Good morning.
I will provide our perspective on the safe carriage of dangerous goods, and how the implementation of an effective safety management system focused on the transportation of these goods can improve aviation safety.
Specifically, this morning I would like to focus on the transportation of lithium batteries and what must be done to ensure they are carried safely aboard aircraft. Lithium batteries are part of everyday life for millions of people throughout the world, powering applications as varied as laptop computers, cell phones, flashlights, and cameras. These batteries are available in two major chemistries, lithium ion and lithium metal. Lithium ion batteries are generally rechargeable and contain a flammable electrolyte, while lithium metal batteries are non-rechargeable and contain metallic lithium.
While the vast majority of lithium batteries shipped as cargo or carried aboard aircraft by passengers and crew members arrive at their destination safely, there have been numerous incidents involving overheating and fire aboard aircraft, including two fatal 747 cargo accidents with onboard fires that involved lithium batteries. Additionally, testing conducted by the FAA at the William J. Hughes Technical Center in Atlantic City has shown that fires involving lithium batteries represent a significant risk to aircraft. If a single battery in a shipment is defective, damaged, or improperly packaged, it can spontaneously catch fire. This fire will then spread to every battery in the shipment, resulting in what may well be an uncontrollable fire. Consignments of lithium batteries may also serve as fuel for an independent fire, greatly increasing the intensity and severity of that fire.
Because the risk of a single lithium battery in transportation is low, both the ICAO technical instructions and the Canadian dangerous goods regulations provide exceptions for the shipment of small quantities of consumer-sized lithium batteries. If a package contains fewer than two lithium ion cells, or eight batteries, it is exempted from the majority of dangerous goods provisions, including the requirement to place a dangerous goods label on the package, train the shipper, and notify the pilots that the shipment is aboard the aircraft. The threat to the aircraft, however, comes from the fact that the dangerous goods regulations stop at the package level. There is nothing to prevent a shipper from consolidating many packages containing eight or fewer cells on a single pallet, and nothing that prevents the operator from loading the entire aircraft with lithium batteries. In fact, there were approximately 80,000 to 90,000 lithium batteries aboard the cargo 747 that crashed in 2010 in Dubai, a situation that would still be allowed today.
There has been recent progress, however. In April of this year I represented IFALPA at an ICAO working group in Montreal tasked with considering the transportation of lithium metal batteries aboard passenger aircraft. Recognizing that halon is ineffective at suppressing a fire involving lithium metal batteries, the ICAO dangerous goods panel recommended that these batteries be prohibited as cargo aboard a passenger aircraft. If approved, this decision will take effect on January 1, 2015. This is a significant safety step, yet it does nothing to address lithium metal batteries on cargo aircraft, lithium metal batteries in equipment, or lithium ion batteries on any aircraft. ALPA therefore believes much more work needs to be done.
From a systems-safety perspective, the transportation of thousands of lithium batteries at a single location represents an unacceptable risk to the aircraft and its occupants. An effective safety management system involving dangerous goods would recognize the risk of large quantities of lithium batteries aboard an aircraft instead of focusing the regulations on the package level. Lithium batteries should be recognized as dangerous goods, packed in an appropriate manner, and loaded into a cargo compartment with fire suppression. Additionally, the quantity of batteries must be limited to that which will allow the suppression system to be effective.
In conclusion, ALPA believes Transport Canada should now take steps beyond those required by ICAO to ensure the promulgation of measures that will protect the public, flight crew members, and other individuals travelling on cargo aircraft and those involved in the air cargo transportation system from the hazards currently associated with the shipment of lithium batteries by air. This action is necessary for improving the overall safety of air cargo operations and the protection of lives and property whenever lithium batteries are moved through the air transportation system.
On behalf of ALPA's members, we would like to thank the committee members for the opportunity to appear before you today.