Are You Shipping Hazmat? Also, Bonus Video on Shipping Lithium Batteries

September 7, 2022 by Leave a comment

Aircraft parts are full of hazmat:

  • Batteries;
  • Squibs;
  • Self-inflating emergency equipment;
  • Compressed gas tanks;
  • Passenger service units with oxygen generators;
  • Residual fuel in a component (even if it is just a small amount);

These are just a few examples of the sort of hazmats that aircraft parts distributors see every day. I have received calls from ASA members whose business models did not involve hazmats; but then they received an air carrier inventory with “extra items.” Extra items that included hazmats.

If you receive unwanted or unexpected hazmat from a business partner, you cannot simply return it without thought. You need to make sure that even a return shipment meets the requirements of the hazmat rules. Civil penalties for getting this wrong can easily exceed $100,000. This means that you need to have trained personnel to identify hazmats, and you need to have trained personnel to classify, package, label and ship the package to wherever it needs to go (the training is required and defined by regulation).

Our next hazmat training class is scheduled for October 4-5, 2022. ASA members get a discount and there is also an additional early registration discount. The deadline for the early registration discount is September 13, 2022.

Our training is offered as a live, online class. You can take the class from the comfort of your desk without any travel. Because it is a live class, we can answer your questions in real-time to make sure you are getting everything you need from the class.

Lithium Batteries

If you are shipping lithium batteries, then you may want to check out our free video on shipping lithium batteries. This video is posted on Youtube.

Make sure you are watching the video for the correct year! We started posting these videos in 2021 and each year we post an updated video reflecting the changing rules surrounding lithium battery shipments. The year is part of the title.

Also please note that the training video is meant to be a supplement to our training class. It is a useful guide for shipping lithium batteries but it is not stand-alone training and it does not take the place of training that meets all of the regulatory requirements.

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Shipping Lithium Batteries

January 29, 2021 by Leave a comment

Lithium batteries can be complicated to ship by air. Most people use the IATA Dangerous Goods Regulations but the lithium battery packing instructions are not like most of the other packing instructions.

To make it easier to ship lithium batteries by air, we’ve prepared a video that goes over the special packaging, marks, labels, and documentation commonly required when shipping lithium batteries by air.

You can watch the video on youtube or just watch here on our site:

This is not a stand-alone module; this video training is meant to be a supplement to the full hazmat certification training that we offer. If you haven’t taken that training, then we recommend attending one of our classes so you can understand the scope of your compliance obligations, and then using this video to review how to follow the IATA instructions for shipping lithium batteries (in particular).

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Updates to Lithium Battery TSOs Available for Comment

January 24, 2018 by Leave a comment

The FAA has issued two new draft TSOs related to lithium batteries.  Draft TSO-C142b Non-Rechargeable Lithium Cells and Batteries, and Draft TSO-C179b Rechargeable Lithium Batteries and Battery Systems, each inform applicants for TSOAs or LODAs of the minimum performance standards articles must meet in order to receive approval and identification with the applicable TSO marking.

These TSOs will cancel the old versions of the TSOs (C142a and C179a) six months after the effective date of the new revisions. After that point, all applications for TSOA or LODA must be made under the new TSO revision.  However, the draft TSOs make clear that articles “approved under a previous TSOA may still be manufactured under the provisions of its original approval.”

ASA has reviewed the draft revision TSOs and they do not appear revoke or amend already-approved TSOAs. This means older equipment manufactured to the old TSOs under previously issued TSOAs remain usable, which should give distributors with articles manufactured in accordance with the old TSOs in their inventory a measure of comfort in the face of the revised standards.

If you think these draft TSOs warrant comment we would love to hear from you.  Email ryan@washingtionaviation.com with your feedback.  Comments are due January 31, 2018 so we need to hear from you before then.

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More Limits on Shipping Lithium Batteries?

January 29, 2016 by Leave a comment

Many aircraft parts distributors who ship lithium batteries have been frustrated with the constant change in lithium battery shipping instructions. It looks like change will remain a constant in this field.

The Associated Press is reporting that ICAO may ban lithium batteries from being flown as cargo on passenger aircraft:

A U.N. panel has recommended that cargo shipments of rechargeable lithium batteries be banned from passenger airliners because the batteries can create fires capable of destroying planes, said aviation officials familiar with the decision.

