Narrative:

Subject: lithium batteries aboard aircraft. During my initial preflight of the main cargo deck; I noticed several cargo containers containing (approximately) 20 x 20 x 10 boxes displaying the red IATA/ICAO lithium battery handling label next to a shipping label stating the box's contents to be 'lithium batteries.' getting my attention; I walked the entire cargo load noting at least five cargo containers that contained at least a dozen similar boxes with the same labels. Knowing only that we're authorized to carry some limited amounts of lithium batteries with specific packaging and quantity requirements depending on whether they are contained in devices or by themselves; I brought the items to the attention of the captain. The captain raised the question with the station manager as to whether there is any available documentation showing exactly where in the load and what amount of batteries existed; since they are not necessarily required to be listed on the notoc paperwork or declared as dangerous goods; as our flight operations information bulletin indicates. The captain also posed the same question to our dispatcher via cell phone. Both our dispatcher and station manager agreed that it was a valid question being raised and began researching for answers. The station manager also explained that load supervisors and station personnel often have no visibility to the existence of lithium batteries within loads; as they are often not listed on the a waybill; but on a courier document supplied be each individual shipping customer. After numerous phone calls over approximately 30 minutes; the station manager was able to track down a supply chains solutions waybill document and a courier customer document from the manufacturer as well as a page (541) from the IATA guidance document - transport of lithium batteries; packaging instruction 967. Upon initial read; the documents seemed; for the time being; to answer everyone's questions; at least concerning the existence of batteries on-board; so we closed doors and departed. Upon closer study of the documents while en-route and further post-flight research; we discovered several incongruities that raise further questions. First; the courier document from the manufacturer says that there were a total of '350 lithium ion batteries contained in equipment' categorized as UN3481 by the IATA guidance document; section 1; as 'lithium ion batteries contained in or packed with equipment;' but the document has no weight listed; nor is there any means of determining whether this courier document corresponds to the numerous boxes throughout our load labeled simple as 'lithium batteries.' second; the company supply chains solutions document for the manufacturer shows only one (1) item - 'lithium battery contained in MP3 player' for a total weight of only 43.0 kg. Not only does this not match the 350 batteries indicated on the other courier document; but it also doesn't correspond to the numerous boxes labeled as 'lithium batteries' that we witnessed onboard; nor does it even comply with 35 kg per item lithium battery limitation for carriage on cargo aircraft listed in the IATA regulation. After considerable research of the IATA guidance and comparing the shipping documents we were provided; I still cannot conclude that numerous boxes aboard our aircraft labeled 'lithium batteries' were in fact the items described in the shipping documents we received. The facts of this incident; in total; lead me to think we have a systemic (potentially dangerous) lack of collective knowledge among flight crews; shipping and receiving personnel; gateway; and load personnel concerning the requirements for packaging; labeling and carrying specific amounts of lithium batteries as cargo aboard our aircraft. As crews and station personnel serve as the last line of defense in our operation; at a minimum; I would suggest that crew members and station personnel become more familiar with the ICAO/IATA technical instruction for the safe transport of dangerous goods by air document and the IATA dangerous goods regulations (dgr). I would also suggest making these documents part of the ship's library; for immediate reference and clarification of questions by crews and station personnel. To buy into the belief that because a consignment is not hazardous because it is of 'limited quantity' becomes very dangerous. To suggest that the IATA/ICAO handling label is a standard advisement on consignments which contain 'lithium ion battery' and/or 'lithium metal battery' is misleading. The advisement is that there are batteries which do not require a class 9 hazardous label; but do require a label as specified in the additional requirements of section ii of packing instructions 965; 966; 967; 968; 969 and 970 of the ICAO technical instructions. DOT/FAA/ar-11/18 air traffic organization next gen & operations planning office of research and technology development washington; dc 20591; freighter airplane cargo fire risk model. The above document speaks volumes as the risk model seems primarily concerned with the monetary costs and not much else; it does however indicate there is predicted to be a significant rise in the type of accidents the cargo industry has already experience twice. We have and continue to carry large quantities of lithium batteries. Yet what should have been an easily handled question resulted in a 43 minute delay multiple communications and now a second event report. In tests conducted earlier by the FAA; researchers found 'that just a handful of certain types of lithium batteries; typically used in some consumer products and electric cars; can result in explosions that can spew molten lithium and potentially damage cargo compartments. More commonly used lithium ion batteries; which have become symbols of the proliferation of hand-held digital communication and entertainment devices; also pose significant dangers when jammed into cargo planes. A runaway fire among these types of cells; according to the agency; also can reach temperatures high enough to ignite paper and cardboard. Some battery fires may reach temperatures 'very close to the melting point of aluminum;' according to the FAA. Government action has been opposed by a broad coalition of rechargeable battery suppliers; cellular phone manufacturers; other makers of electronic devices and retail industry groups. Cargo carriers also have raised complaints about proposed transportation department rules. Pressure from such industry groups including appeals to white house officials about the cost of special packaging and mandatory installation of advanced fire-suppression systems on all big cargo jets has complicated and delayed government rule making.' I am troubled by an industry and company that is opposed to more stringent rules covering packaging; sizes of battery shipments and the necessary extra training for workers distributing; handling and loading lithium-battery packages. It may be that current rules exempt most lithium batteries along with the devices they power from being declared dangerous goods; they also allow for the boarding of batteries and devices without making the captain aware of the size and location of battery shipments. It may be technically legal but it is certainly not morally or ethically correct. I am certain everyone has read: safo safety alert for operators us department safo 10017 of transportation date: 10/8/10 federal aviation administration flight standards service; washington; dc how can we pay special attention to ensuring careful handling and compliance with existing regulations covering the air transportation of class 9 hazardous materials; including lithium batteries if we do not even know we have them onboard?

