Hazardous Duty

When shipping dangerous goods, shippers, airport and airlines need to bring their A-game. Robert W. Moorman investigates.

September 3, 2010: UPS Airlines Flight 6, a fully loaded 747-400F, was enroute from Dubai to Cologne. It was a typical cargo run for UPS. No weather problems were expected and all onboard systems were operating normally. But an hour into the flight, the crew reported a fire in the cockpit and immediately returned to Dubai International Airport. The pilots missed their first approach into Runway 12L and were coming around for another try when radar contact was lost. The airplane crashed in an unpopulated area not far from the airport. Both Captain Doug Lampy and First Officer Matthew Bell were killed. The United Arab Emirates General Civil Aviation Authority (GCAA,) in its 322-page report, determined that the fire which caused the crash originated in the cargo container holding thousands of lithium-ion batteries, which various regulatory authorities classify as dangerous goods.

The incident provides a stark reminder of the potential dangers of transporting dangerous goods by air. In March 2014, the US Department of Transportation (DOT) issued new standards to improve the safety of lithium battery transportation. Among the standards are new requirements to enhance packaging and hazard communication for lithium batteries transported by air and the adoption of separate shipping descriptions for lithium metal batteries and lithium-ion batteries.

The rule, developed by DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA), in cooperation with the Federal Aviation Administration (FAA), also provides a greater level of consistency with international standards, including the International Civil Aviation Organization’s (ICAO) technical Instructions for the safe transport of dangerous goods by air.

Lithium batteries are just one of many substances classified as dangerous goods. Regulatory authorities define dangerous goods as anything that could harm health, safety or property in transportation. The nine classes of dangerous goods include: Class I, explosive substances; Class II, compressed flammable or non-flammable gases; Class III, flammable liquids; Class IV, flammable solids; Class V, oxidizers; Class VI, toxic and infectious substances; Class VII, radioactive material; Class VIII, corrosive material; and Class IX, miscellaneous dangerous commodities, which could include substances like perfume.

“FedEx Express carries all nine classes of dangerous goods, but there are restrictions on certain subsets of those classifications,” said Marvin Sudduth, manager of dangerous goods administration, FedEx Express.

FedEx Express will not carry toxic gas. It does, however, carry radioactive material, but it is typically for medicines, not spent radioactive material from nuclear power plants, which is carried by rail predominantly.

Here is how shipping dangerous goods at FedEx Express works. The dangerous goods package is offered for acceptance at FedEx Express hub or station. The package must be inspected for compliance before they can be loaded onboard the freighter. [Those shipments deemed not to be in compliance are shipped back to the point of origin.] Once the package is accepted for shipment, the dangerous goods are loaded into specially equipped containers and transported by vehicle to the aircraft.

The driver presents the manifest to the flight crew after which the dangerous goods are loaded onboard the aircraft. The goods will be flown initially to one of FedEx Express’ two primary hubs at Memphis or Indianapolis. Regional hubs are also used to sort goods in the continental US.

Europe bound dangerous goods are sorted at hubs in Brussels, Paris Charles de Gaulle, and Cologne, Germany. Asia-Pacific bound packages are sorted at Guangzhou, China. Latin America-bound goods are sorted at Miami initially before continuing south.

The shipment of radioactive material is the most detailed and complex process, according to Sudduth. Customers must provide sufficient radioactive shielding before the package will be accepted for shipment.

FedEx Express ships approximately four million pieces of cargo per day. Of that amount, 13,000 or more items are classified as dangerous goods, Sudduth estimated.

UPS is also a leader in transporting dangerous goods. It has long advocated for the harmonization of US and international hazardous materials shipping rules. In the US, UPS participated in the PHMSA rulemaking process on updating standards for the shipment of lithium batteries. Internationally, UPS provides input in the International Civil Aviation Organization (ICAO) and IATA’s regulations and standards. It participates in ongoing ICAO discussions on the carriage of lithium batteries, including a recent meeting in Brazil.

Innovation & Training

Both FedEx Express and UPS are credited with developing safer containers for the transport of dangerous goods and other materials. In 2009, FedEx Express unveiled the industry’s first onboard automatic fire-suppression system (FSS). The airline has installed FSS technology on all of its Boeing MD-11s and 777 freighters. Seventy-four wide bodies used for international service were upgraded with FSS.

In 2013, UPS began implementing the use of fire-resistant shipping containers. The containers, also known as unit load devices (ULDs), can contain a fire with a maximum temperature of 1200-degrees for four hours, UPS claims. While enhancing safety, the ULDs are around 40 pounds lighter, which reduces aircraft fuel burn.

