been received or will be acted upon. Given the PHMSA’s last response to the NTSB, one would think the Safety Board would have classified recommendation A-07-109 as “CLOSED – Unacceptable Response.” Characterizing PHMSA’s reaction as “Acceptable” is really just a vain hope that some day, somehow, the PHMSA will step up to its responsibilities.


August 20, 2009


Ms. Cynthia Douglass

Acting Deputy Administrator

U.S. Department of Transportation

Pipeline and Hazardous Materials Safety Administration (PHMSA)

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Ms. Douglass:

The Air Line Pilots Association, International (ALPA) … would like to express its profound and growing concern about the hazardous shipment of batteries on cargo aircraft. Since June 18, 2009, there have been three separate incidents involving the carriage of lithium-ion batteries on US cargo aircraft which could have resulted in accidents:

— August 14, Minneapolis-St. Paul International Airport (MSP). After landing and exiting the runway, the crew received a warning indicating smoke in the forward cargo compartment. The MSP aircraft rescue and firefighting [ARFF] personnel observed smoke emanating from the forward cargo compartment and detected a heat source forward of the cargo door. They removed the cargo in the compartment and discovered a container emitting flames. Fortunately, the ARFF personnel were able to extinguish the fire with no damage to the aircraft or loss of life. Although the {National Transportation Safety Board] investigation is presently ongoing, initial indications are that the fire originated with a shipment of approximately 1,000 e-cigarettes, each containing a rechargeable lithium-ion battery.

An e-cigarette provides nicotine without all the other harmful ingredients of tobacco. The atomizer is powered by a lithium battery.

An e-cigarette provides nicotine without all the other harmful ingredients of tobacco. The atomizer is powered by a lithium battery.


— July 15, Santo Domingo, Dominican Republic. The initial report from the airline indicated that one of several related packages transported from Romulus, MI was discovered to be emitting smoke and smoldering. Upon inspection, the package was found to contain numerous, loose lithium-ion cell phone batteries with no protection of the contact points. Package documentation indicated ‘used batteries – non-haz.’

— June 18, Honolulu, HI. The initial report indicated that a burned package was discovered inside a Unit Load Device as it was being unloaded. The package, containing a lithium-ion bicycle-power device, was originally loaded in Philadelphia and was subsequently transported from Ontario, CA.

The similarities between these incidents and the February 7, 2006 accident involving a UPS DC-8 at Philadelphia, PA (UPS flight 1307) are striking. Following the investigation of that accident, the NTSB issued a number of recommendations addressing lithium battery transport, including a recommendation to fully regulate these batteries as dangerous goods (A-07-109). Since the UPA accident, the Federal Aviation Administration (FAA) has documented 26 additional incidents involving lithium-ion and lithium-metal batteries in air transportation.

ALPA has long advocated for improved transport requirements for lithium-ion and lithium-metal batteries. From 2004 to the present, ALPA has urged the Department of Transportation to fully regulate these batteries as dangerous goods, including packaging, labeling, marking, testing, and pilot notification requirements. Furthermore, ALPA has asked that the ban of bulk shipments of lithium-metal batteries on passenger aircraft be extended to all-cargo aircraft until adequate packaging standards can be developed.

At the May 14th, 2009 hearing of the House Subcommittee on Pipeline and Hazardous Materials, in response to questioning from Chairman Oberstar, you indicated that rulemaking was being drafted to improve lithium battery safety, including fully regulating lithium batteries as dangerous goods. We certainly endorse and support the development of this rulemaking and look forward to commenting on the proposed rule. However, it is clear from these recent, ongoing incidents that decisive action to safeguard aviation should not be withheld until the rulemaking process concludes. We have been most fortunate that the lithium-ion battery malfunctions noted above did not cause an accident, but luck is not a sound safety strategy.

Accordingly, we call upon PHMSA to immediately issue a temporary prohibition on the carriage of lithium-ion and lithium-metal batteries as cargo on passenger and all-cargo aircraft which will remain in place until the agency has concluded the rulemaking process and shippers can safely transport these hazardous items in accordance with the new rules.

Thank you for your consideration of this recommendation. We look forward to your earliest response.


John Prater

President, ALPA

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