Banning lithium battery cargo from commercial aircraft hurts supply chains

Update as of 2/23/2016: ICAO Approves ANC’s recommendations to prohit the carriage of UN 3480 on passenger aircraft http://www.icao.int/safety/DangerousGoods/Pages/DGP25-Report.aspx Rule goes into effect on April 1, 2016.


IATA published an update to their document titled “Lithium Batteries as Cargo in 2016” to inform lithium battery shippers of the pending ban of lithium batteries on passenger aircraft. On 27 January the ICAO Air Navigation Commission (ANC) recommended that lithium ion batteries, UN 3480 be forbidden for carriage as cargo on passenger aircraft. The ANC recommendation will next be considered by the ICAO Council the last week of February. It is likely that the Council will endorse the ANC’s recommendation to prohibit the carriage of UN 3480 on passenger aircraft. The date of implementation of the prohibition has not been confirmed, however it is expected that it will be aligned with other pending amendments (e.g. 30% State of Charge for stand alone batteries) that are scheduled to come into force from April 1, 2016.  IATA indicated that a further addendum to the DGR will be issued once the ICAO Council has confirmed the prohibition.

Impact on Supply Chains

This prohibition will have significant impacts to supply chains because cargo aircraft services and routes are limited and some destinations are only serviced by passenger aircraft. This will be critical for instance for batteries needed for critical life-saving purposes (e.g. replacement batteries needed for medical devices).  The ban on the shipment of lithium ion batteries aboard passenger aircraft will result in the inability to deliver lifesaving medical device batteries needed by patients, doctors, nurses and hospitals in remote areas.

Critical Exeptions Accounted For?

According to the text recommended by the ANC medical device companies will not be able to ship even one battery aboard a passenger aircraft.  The fact that A201 requires an exemption to the ICAO TI makes it virtually impossible to ship aboard passenger aircraft even if appropriate risk mitigation measures are put in place or if a single small battery needs to be shipped to meet urgent lifesaving needs.  The ANC obviously did not take the full impacts of the ban into account.

Having a reasonably achievable approval provision (state of origin and operator) would facilitate urgent shipments and promote interim development of packaging and risk mitigation solutions that could be implemented to allow critical shipments of medical device batteries to be transported on passenger aircraft.  The extreme difficulty of applying for the exemptions is magnified because there is no common application form, time schedule for processing, and payment method because each State has its own.

Establishing a reasonably achievable approval provision (state of origin and operator) for transporting lithium ion batteries aboard passenger aircraft would facilitate the interim development of packaging and risk mitigation solutions that could be implemented to allow critical shipments of medical device batteries.  In some cases it may be necessary to ship only one critical battery by passenger aircraft to save a life.  Under the current text adopted by the ANC this is not possible.  We understand that the ANC has been requested to provide a reasonable approval provision for lithium ion batteries needed for urgent needs.  Let’s hope they do the right thing.


Labelmaster is a full service provider of goods and services for the Hazardous Materials and Dangerous Goods professional, shippers, transport operators, and EH&S providers. See our full line of solutions at www.labelmaster.com.

 

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