In addition, UPS has developed 575 fire containment covers for palletized freight loads. The covers are used primarily on high-energy shipments, such as lithium batteries. UPS claims the covers can contain a 1200-degree fire for four hours. The fiberglass-coated covers are placed directly on bulk shipments and secured with fire-resistant netting.

As for training, every airline is required by law to train all new hires on the acceptance and handling of dangerous goods. Annual recurrent training is also mandated.

Dangerous goods specialists working for FedEx Express and UPS receive more in-depth training. These are the individuals who are required to perform the compliance inspection on all dangerous goods earmarked for air shipment.

At FedEx, the specialists go through a five-day course, which shows them how to identify, classify, package, label and document the dangerous good before it is accepted into the system. The training also shows specialists how to clean up a spillage of dangerous goods.

FedEx Express flight crews also get dangerous goods training, initial and recurrent. “The flight crew gets a snapshot of what dangerous goods are onboard and where they are loaded for every flight,” said Sudduth.

In addition, FedEx, for a fee, provides customers/shippers Public Dangerous Goods Seminars throughout the country. Attendees are taught what is required before dangerous goods can be shipped aboard the airline.

UPS provides a similar course for ground and air personnel. “While we’ve had internal and external training programs in place for years, we have ramped them up in recent years,” said a UPS spokesman.

Not everyone believes that the current level of dangerous goods training for airline personnel is sufficient. “It has been my experience, regardless of mode of transportation, that third party training is not adequate,” said Sam Burton, president of Branson, Mo.-based GSI Training Services, whose clients include Fortune 100 companies that ship dangerous goods.

As to in-house training by airlines, Burton said: “I have only had the opportunity to review a couple of airlines’ training materials and have found them to be lacking the details and accuracy necessary to adequately train their employees.”

Singing the Same Tune

Dangerous goods air transport is tightly regulated on both the international and national levels. Yet shippers and airlines must navigate through a regulatory labyrinth when moving hazardous materials throughout the world.

In the past few years, there has been substantial work on harmonizing US dangerous goods regulations with the international regulations promulgated by ICAO, also known as “Technical Instructions”.

Most ICAO member states follow ICAO’s Technical Instructions verbatim in their own regulations. The US and Canada, however, incorporate the provisions of the Technical Instructions and the UN Model Regulations for the shipment of dangerous goods by road, marine and air transport into domestic regulations. The US every two years has to go through a harmonization rulemaking process for domestic transport of dangerous goods to “harmonize with the international provisions,” specified in the Technical Instructions, said Dave Brennan, assistant director, Cargo and Safety Standards, IATA. Brennan is IATA’s representative on ICAO’s 19-person Dangerous Goods Panel.

The US DOT’s strengthening of the standards for the shipment of lithium batteries is part the overall effort to standardize regulations for the air transport of all dangerous goods.

“Our continuing efforts to harmonize US Hazardous Materials Regulations with international standards improve consistency in procedures and terminology when shipping lithium batteries around the globe,” noted PHMSA Administrator Cynthia L. Quarterman.

Elsewhere, there is safety-enhancing work going on. A call to the Montreal offices of ICAO revealed what this international body is doing to make the air shipment of dangerous goods safer. An amendment strengthening the training standards on hazardous materials contained in Annex 18 is currently being processed, according to an ICAO spokesman. The amendment has completed the State consultation process and goes before the Council in January 2015 for approval of a November 2015 acceptance.

One of ICAO’s principal concerns is that employees of operators not approved to transport dangerous goods by air still need dangerous goods training. This amendment to Annex 18 makes it clear that everyone needs training.

In other efforts, Amendment 38 to Annex 6, Part 1 strengthens dangerous goods training requirements. The amendment introduces a new chapter in dangerous goods classification and makes the training requirements very clear, said ICAO.

In a related development, the ICAO DG Panel is currently considering amendments to the training provisions in the Technical Instructions, which are aimed at aligning with competency-based training principles.

ICAO offers training currently on how to use the Technical Instructions for the safe transport of dangerous goods by air. The Organization is developing a dangerous goods inspector’s course that will be delivered sometime in 2015.

Batteries Above

The US Department of Transportation’s new standards for the shipment of lithium batteries will likely enhance safety. But what about the issue of batteries contained in personal electronic devices that are carried onboard airliners by passengers and crew.

The likelihood of a lithium battery fire onboard a commercial airliner or freighter aircraft is highly unlikely. Yet concern is raised when one considers the number of lithium batteries produced annually that might be defective.

The Rechargeable Battery Association acknowledges that one in every 10 million lithium batteries has a manufacturing defect, typically in the separator that can result in a “thermal overheat.”