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Original NASA ASRS Text

Title: An all cargo carrier Captain questions the current regulations regarding documentation; handling and carriage of Lithium batteries.

Narrative: Subject: Lithium Batteries aboard aircraft. During my initial preflight of the main cargo deck; I noticed several cargo containers containing (approximately) 20 x 20 x 10 boxes displaying the red IATA/ICAO Lithium Battery Handling Label next to a shipping label stating the box's contents to be 'lithium batteries.' Getting my attention; I walked the entire cargo load noting at least five cargo containers that contained at least a dozen similar boxes with the same labels. Knowing only that we're authorized to carry some limited amounts of lithium batteries with specific packaging and quantity requirements depending on whether they are contained in devices or by themselves; I brought the items to the attention of the Captain. The Captain raised the question with the Station Manager as to whether there is any available documentation showing exactly where in the load and what amount of batteries existed; since they are not necessarily required to be listed on the NOTOC paperwork or declared as Dangerous Goods; as our Flight Operations Information Bulletin indicates. The Captain also posed the same question to our Dispatcher via cell phone. Both our Dispatcher and Station Manager agreed that it was a valid question being raised and began researching for answers. The Station Manager also explained that Load Supervisors and Station Personnel often have no visibility to the existence of lithium batteries within loads; as they are often not listed on the a Waybill; but on a Courier Document supplied be each individual shipping customer. After numerous phone calls over approximately 30 minutes; the Station Manager was able to track down a Supply Chains Solutions Waybill document and a Courier Customer Document from the manufacturer as well as a page (541) from the IATA Guidance Document - Transport of Lithium Batteries; Packaging Instruction 967. Upon initial read; the documents seemed; for the time being; to answer everyone's questions; at least concerning the existence of batteries on-board; so we closed doors and departed. Upon closer study of the documents while en-route and further post-flight research; we discovered several incongruities that raise further questions. First; the courier document from the manufacturer says that there were a total of '350 lithium ion batteries contained in equipment' categorized as UN3481 by the IATA Guidance Document; Section 1; as 'lithium ion batteries contained in or packed with equipment;' but the document has no weight listed; nor is there any means of determining whether this courier document corresponds to the numerous boxes throughout our load labeled simple as 'lithium batteries.' Second; the Company Supply Chains Solutions document for the manufacturer shows only one (1) item - 'lithium battery contained in MP3 Player' for a total weight of only 43.0 kg. Not only does this not match the 350 batteries indicated on the other courier document; but it also doesn't correspond to the numerous boxes labeled as 'lithium batteries' that we witnessed onboard; nor does it even comply with 35 kg per item lithium battery limitation for carriage on cargo aircraft listed in the IATA regulation. After considerable research of the IATA guidance and comparing the shipping documents we were provided; I still cannot conclude that numerous boxes aboard our aircraft labeled 'lithium batteries' were in fact the items described in the shipping documents we received. The facts of this incident; in total; lead me to think we have a systemic (potentially dangerous) lack of collective knowledge among flight crews; shipping and receiving personnel; gateway; and load personnel concerning the requirements for packaging; labeling and carrying specific amounts of lithium batteries as cargo aboard our aircraft. As crews and station personnel serve