This could result in all lithium batteries being flown under a “Cargo Aircraft Only” limit.  The matter is not yet final – it must be approved by the ICAO Council.  The ICAO council is scheduled to take up the matter in February, 2016.

This appears to reflect a reversal of ICAO’s expected position, as the ICAO Panel on Dangerous Goods voted 11-7 against a ban in October 2015.

In July, Boeing advised air carriers of the dangers of shipping lithium batteries.  As a consequence, many air carriers have already implemented their own voluntary bans – they have made unilateral decisions to refuse lithium battery shipments.

Under the 2012 FAA Modernization and Reform Act, Section 828, Congress precluded the U.S. Department of Transportation from issuing or enforcing any regulation regarding the air transportation of lithium batteries, if the requirement was more stringent than the ICAO Technical Instructions.  This means that changing the ICAO standards becomes an important prerequisite to any increase in U.S. standards.

New Solutions on the Horizon?

Stanford University researchers claim that they have developed a technology that will “shut down” lithium batteries when they reach a certain temperature, preventing them from continuing to contribute to the conditions that contribute to lithium battery fires.  Even if this technology is successful in preventing fires, it could take some time to implement the technology in batteries, and the technology could have other implications in batteries used in aircraft (so it would have to be fully tested).

Watch the Requirements

Because of the frequency of changes in lithium battery instructions, it is important that all shippers ensure that they have the latest versions of the instructions from which they are shipping (whether they use the IATA Dangerous Goods Regulations, the ICAO Technical Instructions, of the U.S. DOT Regulations).  Lithium battery instructions have been changing on a more frequent basis than the three year recurrent training requirements, so more frequent training may be appropriate.

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Battery Shipments Could Get Tougher

July 21, 2015 by 1 Comment

Last week, Boeing issued a warning about transporting lithium batteries on aircraft.  The news media is reporting that:

The guidance sent to airlines around the globe urged that they not carry the batteries as cargo “until safer methods of packaging and transport are established and implemented,” Boeing spokesman Doug Alder told The Associated Press in an email.

IATA has published its own guidance on the subject.  In addition to republishing ICAO’s dangerous goods shipping requirements, IATA has also published its own lithium battery risk mitigation guide for air carriers.

The Portable Rechargeable Battery Association (PRBA) issued a press release on July 20th in response to the Boeing missive that stated:

PRBA–The Rechargeable Battery Association shares Boeing’s goal of improving the safe transport of bulk shipments of lithium ion batteries by air. We look forward to continuing our engagement with Boeing and other aircraft manufacturers, the airline industry and regulators at the ICAO battery meeting in late July to discuss battery transportation issues, specifically a new and unprecedented lithium ion battery standard and packaging criteria.

Ongoing international regulatory initiatives, along with the development of innovative fire suppression technologies and more robust international enforcement efforts are reducing risk and advancing battery safety. Together, these ambitious efforts to improve transportation safety mitigate the need to prohibit air shipments of lithium ion batteries used daily in thousands of consumer, aerospace, medical, military, transportation and environmental applications.

Safety remains PRBA’s No. 1 priority and our members are proud of their outstanding safety record. We also have supported ICAO’s recent regulatory initiatives on lithium batteries, including new stringent packaging and labelling requirements. Billions of lithium ion batteries have been shipped safely by all modes of transportation over the last 25 years. PRBA is not aware of a single incident involving the transport by air of a fully compliant shipment of lithium ion batteries.

PRBA also remains concerned that certification of aircraft fail to consider the unique hazards associated with the carriage of any dangerous goods, not just those associated with lithium batteries.

The FAA continues to press for compliance in this arena, and has announced multiple civil penalty actions related to improper shipment of lithium batteries in the past year.

Distributors shipping lithium batteries should make sure that the batteries are treated as dangerous goods and properly prepared for shipment, but distributors should also be aware that some carriers could refuse to carry lithium batteries in the wake of the Boeing all-operators letter.  It appears that some carriers have already banned the bulk shipment of batteries:

Several airlines have already banned bulk battery shipments from the bellyhold, including Cathay Pacific, United, IAG Cargo and Qantas.

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