On average, there is one lithium battery per person on all commercial airliners flown today. By using the one in every ten million benchmark, this mean that 330 batteries are on commercial airliners every year with the potential to go into thermal overheat. “The end result is an aggregate number that may be more than what we are comfortable with as an industry,” said Capt. John Cox, CEO of Safety Operations Systems, who addressed this concern during the recently held EATS (European Airline Training Symposium) conference in Berlin.

Of greater concern is that the number of lithium batteries being produced and carried onboard aircraft is “rising significantly,” said Cox, a retired US Airways pilot.

Asked about training on handling a lithium battery in “thermal overheat,” Cox said, “There are sporadic pockets of training.” A number of first-tier airlines are beginning to provide general training for flight crews on what to do if the battery of passenger or crewmember’s personal electronic device overheats.

The issue: “There isn’t an industry consensus on what to do with the devices,” said Cox. “The guidance provided by the regulators is outdated and under revision.”

Nevertheless, pilots believe adequate training is imperative. "Effective procedures and adequate training are essential in successfully responding to a dangerous goods incident on an aircraft, especially one involving lithium batteries,” said Mark Rogers, director, Dangerous Goods Programs, Air Line Pilots Association, International. “While all commercial airline pilots are required to receive initial and recurrent training in dangerous goods, these training programs may not always cover the specific actions that need to be taken following a portable electronic device fire involving a lithium battery.

Rogers continued, “ALPA recommends that every dangerous goods training program for flight and cabin crew includes guidance on responding to lithium battery fires, and supports the highest standards overall in dangerous goods training."

In its guidance, published in January 2004, the FAA stated that the suspect device should not be moved. Crew should pour water on the device to cool it. Most crews interviewed informally said they would not pour water on the device in the cockpit for fear of damaging aircraft systems.

In the US, shipping lithium metal batteries in the belly of passenger airliners is prohibited. As for batteries carried onboard, there is not a specific regulation, said Cox. Batteries are permitted in the cabin, but not allowed to be stored in luggage in the cargo holds. Most personal electronic devices are powered by lithium-ion, not lithium metal batteries, which can’t be recharged. Lithium metal batteries typically power devices such as defibrillators, which are allowed onboard airliners.

Training and Trainers

Airlines that ship dangerous goods domestically and internationally are required by law to train new hires and provide recurrent training. There are independent training houses that provide this service but most of their students/clients are air shippers of dangerous goods not airlines.

Various associations provide some kind of dangerous goods related training. The American Association of Airport Executives (AAAE) provides some hazardous materials handling training. But their focus is on training first responders. IATA Training and Development Institute provide numerous dangerous goods (DG) training courses.

Among those courses are: DG awareness training, DG instructional awareness training; DG Instructional Techniques; DG Regulations (DGR) familiarization training, DGR for Shippers and Packers, DGR for Auditors and CAA Inspectors, Infectious Substance Transport Training; and Shipping Guidelines for Infectious Substances, among other courses.

One three-day classroom course reviews IATA’s Dangerous Goods Regulation Manual and international and intermodal requirements. Dangerous goods instructors, airline and cargo training specialists and managers are recommended to attend.

The Airports Council International is not directly involved in the training or handling of dangerous goods. ACI’s involvement is on the management and compliance of FAA regulations. For example: ACI reviewed the 2012 FAA Advisory Circular on the hazardous materials management, primarily related to fuel handling.  ACI does participate in industry forums that could lead to stronger regulations or best practices of the carriage of dangerous goods in an around an airport.

In the wake of the July 2013 crash landing of an Asiana 777 at San Francisco International Airport (SFO), ACI facilitated a series of forums with the airport on lessons learned from that tragedy, which killed three people, including two Chinese nationals, of whom one was run over twice by an emergency response vehicle. A significant fuel and oil leak occurred following the crash, which sparked the fire that consumed much of the downed airliner.

While not classified as a dangerous good in the conventional sense, there is growing concern within the airport and airline communities on what to do when apassenger tests positive for Ebola or another potentially deadly communicable disease. “That becomes a bigger issue when there is a suspected (or positive) case of Ebola on board an aircraft,” said Chris Oswald, vice president for Airports Council International – North America.

Expect more information on this concern in coming months. “It is an area in which the industry has numerous questions, Oswald said. At present, there are no set guidelines on how to handle the issue of infected passengers who, in effect, become hazardous material. At the same time, aviation professionals involved in such an incident do not want to be insensitive toward that passenger suspected or proven to have contracted a highly contagious and deadly infection.