as the last line of defense in our operation; at a minimum; I would suggest that crew members and station personnel become more familiar with the ICAO/IATA Technical Instruction for the Safe Transport of Dangerous Goods by Air Document and the IATA Dangerous Goods Regulations (DGR). I would also suggest making these documents part of the ship's library; for immediate reference and clarification of questions by crews and station personnel. To buy into the belief that because a consignment is not hazardous because it is of 'limited quantity' becomes very dangerous. To suggest that the IATA/ICAO handling label is a standard advisement on consignments which contain 'Lithium ion battery' and/or 'Lithium metal battery' is misleading. The advisement is that there are batteries which do not require a Class 9 Hazardous Label; but do require a label as specified in the additional requirements of Section II of packing instructions 965; 966; 967; 968; 969 and 970 of the ICAO Technical Instructions. DOT/FAA/AR-11/18 Air Traffic Organization Next Gen & Operations Planning Office of Research and Technology Development Washington; DC 20591; Freighter Airplane Cargo Fire Risk Model. The above document speaks volumes as the risk model seems primarily concerned with the monetary costs and not much else; it does however indicate there is predicted to be a significant rise in the type of accidents the cargo industry has already experience twice. We have and continue to carry large quantities of Lithium Batteries. Yet what should have been an easily handled question resulted in a 43 minute delay multiple communications and now a second event report. In tests conducted earlier by the FAA; researchers found 'that just a handful of certain types of lithium batteries; typically used in some consumer products and electric cars; can result in explosions that can spew molten lithium and potentially damage cargo compartments. More commonly used lithium ion batteries; which have become symbols of the proliferation of hand-held digital communication and entertainment devices; also pose significant dangers when jammed into cargo planes. A runaway fire among these types of cells; according to the agency; also can reach temperatures high enough to ignite paper and cardboard. Some battery fires may reach temperatures 'very close to the melting point of aluminum;' according to the FAA. Government action has been opposed by a broad coalition of rechargeable battery suppliers; cellular phone manufacturers; other makers of electronic devices and retail industry groups. Cargo carriers also have raised complaints about proposed Transportation Department rules. Pressure from such industry groups including appeals to White House officials about the cost of special packaging and mandatory installation of advanced fire-suppression systems on all big cargo jets has complicated and delayed government rule making.' I am troubled by an industry and company that is opposed to more stringent rules covering packaging; sizes of battery shipments and the necessary extra training for workers distributing; handling and loading lithium-battery packages. It may be that current rules exempt most lithium batteries along with the devices they power from being declared dangerous goods; they also allow for the boarding of batteries and devices without making the Captain aware of the size and location of battery shipments. It may be technically legal but it is certainly not morally or ethically correct. I am certain everyone has read: SAFO Safety Alert for Operators U.S. Department SAFO 10017 of Transportation DATE: 10/8/10 Federal Aviation Administration Flight Standards Service; Washington; DC How can we pay special attention to ensuring careful handling and compliance with existing regulations covering the air transportation of Class 9 hazardous materials; including lithium batteries if we do not even know we have them onboard?

Data retrieved from NASA's ASRS site as of April 2012 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.